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Appendix C: Comments Received by the Committee
Pages 233-255

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From page 233...
... More responses were received from trucking industry groups than from any other category of organization, reflecting in part the specialized interests of segments of the trucking industry in particular features of the regulations that most affect their operations. In addition to indicating the views of the respondents on particular options for changes in federal regulations, the responses read as a whole point out three general issues regarding federal truck size and weight regulation that are sources of concern: 1.
From page 234...
... American Trucking Associations Distribution & LTE Carriers Association Motor Freight Carriers Association National Automobile Transporters Association National Solid Wastes Management Association Western Highway Institute Association of Waste Hazardous Materials Transportation National Private Truck Council .
From page 235...
... Box C-1 (continued) Organizations Asked for Comments Shipper associations National Industrial Transportation League Intermodal Association of North America National Small Shipments Traffic Conference Railroad industry association Association of American Railroads Motorist or safety advocacy organizations American Automobile Association Coalition Against Bigger Trucks Insurance Institute for Highway Safety Advocates for Highway and Auto Safety Surface Transportation Policy Project State transportation departments Connecticut Department of Transportation Florida Department of Transportation Georgia Department of Transportation Idaho Transportation Department Indiana Department of Transportation Michigan Department of Transportation New York State Department of Transportation Texas Department of Transportation Minnesota Department of Transportation New jersey Department of Transportation Other government American Association of Port Authorities American Association of State Highway and Transportation Officials Commercial Vehicle Safety Alliance International Bridge, Tunnel and Turnpike Association National Governors Association 235
From page 236...
... I POLICIES WITHIN EXISTING FRAMEWORK AND PRECEDENTS OF FEDERAL TRUCK SIZE AND WEIGHT REGULATION These do not entail changes in pavement and bridge design practices, basic truck design, or highway user fees.
From page 237...
... I Uniformity: extend federal weight limits now applicable on Interstates to all roads on the 200,000-mi federally defined national network; eliminate grandfather provisions.
From page 238...
... Permitting program recommended in Truck Weight Limits for heavier trucks on Interstates.
From page 239...
... it is intolerable to consider creating circumstances that give drivers less ability to safely operate commercial motor vehicles." If use of larger trucks were expanded, the trucks would be operated by drivers of all skill levels on all roads; limiting use to the best drivers and roads would be impractical. Michigan Department of Transportation The committee should not recommend abolition of existing state grandfather rights under federal size and weight laws.
From page 240...
... be required to be equipped with "the most modern and practical safety crevices available." Arguments: · The experience of the automobile transporters industry shows that liberalizing limits leacis to increased productivity and less truck traffic. Since fecleral law and regulation established nationwide minimum length stanciarcis for automobile haulers, the automobile hauler fleet size has clecreasec!
From page 241...
... 551 as one component of a package of changes in federal law to prevent further liberalizations of state size and weight limits, including repeal of the Symms amendment defining grandfather rights, and defining nondivisible loads in such a way as to close a present loophole in federal weight limits. Arguments: · The 1998 DOT Comprehensive Truck Size and Weight Study found that allowing larger trucks would generate large costs for bridge improvements, for example, $300 billion in the case of extensive use of longer combination vehicles.
From page 242...
... Motor Freight Carriers Association The committee should consider proposals for operations of triples on highways that can safely accommodate them and under conditions that foster safe operations. Such proposals would entail a more lim~ted network of roads and lower maximum weight than the assumptions of the DOT study triples scenario.
From page 243...
... The federal law should compel the state permit programs to have features similar to those of the permit program recommended in Truck Weight Limits (TRB 199Oa) Which referred only to vehicle weights and not lengths or configurational, including safety requirements for vehicles, drivers, and carriers, and accident and mileage data reporting for safety monitoring.
From page 244...
... 9. Changes in federal weight limits [other than DOT scenarios, Peterson-Cook bill, or Truck Weight Limits (TRB 199Oa)
From page 245...
... Western Highway Institute The committee should recommend repeal of the federal 80,000-Ib weight limit now in effect on Interstate highways. States should be alfowed to set higher (but not lowers maximums or to leave weight governed only by the federal axle weight limits and the federal bridge formula.
From page 246...
... American Bus Association The committee should recommend that federal law specify weight limits for intercity motor coaches independent of those applying to trucks or exempt motor coaches from federal weight limits. The legal maximum weight for the tandem axle pair of a motor coach should be no less than 36,000 Ib, and for the drive axle of the tandem axle pair, 22,400 Ib.
From page 247...
... American Trucking Associations The committee should recommend elimination of the federal 80,000-Ib weight limit on Interstate highways. Gross weight should be governed by appropriate axle weight limits and the bridge formula.
From page 248...
... Federal Express Corporation The committee should consider recommending that federal law prevent states from establishing maximum trailer length limits of less than 53 ft for a semitrailer in a tractor-semitrailer combination. Connecticut Department of Transportation The committee should recommend that certain ambiguities in federal trailer length regulations (23 CFR Section 658.13)
From page 249...
... . and our communities appear well served by existing transportation modes." Motor Freight Carriers Association The committee should consider the range of reasonable proposals that have been made in recent years for liberalizing limits to provide increased productivity, including the recommendations of earlier TRB committees on size and weight issues, including Truck Weight Limits and the Turner Proposal study (TRB 199Ob)
From page 250...
... New bridge formula from Truck Weight Limits. National Solid Wastes Management Association The committee should recommend a new bridge formula similar to the one recommended in Truck Weight Limits, either as a state option or as a federal mandate.
From page 251...
... National Solid Wastes Management Association The committee should recommend a permitting program with features similar to the recommendation of Truck Weight Limits as a state option. Arguments: See NSWMA arguments under Option 13 (bridge formula)
From page 252...
... National Automobile Transporters Association "The privilege of hauling additional weight should be indexed into the current heavy vehicle use tax." Michigan Department of Transportation The committee should consider mechanisms to fund pavement, bridge, freeway interchange, and local road upgrades necessitated by any changes in commercial vehicle weights, lengths, and widths. New York State Department of Transportation If federal weight limits on the Interstates are increased, the trucking industry should pay for any improvements necessary to accept heavier loads on roads giving access to the Interstate system.
From page 253...
... III. POLICIES TO MITIGATE THE EFFECTS OF LARGE TRUCKS Such policies would provide a broader range of options for achieving the underlying goal of controlling the costs of truck traffic while allowing efficient freight transportation.
From page 254...
... New York State Department of Transportation In addition to weight, new regulations changing the federal weight limits would have to address suspension characteristics and performance, tire characteristics, maximum weights for axle groups, horsepower-to-weight ratio, and state permitting and fee requirements.
From page 255...
... 1990a. Special Report 225: Truck Weight Limits: Issues and Options.


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