May 7, 2004

SUBJECT: Reducible Loads
DATE: May 07, 2004 (revised)
POLICY: General Reducible Load Policy & Transportation Permit Conditions # 10

OBJECTIVE
To change the current policy for reducible loads in regards to a vehicle or unit being towed by a permitted load. By changing the current "policy" the safety of the traveling public will be increased and the Air Quality problem that we currently have will be decreased.

BACKGROUND
Caltrans Permit Conditions are the parameters established for the movement of "extralegal loads", which has imposed adverse impact on the Transportation Industry and created additional safety concerns of the traveling public and reduced air quality.
California Statutes and Administrative Code Regulations, which preempt Caltrans Permit Policies, establishes guidelines for permit policy. These include:
" CVC 320.5 that provides for "reasonably reduced" loads,
" CVC 35780 that provides that if "good cause appears", and
" Government Code Section 11340(d) that provides "prescriptive standard ........ where performance standards could reasonably be expected to produce the same results......".
The Legislature has provided guidelines that support the requested changes. The requested changes are "reasonable" and will not adversely affect the safety of the general motoring public, but will improve air quality and reduce traffic counts.

EXISTING DOCUMENTATION
Caltrans Transportation Permit Conditions section #10 Reducible Loads:
1. This permit is issued for the movement of an "Extralegal Load" as defined in C.V.C. 320.5 when loaded at its least dimensions.
2. This permit is automatically canceled if the permitted dimensions and weight can be reduced to legal limits by repositioning and/or practical removal of a part, portion, or unit therefrom
3. This permit does not authorize extralegal weights if the load can be repositioned to stay within legal axle or axle group weights authorized in C.V.C. 35551 or 35551.5. If the load cannot be repositioned, the weights shown on the permit are authorized.
4. Other items may be hauled in addition to the permitted item provided they do not exceed the dimensions of the vehicle or permitted item (whichever is greater) and the loaded vehicle is of legal axle and gross weights.

CURRENT PRACTICE
Transportation Permit Policy allows the crane to extend the boom to the front 25' or 35' to the rear at the operator's option, therefore increasing the operational length and road width requirements of the vehicle. Also the crane can use a legal weight boom support trailer/dolly at their option.

Current permit policy also allows non-qualifying hauled loads to be permitted on one leg of a permit move if a qualifying load is moved on the return trip.

PROPOSED CHANGES
Transportation Permit Conditions
" We are requesting that the Transportation Permit Policy, in specific, Permit Condition #10 Reducible Loads be modified to add condition No.5, ..... Self-propelled single permit vehicles may tow a legal size motorized vehicle or trailer within the legal combination length limits for the highways traveled.

BENEFITS / IMPACT / JUSTIFICATION

BENEFITS
The Safety of the traveling public will be increased due to the number of self-propelled permit vehicles that would not be used to travel back and forth from the job-site, but rather left on-site and the vehicle that was towed to the job would be used.

There would be a decrease in Air Quality with the use of a smaller vehicle traveling back and forth from the job-sites on a daily basis. Presently the Industry has to use 2 vehicles and 2 employees to shuttle vehicles to the job location and if there is any distance involved, due to the Federal and State Regulations regarding Hours of Service, the driver is generally out of hours and the crane can't leave.

There would be less damage to the roadways by the limited use of these cranes on the highway.
This would also increase profitability to the job-site in setting up and tearing down a crane at the end and beginning of each shift.

IMPACT
Extra weight on a structure would not be impacted by the extra 4,000 to 5,0000 lbs. It would not increase the axle weight of the crane but rather the gross weight and we don't believe that it would be significant.
Traffic and congestion would be impacted considerably less.

JUSTIFICATION
A legal weight crane can legally tow a vehicle from behind as can a Motor home tow a boat and a jet ski at the same time as long as they stay within legal limits. The only criteria that changes on a crane is generally weight. The width, height, and length even with the vehicle being towed are within legal limits other than the weight of the crane. It has been permitted for that weight and can legally travel. The issue of safety hasn't changed, but rather because we are over weight on our axles, we can no longer tow the vehicle we need to be able to leave the crane on site or even get to a hotel for the evening. We are requesting the change in the best interest of Public Safety, Air Quality and better Congestion Management.

Respectfully submitted,

Gregory D. Dineen
Industry Transportation Consultant