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May 2007
Caltrans – 7, 8 & 9-axle
Annual Permits approved
Pending Implementation -
1) Annual Permits for 7, 8 and 9-axle:
Caltrans, after five years of discussion, has agreed to approve Annual Permits for 7, 8 and 9-axle vehicles.
This proposal was submitted on October 29, 2002. The roadblock to approval always seemed to be a structure issue.
We agreed to review all the bridge data in California on the mainline routes to see how extensive the problem really is. Caltrans was concerned that there were structures where theses loads would bee too heavy to traverse without causing damage to the structure. We submitted the bridge data information regarding the structures that were going to be weight problems for Caltrans review.
Based on the information that we supplied to Caltrans, there shouldn’t have been any reason that an annual permit shouldn’t be issued. Our position is there is no reason to restrict the entire state, but only a very few bridges where these vehicles can’t travel.
Caltrans, after extensive review has approved the 7, 8 & 9-axle Annual Permit but the program will not be implemented right away due to a couple issues.
The first issue is the long-delayed Transportation Permit Management System (TPMS) Permit program; there will not be any approved proposals implemented until TPMS is rolled out and then it would be 90-days after that before any changes to the system can be made.
When will this happen?
Soon, is what we have been told since November of 2005.
Second, Caltrans must develop a system to monitor the number of trips of overweight vehicle over any particular structure, due to a bridge collapse over Route 246.
Legislative hearings on the bridge collapse were held and questions about annual permits and their monitoring and tracking came up. It was clear that Caltrans system did not have sufficient controls or monitoring over annual permits. This lack of controls still exists despite many improvement measures instituted.
We will be working with Caltrans to develop a system that will be sufficient and not burdensome on industry.
Pending Caltrans approval -
2) Allow the Issuance of Laden Multi-Vehicle
Combination Annuals not to exceed established weight:
This proposal was rolled into one, with the 7, 8, and 9-axle Annual, but is still under review. Current permit policy authorizes un-laden 9-axle annuals up to 110,000 pounds of gross weight with pilot car, Jeep or mechanical distribution unit loaded while returning from or going to pick-up a qualifying load. Economics and business decisions have changed over the years and it is time that we eliminate traveling empty when there is an opportunity to have a payload when available. We would like to expand the current un-laden annual that allows 110,000 pounds of gross weight by authorizing any payload as long as the gross weight does not exceed 110,000 pounds.
El Dorado County – Insurance and Route Survey requirement
We were contacted by members in El Dorado County due to changes in their Transportation Permit requirements. There were two issues and the first was additional insurance being required to obtain a permit and the second was requiring a route survey for each load. The Route Survey alone would be a financial impact and delay to the industry.
We contacted the County and explained that they can’t require additional insurance in lieu of a permit per CVC 35782 unless the load is an “unusually large or heavy load.” The problem for local agencies is that there are several, sometimes conflicting, other state regulations, such as:
35782. (b) The Department of Transportation or a local authority may not require the posting of a bond as a condition of the issuance of a permit, except that a requirement of extra insurance or other financial security may be imposed as a condition for a permit for unusually large or heavy loads that pose a substantial risk to public facilities.
(c) Except as provided in subdivision (b), the Department of Transportation or a local authority may not require proof of financial responsibility in an amount greater than that required for compliance with Section 16500.5 as a condition of the permit, and shall accept evidence of financial responsibility that complies with Section 16020.,
16500.5. (a) Except as specified in subdivision (b), the owner of the following commercial vehicles shall maintain proof of financial responsibility in the amount required by the director:
(1) A vehicle used to carry passengers for hire, except taxicabs as defined in subdivision (c) of Section 27908.
(2) A vehicle having an unladen weight of over 7,000 pounds, which is used in the transportation of property in the conduct of a business.
16020. (a) All drivers and all owners of a motor vehicle shall at all times be able to establish financial responsibility pursuant to Section 16021, and shall at all times carry in the vehicle evidence
of the form of financial responsibility in effect for the vehicle.
(b) “Evidence of financial responsibility” means any of the following:
(1) A form issued by an insurance company or charitable risk pool, as specified by the department pursuant to Section 4000.37.
The following issues are potential problems:
1. Insurance requirements increased -
- Before: The County was requiring that “You will need a Certificate of Insurance naming the County as additionally insured for 1 million General Liability, $2-million for Automobile Liability, and Excess Liability of $5-million per occurrence.”
- After: The County is now requiring that “You will need a certificate of insurance naming the County as additionally insured for at least the amount required by the California Vehicle Code (see sections 34630 thru 34632)”.
The California Vehicle Code only requires a minimum insurance of $750,000 the same amount that is required to operate in the State of California under a Motor Carrier Permit.
2. Traffic Control and Route Survey
- “Traffic Control and Route Plan with diagrams, indicating turn out locations and narrow road sections”.
The County under the Health, Welfare, and Safety of the public is requiring route surveys with a “reasonable drawing.” The County is in need of the route data for their roads and requiring industry to pay for the data showing route restrictions through these required route surveys.
We understand their need for the information and we believe industry can supply that information without burdening industry with turning in a route survey for every load, every time. This would be a cost to industry that is unnecessary of routine loads. As we explained if a 16’ high load can travel a certain route then the next load that maybe 15’- 10” is going to clear that same route. This requirement is an unnecessary and burdensome process for both the county and industry.
We are hoping to have a resolution to this issue soon.
Contra Costa County – To issue Annual Permits
We received word that the county has agreed to the concept of issuing Annual Permits. As with most agencies, staff and extra time to work on additional projects is limited, but they have agreed to work with industry to assist them. We will be working with the county on developing the policy and procedures for the issuance of annual transportation permits, application requirements, permit conditions, list of applicable roads with load limits, etc…
Sacramento County – Changes have changed again
We recently met with Sacramento County staff to review changes that were agreed upon with industry on October 10, 2006 and additional changes went into affect January 1, 2007.
The County’s staff has become very difficult to work with; changes are made without any consultation, justification or notification. These employees appear to be suspicious of industry intent and contentious when industry makes suggestions for improvement in their procedures.
The county made it clear that they reserve the option to make any changes, any time!
a.) Annual/Repetitive Annuals
In our original discussion on over-dimensional permits, the county agreed to take away limitations on dimensions their current Annual Permits, saying “if we give these dimensions to one company, then we need to give them to everyone.” We had no disagreement; a company is only going to ask for dimensions that they are going to need. It was finally decided that if a company wanted an additional dimension on their Annual Permit, the county would issue a separate permit and name it a Repetitive Annual Permit. If industry wanted this type of permit, the company would have to run a route survey over those particular routes that they could justify by certifying those routes in writing. This seemed to solve the problem.
Two things changed since our first meeting:
- The county had no provision in its current ordinance to allow for issuance of repetitive permits, but they have been issuing this type of permit for years. They also haven’t offered to go to the Board of Supervisors to change the ordinance.
- At our October meeting, when industry disagreed with the increased charges for permits and copies, they came back to tell us “fine, then we will charge you $90 for all permits.” Another example: they increased the cost for copies from the first 5 copies $7 and any additional $5 to $47 each to start charging for each permit. Their justification for the increase: the permit writer’s time is worth $98 per hour! Note: County staff decided to change the Permit Fees structure and after years of allowing copies at a lower cost they felt copies were meant to be used only in case you lost one or wanted to keep the original in the office and the a copy in your truck (the first 5 copies $7 and any additional copies will be $5).
Again, we agreed to this change in the original Annual Permit because there was going to be another option. Because the county wasn’t able to come through with what was agreed, we are going to have to work out other arrangements.
b.) CHP Escort/Escort Requirements - After a lengthy discussion, we agreed that CHP is the preferred agency of the County of Sacramento, but if they are busy, you may contact the County Inspector or any local enforcement agency.
Industry is concerned about the clarity of the current language that the county is using on the Transportation Permits Application Process and Guidelines. The guidelines should not be misleading and should clearly explain the options if CHP is busy, so that industry wouldn’t have to sit for days waiting on the services when there are other options available.
Rules and regulations should be clear and precise no matter who reads them and currently it states “CHP Escort Requirement”. Permittees don’t know there are other options that may save their customers a considerable amount of transportation cost by knowing all the rules ahead of time. This is a poor example of communication. The staff stated if permittees ask or express a hardship they will see what they can do; almost as if they will do them a favor!
We find this approach unsatisfactory and will pursue it further.
c.) Restricted Movement Times - This change had taken place and implemented since our last meeting without any industry input. The county revised their permit requirement and added revised this new the language: “No movement of loads exceeding allowable (legal) dimensions are permitted between the hours of 7:00AM – 8:00AM and 3:30PM – 6:00PM. Loads exceeding weight limits are allowed if dimension limits are not exceeded.” (Revised as of 3/28/07)
Industry has two requests:
- Modify the curfew time in the afternoon from 3:30 p.m. back to 4:00 p.m.
- We are requesting that the county modify dimensional limits and allow loads up to 10’ wide travel through curfew. Caltrans restricts all loads exceeding 10 ft. wide only, excluding height, length and weight to travel through curfew. The county agreed that their lane widths are mainly 11’ wide. These same loads at 10’ wide travel the other 20-½ hours and there have been no complaints of lane violations. As an example: we have cranes companies that are affected by this restriction and transportation companies that have empty 10’ wide trailers that can’t go to or from their yards. We feel that both these requests for modification are reasonable and staff will consider our requests.
Holiday Moratorium Requirements
In accordance with Section 7-8.06 of the Standard Construction Specification and in complying with the intent of these requirements, the County of Sacramento instituted their annual Holiday Season Moratorium. This moratorium restricted construction within county roadways, house moving work that interferes with public traffic and transportation of permitted loads on specified county roadways during the Thanksgiving four-day weekend and most of the month of December.
In December of 2006, the construction industry expressed the financial hardship that this requirement has on the industry and other county businesses. The industry felt then, as it does now, that the Section 7-8.06 of the Sacramento County Standard Construction Specifications applies to work being conducted in the roadway, not interstate commerce and/or equipment transportation.
Tom Zlotkowski, Director of the Department of Transportation issue a memo December 21, 2006 that suspended the moratorium as it related to trucking and house moves until after the 2006 holiday season. At that time, the county pledged to evaluate the concerns expressed by the trucking industry.
County staff said they would not discuss this issue in our latest meeting. Industry requested that this not drag out until the holidays come back around again.
d.) Void Permits in Construction Zones
Industry expressed a concern regarding the proposed text stating that transportation permits in construction zones are void. This would apply to any type of construction, center median work, curb and gutter work or any type of construction that doesn’t even necessarily affect through traffic. We informed the county that all permit loads require pilot cars or aren’t excessively wide. There should be no reason that the permit is void in a construction zone.
At our last meeting staff agreed to revise their text to indicate that the permit holder is responsible for not proceeding into a construction zone and other routes should be used to avoid these locations if possible, but has since decided not too. The staff said a situation took place where a wide load traveled through a construction zone and knocked down 4-5 miles of cones. We still don’t believe that because of an isolated incident that the entire industry be burdened.
After the meeting, I personally traveled on Watt Avenue from Elder Creek Rd north of Business 80, through several construction zones. Watt Avenue was three lanes in each direction and there would be no reason for a permit load to have a safety reason to detour unless it was a variance load. If it is a variance load the permit office should be routing the load around these types of construction projects.
We see no justification to consider a permit void while traveling through a construction zone.
We will be scheduling a meeting in the near future to express the need for these changes and how they affect efficient goods movement and the how it effects the transportation construction industry.
City of Los Angeles – Public Works Meeting on April 9, 2007
We were invited to attend a meeting at the request of the Board of Public Works because the City Council is trying to reach out to the Construction Industry to improve bids on city projects. Councilmember’s have realized that they are not getting the bidders they need and want to do what they can do better to attract contractors. The meeting goal was to get input from the Industry. We were there to make sure that we didn’t lose sight of transportation issues. We submitted the following as part of industry comments that will be given to City Council.
There are a few issues affecting the construction community from a transportation perspective.
- Mayor’s order/policy “No Construction in the street/roadway during Peak Hours, from 6:00 a.m. to 9:00 a.m. and 3:30 p.m. to 7:00 p.m., only allows 6-½ hours a day to work. If you have import or export on the project, the trucking industry is only able to work a portion of the day (part time). Street Services continues to want this policy to include trucking/crane movement. If Street Service pushes this forward, this would be a major impact on all projects, plus the impact to interstate commerce. We understand the concerns of traffic congestion, we all experience it, but we feel the curfew restrictions should be reduced.
- Street Services continues to make changes that impact our industry, without any consultation. There must be a resolution to this problem. The city should partner with industry on all changes that will ultimately affect us. The most recent example was again without notice; Street Services included the Mayor’s order of No Construction during Peak Hours to v include Oversized Transportation Permits. This took weeks to resolve and is now back to it original requirements.
- Board Report #05-1569, July 2005 – Ordinance Change: These approved changes are and have been affecting the way contractors do business in the City of Los Angeles. We are suffering from unreasonable delay in producing the final language for changes that have been approved by the Council. These changes were to fix costly delays and we are not seeing any light at the end of the tunnel.
Los Angeles has become a better place to do business since we started working on transportation issues 8-1/2 years ago, but we continue to have roadblocks put in front of us, in terms of partnership and consultation. The cost of not having the ability to move efficiently, affects every project in the City of LA. If a contractor can’t transport their equipment to and from the project in an efficient manner, everyone loses.
We have members who avoid working with the city because of these and other issues. We have tried to be the catalyst between the problems and make the transportation permit process seamless. It hasn’t always been easy, but without help from Jim Gibson, Executive Officer for LA City Board of Public Works, we would have never accomplished what we have. That being said, Jim isn’t always going to be there, so we need to have mechanism in place to safeguard what has been accomplished and assure that industry will always be at the table during discussion anytime a change may affect the way we do business. That is what is called being business-friendly and if the city wants more contractors to bid work and be competitive, then transportation has to be included.
City of Indio – Annual Permit’s were going to be changed
We met with the Public Works Staff, Police Chief and a Commercial Officer to discuss the changes. We explained that we had working on truck routes (for over two years) and the city officials agreed that there were no reason to make any changes to their permit requirements. These were the proposed changes that were not implemented:
- Annual Permits – The new changes would require all Annual Permit holders to notify the city prior to each move pending approval. Public Works is open Monday thru Thursday 8:00 to 4:30 and Friday 8:00 to 12:00. It was agreed, if there were any emergency closures the City will notify Annual permit holders, rather than requiring them to notify the City on every move
- Peak Hour Travel Restriction – It was agreed that a peak hour curfew wasn’t necessary. They want to implement a Peak Hour curfew from 6:30 am to 8:30 am and 4:00 pm to 6:00 pm citywide.
Internet Permit Program (IPP) - Streamline Permit Issuance
We are currently working with a local city agency on an on-line permit program that that would be beneficial to other agencies throughout the state (cities and counties). This Internet Permit Program (IPP) will allow permits to be issued on-line 24/7. This will help both local agencies and industry to streamline the permit process. We have already been talking to several agencies up and down the state regarding this on-line system.
Our goal is to have uniform permit system that will be used by permitting agencies. We still have agencies that the permits are issued manually. This program will be made available to any agency at no cost, because of the substantial benefits to industry, as it is a major step toward uniformity and streamlining the permit process.
Respectfully submitted,
Gregory D. Dineen
Industry Transportation Consultant
cc: John Hakel, AGC D. Cash Benton, SCCA
Richard Paine, ECA Sam Meyer, MCOG
Richard Lambros, BIA Lee Brown, CDTOA
Aimee Shook, DCA Jeff Hunter, CTTA
Michael Vlaming, COA Michael Lewis, CIAQC
Doug Ball, SC&RA |
