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October 12, 2003
Clayton White
City of Los Angeles
600 S Spring Street
4th Floor
Los Angeles, CA 90014
Dear Clayton:
The Industry is recommending changes in
your permit regulations presently being administered.
CURRENT REGULATION:
- Hours of Operation
"…On Saturdays, moving is prohibited during
the hours of 12 noon to 12 Midnight. This permit is
not valid on Sundays or on the following holidays-New
Year's Day, Memorial Day, Independence Day, Labor Day,
Thanksgiving Day and Christmas Day unless specifically
authorized by the Board of Public Works. "
LA City Ordinance - Section 62.138 (c) Any overload
on any Saturday, Sunday, or on the following holidays:
New Year's Day, Memorial Day, Independence Day, Labor
Day, Thanksgiving Day and Christmas Day; provided, however,
that the Board may permit overloads to be moved on Saturday,
Sunday, or any of such holidays if it finds that the
movement of the overload may be made safely and without
undue interference with traffic. Such permission, when
granted, shall be included in and made part of the permit
required by section 62.136.
REQUESTED CHANGE:
- Caltrans currently allows weekend
movement; green weight loads are 24 / 7 without a pilot
car, purple weight is restricted from 3:00am to 9:00am
Saturdays and Sundays.
- Caltrans is currently changing
their weekend movement policy to allow 24 / 7 movement
for purple weight and pilot car movement.
- Los Angeles County is also currently
reviewing their policy to become uniform with Caltrans.
This City Ordinance clearly
states that permits can be issued on Weekends and Holidays,
rather than being denied because it is a residential area,
and not a commercial area. We have a member that is located
within the City of Los Angeles; the company is located
1.29 miles from the freeway. They cannot travel to and
from the freeway because of these outdated regulations.
This is disrupting local business.
We recommend, that due to traffic volume during the week,
that all permits be allowed 24 / 7 movement rather than
on weekends, with the exception of loads exceeding 10'
wide during the current curfew hours. This would eliminate
the current problem with the City of Los Angeles, which
interrupts local businesses from performing their day-to-day
business. These situations do not appear to follow the
City's efforts toward promoting a "Business Friendly
Environment." The City should be concerned that local
businesses are able to conduct business efficiently rather
than dictating what days of the week they may work.
CURRENT REGULATION:
2. Curfew Travel
"... Moving is prohibited on Mondays through Fridays
during the hours of 7:00 a.m. to 9:00 a.m. and 4:00 p.m.
to 6:00 p.m."
REQUESTED CHANGE:
¨ Caltrans and Los Angeles County have curfew restriction
for loads exceeding 10' wide. The curfew restriction is
for loads exceeding 10' in width. Which means that loads
are permitted to travel 24/7, including annual permit
loads, including unladen travel.
We recommend the City
become uniform with Caltrans and the County of Los Angeles's
current curfew travel policy.
CURRENT POLICY
3. Insurance
Why do Insurance Certificates
continue to delay permits? We have been informed that
it takes up to 3 days to have an insurance certificate
processed.
REQUESTED CHANGE:
We recommend the City evaluate their current system to
help expedite the process and eliminate unnecessary delays.
CURRENT ORDINANCE:
4. Inspection Loads
"…Section 62.137 (e) OVERLOADS - WHEN UNLAWFUL
TO MOVE WITHOUT INSPECTION: (E) waiver by The Board"."
The Board finds that movement may be made safely, without
damage to the pavement or undue interference with traffic,
the Board may waive the requirements of this section".
REQUESTED CHANGE:
There have been two ordinance changes to this section
since it's original date, some 60 yrs ago. This section
has had some type of change on July 7th, 1940 and December
18th, 1956.
When there are multi loads traveling over the same route,
similar types of loads dimensions similar and an Inspector
has inspected the first load and there are no problems
making the delivery, an Inspector should not be required
for each load. Example: 24 railcars going to the Gold
Line project over a period of 1 month, everything identical
and each load were assigned an inspector. The Cost to
the Contractor and the Consumer is approximately $7,000.00.
When this ordinance was adopted, I don't believe that
they took into consideration the number of identical loads
that may take place. The Ordinance does address discretion
of travel, but it is not being taken into consideration.
We recommend that the
ordinance be modified to allow multiple loads that are
similar, travel over a similar route and have demonstrated
to have been transported safely, the Inspector be waived.
CURRENT ORDINANCE:
"… Section 62.146 OVERLOADS - INSPECTION. -
The charge established by the Board for each 4 hours,
or fraction thereof".
REQUESTED CHANGE:
Can we both agree that the charges for the inspectors
are to cover the costs of the inspector?
I have a few questions:
a) How many inspections
does an inspector do in a single shift?
b) If the Inspector does 2-3 inspections, maybe more is
our Industry compensated back for the 12 hours we were
charged for the 3 possible moves, when the inspector may
have only worked 6 - 8 hrs?
c) When is inspector considered to be on overtime, what
time is that?
d) If an inspector has to come in an hour early, why is
the Industry being charged overtime for the entire 4 hours?
It should only be the hours during overtime, not the entire
shift.
e) Are we being charged the fraction thereof on any moves?
We would like to see a review of these charges to verify
the charged hours and the hours billed to the Industry
are accurate.
CURRENT REGULATION:
5. Street Use Permit
We have been receiving
many complaints from the Crane Industry regarding the
cost of street closures and delays to obtain the permit.
There have been problems in the past with damage to sidewalks
and now it has forced the cranes to sit further in the
street, in order to do their job safely.
Some of the problems we would like to bring to your attention:
REQUESTED CHANGE:
a. Having to work at Night or Sundays, which require more
of a cost, not including being inconvenienced, but double
time for Sunday. The Police Commissioners office must
also be notified, which takes 30 to 45 days. Charges can
be $3000.00 to $4,000.00 including traffic control, drawings
and permits. This cost needs to be minimized.
b. We have the problem with the cost of the permits, and
exactly what the cost is for. When you request a lane
closure, one is generally requesting the parking lane
and the first lane of traffic. That is not the problem.
The problem is when the crane needs to do the pick in
a safe manner, and may need part of another lane. Why
is it that when you are trying to do a procedure safely,
you are penalized considerably?
For example: you arrive
on the project to replace an air conditioning unit on
the top of a high rise. You sent your company representative
out prior to the job to inspect, and he feels that you
are fine with the one lane closure. The crane arrives
on site and the experienced operator feels that he needs
to be further out. However, he cannot move now because
the one lane closure was all that was asked for. That
Crane Operator should be able to make that decision and
not affect the project at the time.
When the operator goes
ahead with a pick for fear of a job shut down, rather
than let the roadway absorb a change in traffic for a
short time, the cost is public safety. Let's not forget
that a business that is trying to conduct itself with
out the convenience of air conditioning could go much
longer without it if a new permit must be procured. The
choice is between a business full of people, or a short
delay in traffic. There are alternate routes for traffic
but not an alternate plan for a building without proper
ventilation.
Why is the contractor
being charged by the square-foot when it is necessary
to close a second lane for safety purposes? If there is
a closure, whether it is one lane or two, why is the difference
such an exorbitant fee? What is this fee paying for? We
are working for businesses within your city that are already
looking for the reasons to continue doing business in
the City. Why would you not want to be working with local
businesses rather than look for another reason to increase
their costly project or job? The cost should not be anymore
than what the city is consuming in revenue for the closure.
It is almost as if the city is leasing or renting street
space, and if that is the case under what authority is
this being done?
We recommend the fee
schedule that is presently being administered be reviewed
and demonstrate that Industry is only paying for the cost
of the closure. We are also recommending that the charge
for a single lane closure or a double lane closure be
the same and not by the square foot, if you should need
the extra lane for safety reasons. We are using the street,
not leasing it to perform work within the city in a safe
manner.
6. Customer Service
We have noticed a favorable
change in Management's attitude and enthusiasm to communicate
and work with Industry. We do, however, continue to receive
complaints on how city employees at the permit counter
are failing to demonstrate good costumer service, and
appear to be expressing a lack of concern and helpfulness.
We realize that within the July 2nd Board Report, item
#7 the city was to review Customer Service. Perhaps the
city has not yet completed its study?
We are making these requests
with the support of the following organizations: S.C.C.A.,
A.G.C., E.C.A., B.I.A., C.D.T.O.A., and the Operating
Engineers, Local 12. HERO has also obtained support from
Caltrans Headquarters in Sacramento, the California Highway
Patrol Commercial Enforcement also in Sacramento. The
Industry, Government, and Enforcement are all looking
for uniformity within the permit system. These few requests
are minimal and with your support, the City of Los Angeles
can be a part of the solution to this statewide problem.
With the cooperation of Caltrans, Counties, Cities and
the Industry as a whole working toward safety, we can
make our roads safer for the traveling public.
SAFETY IS ENHANCED BY
UNIFORMITY
If you should have any questions,
feel free to contact me at (760) 249-HERO (4376).
Sincerely,
Gregory D. Dineen
Industry Transportation Consultant
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