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June 28, 2004
CTPAC - PROPOSAL
SUBJECT: Allow Maximum Chart Weight
For Fix Load Vehicles Section 305.2.1
DATE: June 28, 2004
POLICY: CTPAC -WG7 - 062804 - 001
OBJECTIVE
Change the current permit policy that identifies a fixed
load vehicle as a reducible vehicle unless the design
dictates the need for the extra-legal size or extra-legal
weight. Then policy limits axle weights to the actual
scale weight plus 700 pounds. Change Permit Policy and
authorize up to maximum Green or Purple axle weight for
fixed load vehicles. Authorizing chart weight for fixed
loads will place them on the same level playing field
as hauled loads. This change will minimize CHP enforcement,
expensive and unnecessary design changes, and less Caltrans
involvement. Allow Permittee to eliminate jeep if not
needed.
BACKGROUND
Caltrans Policy has always identified a fixed vehicle
as a reducible vehicle even when the Department has no
expertise to discuss many vehicle concepts. These vehicles
are subject to an Inspection prior to permits being issued.
The Inspectors assume all component are necessary and
do not question there need while documenting all necessary
information regarding the vehicle dimensions and axle
weights. The Inspection report is then issued and the
said vehicle is authorized an additional 700 pounds for
undocumented components.
EXISTING DOCUMENTATION
Caltrans Transportation Permit Manual section No. 305.2.1
Fixed Load Vehicles:
305.2.1 General
"Operations of extralegal weight fixed load vehicles
under permits are controlled by the orange, green or purple
standard overload charts. Permit weight will not be authorized
for reasonably reducible loads or for portions of loads
which are not necessary to perform a primary and singular
task at the job site, e.g., drilling, servicing pumping,
and testing. Extralegal weight permits may be issued for
critical operational components such as sand line, drill
rod, drums etc., as long as these components do not cause
the weight to jump to the next higher level, etc. (green
to purple)
Extralegal weight will not be allowed on motor vehicles
where the equipment required to complete the prime function
may be reasonably transferred to a single or tandem axle
trailer and the combination complies with axle an gross
weight, nor where the motor vehicle can be made legal
by the addition of another axle or the use of a longer
wheelbase chassis."
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.
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
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.
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 Fixed Load Vehicles
to obtain a transportation permit based on the original
inspection weight plus 700 lbs. If fixed load vehicle
exceed the permitted axle weights the permittee is issued
a Misdemeanor citation along with a Permit violation,
which may put their company in jeopardy of losing their
permit privileges. If a fixed load has become heavier
due to repairs it may be re-inspected and allowed more
weight, provided that it stays within chart weight.
PROPOSED CHANGES
Transportation Permit Conditions
We are requesting that Fixed Load Vehicles in the Transportation
Permit Manual be changed to authorize maximum Green or
Purple chart weight per their respective axle weights.
Like hauled loads, if the fixed load vehicle exceeds permitted
axle weights, corresponding overweight citations are applicable.
BENEFITS / IMPACT / JUSTIFICATION
BENEFITS
Safety is not jeopardized in any way. This change will
increase safety by making it easier to be compliant with
Caltrans weight policy. Currently due the fact that if
you're close to being legal permit weight, even though
you're not necessarily over your chart weight for your
axle, you are more apt to avoid scale faculties. There
is no one who wants to take the chance receiving a citation.
This will also eliminate the Industry time in court over
citations that they normally wouldn't receive if they
were allowed full chart weight
The Courts will not have to take the time to deal with
citations that are considered Misdemeanors. Business Owners
and Attorney's are currently required to attend appearances
to represent their companies.
The 700 pound allowable overweight is so small, that Industry
has made it a common practice to take parts off these
units to make weights and have the parts hauled on a separate
truck. This practice continues to cost the Industry and
the Consumers. Conversely, Industry has been forced to
add unnecessary weight to their units to build in a reasonable
safety margin. This weight is removed after an inspection
report is obtained.
Air Quality is a factor in our request - less Trucks on
the roads equals less pollution.
Public Safety is a factor in our request, less Trucks
means fewer miles, fewer accidents, and fewer traffic
fatalities.
Congestion Management is a factor in our request, less
Truck miles equals less congestions.
IMPACT
The impact of receiving unnecessary citations and jeopardizing
a companies permit privilege, could result in putting
a company out of business.
When the rules are so strict or unfair, it forces company's
to avoid the scales whenever necessary, taking longer
routes and posing more of a safety concern.
JUSTIFICATION
Currently fixed load vehicles are being modified to remove
their running gear and hauled as a load on a trailer to
eliminate the reducible load policy.
For example, Crushers on their own running gear and weighing
56,300 lbs, will be allowed an extra 700 pounds of permitted
weight for a total of 57,000 lbs. We can take that same
Crusher, cut the axles out from underneath it (which we
are doing) and put it on a lowbed trailer with the same
axle configuration and be permitted 60,000 lbs., regardless
of the actual axle weight. Additionally overweight misdemeanor
citations are being issued if they exceed the reducible
load weights and the permittee is spending time in court
over this issue.
This continued problem is only raising the stress level
of the drivers that are being put in position of not knowing
if they are close on their axle weights. Drivers wonder
if they have taken enough handrails off or panels to bring
the unknown weight down. When we talk about 700 lbs tolerance,
you are hoping that the steel plate that they had to weld
on to repair the crusher doesn't put you over weight.
The weights of asphalt silos fluctuate with accumulated
build up after the day-to-day use. Again, we are not asking
for increase in weight to exceed chart weight, only the
chart weight that you are already allowing.
A fixed load that is 1000 lbs over green weight is routed
as maximum purple weight (41,000 - 46,000 = 5000 difference,
compared to 41,000 + 700). Structures department only
knows maximum green or maximum purple weight.
The Industry has invested an enormous amount of money
into State of the Art Equipment and even older equipment
in their fleets. They purchase components for this equipment
that is expensive and then are dictated by Caltrans that
they will only let you take with you the equipment required
to complete the prime function. This practice may have
been something that was acceptable in the past, but times
have changed. You need to be ready and prepared immediately
of a jobsite change or even and emergency situation. These
are function changes depending on job-to-job requirements.
We are not asking to be in excess of chart weight, but
rather the maximum chart weight that is already being
authorized to the Heavy Haul Industry.
We are requesting the change in the best interest of Public
Safety, Air Quality, and better Congestion Management
and to better the Economy of California.
Respectfully submitted,
Gregory D. Dineen
Industry Transportation Consultant
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