Multi-State, Multimodal, Oversize/Overweight Transportation (2016)

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1 S u m m a r y Introduction Oversize/overweight (OSOW) cargo is among the fastest growing segments of freight, with some states reporting 50% growth in OSOW cargo movements over the last 10 to 15 years. Moving OSOW freight is complicated for a number of reasons, including infrastructure constraints, regulatory restrictions, and permitting processes. OSOW transportation can be significantly more complicated when moving OSOW cargo across state lines because regula- tions, permitting processes, and available information about routes often differ by state. This patchwork of regulations, permitting processes, and available information can result in inefficiencies in multi-state OSOW transportation, which can lead to increased costs for carriers and shippers, as well as for the society more broadly. The intent of this research project is to provide an information resource—a guidebook— to describe the current OSOW transportation regulatory and permitting landscape in the United States, to identify and define the challenges associated with multi-state OSOW trans- portation, and to suggest options to address these challenges. Why should multi-state OSOW transportation inefficiencies be discussed? For carriers and shippers, it is about efficiency of process and routing, minimizing time and cost, and promoting safe and reliable transportation. For the public sector, it is about minimizing impacts on bridges and roads, avoiding disruptions, and reducing negative externalities and social costs, while promoting safety and commerce. Challenges in Multi-State OSOW Transportation OSOW carriers and shippers are unanimous in citing inconsistent road transportation regulations and permitting processes across state lines as the dominant and overarching challenge to efficient multi-state OSOW transportation in the United States. Carriers must plan for and adapt to differences in state regulations, such as the maximum permitted axle weight limits, civilian and police escort requirements, and truck configuration restrictions when moving OSOW cargo across multiple states. The conceptual map (Figure S-1) highlights the extent of the inconsistencies in OSOW road transportation regulations and permitting processes across the United States based on an index representing a combination of OSOW regulations, operational restrictions, and permitting requirements. The thicker the line along a state border, the greater the inconsistency or regulatory and permitting “friction” between the neighboring states. During consultations with the research team, one carrier noted that the barrier for multi-state OSOW transportation was sometimes so great that it felt like there were 48 countries under one flag. Multi-State, Multimodal, Oversize/ Overweight Transportation

2 multi-State, multimodal, Oversize/Overweight Transportation Notwithstanding state differences in OSOW road transportation regulations and permit- ting practices, OSOW carriers and shippers identified the following as the most significant multi-state OSOW transportation challenges: Challenges in the Permitting Process • Long or varying processing time. The processing time for OSOW permits can vary greatly by state. Some states issue OSOW permits quickly, using automated permitting systems, but some states issue permits manually, taking more time. For larger loads, or when local permits are required, turnaround times can be several weeks. There is also a great deal of inconsistency in the number of days in advance of a move that carriers can apply for a per- mit and the total number of days a permit is valid. • Limitations in state permitting budgets. States are increasingly encountering constrained budgets, which limit staffing, purchase of new permitting software, and the overall abil- ity to analyze OSOW permits in an effective and efficient manner. OSOW routes become increasingly circuitous as the infrastructure condition worsens and the number of restricted bridges or roadways increases. Figure S-1. Barriers to multi-state OSOW road transportation.

multi-State, multimodal, Oversize/Overweight Transportation 3 • Inconsistent permit amendment rule. Some states grant amendments or extensions to permits to accommodate a delay, a breakdown in equipment, or a necessary route change, but some states do not issue amendments under any circumstance. In these cases, carriers must reapply for a new permit subject to the same process, information requirements, and timelines as the original permit, which can further delay the move. • Differences in permit applications and permit system interfaces. The advent and broad adoption of online application systems have improved the efficiency of obtaining OSOW permits in certain states, though different permit application systems and processes in different states can make applying for multi-state permits cumbersome. • Local permit requirements and utility notifications. It can be a challenge to obtain infor- mation about local infrastructure and utility restrictions and clearances, when required. This information, along with associated contact information, is typically not available from State Departments of Transportation (DOTs) and must be researched by carriers. The local permitting process may also take longer to issue a permit, thereby delaying the move. Challenges in Communication and Coordination • Unanticipated construction along a planned OSOW route. Construction projects can vary on a weekly basis and are not easily factored into OSOW routing plans, especially for those planned far in advance. Construction projects are also a problem when OSOW loads move across state lines as permitting agencies in one state may be unaware of construction along the same route in a neighboring state. • Local infrastructure investment decisions and OSOW transportation. Local road invest- ment decisions may not adequately reflect the needs of OSOW transportation on OSOW corridors. Local construction of roundabouts with fixed signage or tight turning radii, or the presence of unmovable structures in the center island on a port access road, an inter- state, or the on and off ramps of highways are classic examples. This challenge may stem from local control over design and build specifications, though it is also likely a failure of road planning coordination. Challenges in Operational Restrictions • Hours and days of operation. States and local jurisdictions specify the hours, time, and days of the week that an OSOW load is allowed to move. Often allowed hours and days of operation are different across state lines. For example, one state may require daytime travel while the neighboring state may require nighttime travel. Some states also restrict OSOW transportation on weekends, in varying degrees. Generally OSOW carriers can plan for this but unforeseen delays or rerouting could result in loads having to wait at state borders until allowed to travel in the state. • Requirements for police escorts. Police escorts are often required to accompany larger OSOW loads, but related requirements often differ across states. From an operational perspective, carriers have to work around the hours police will work, plan with district offices, and plan for exchanges at jurisdictional boundaries, all of which contribute to delays and increased costs. • Frost and thaw restrictions. Frost/thaw restrictions, which place seasonal limits on the axle weights allowed for OSOW loads, notably in northern United States, can differ by states. Carriers may need to add axles for a move, route around a state, or wait until the restriction is no longer in effect. These challenges can lead to delays in moving OSOW loads and increased costs for carriers. For example, if an OSOW load is required to wait at a state border due to allowable hours of

4 multi-State, multimodal, Oversize/Overweight Transportation operation regulations, the carrier will incur additional labor costs and may also incur addi- tional costs associated with civilian or police escorts. When a move must be rerouted around a state due to regulatory restrictions in that state, the carrier incurs higher fuel, labor, and other operating costs. In some cases, carriers must also invest in additional trailers or related equipment to meet the specific truck configuration requirements of the state. These increased costs are ultimately largely passed on to the shippers, in one form or another. Public Costs of Inefficient Multi-State OSOW Transportation On top of the additional costs incurred by carriers and their shippers, there can be very real costs imposed on society when OSOW loads are routed sub-optimally because of regulation- or restriction-induced circuitous routings. These external costs, which include increased wear and tear on roads, emissions from fuel consumption, or disruptions on roadways, are passed on to society as a whole. A number of case studies—based on actual moves—were used to demonstrate the social costs of inefficient, multi-state OSOW transportation resulting from OSOW regulations and permitting. In one case study involving a 250,000 lbs move from Pennsylvania to Texas, the carrier submitted permits on a route through Pennsylvania, West Virginia, Ohio, Kentucky, Tennessee, Arkansas, and finally Texas (Figure S-2). The carrier was approved for weights in all states but Tennessee, which resulted in the load being routed around Tennessee. It was estimated that this sub-optimal route led to a 27% increase in social costs (e.g., emissions, pave- ment impacts), among other external costs that can’t be quantified (e.g., traffic disruptions, bridge impacts), compared to the more direct route. Other case studies—also based on actual moves—revealed an increase in social costs associated with routing OSOW loads around states because of regulatory and permitting inconsistencies across states. These findings point to a commercial, economic, and social impetus to address the challenges of OSOW transportation outlined in this research. Opportunities to Improve Multi-State OSOW Transportation Initiatives are being taken to improve multi-state OSOW transportation. FHWA and AASHTO have taken an active role in advancing the harmonization of OSOW regulations through research and meetings of AASHTO Standing Committee on Highway Transporta- tion (SCOHT). Certain states have also sought to better coordinate OSOW transportation, such as Minnesota and Wisconsin, which have collaborated to designate regional OSOW corridors. Opportunities to improve OSOW transportation identified as part of this research proj- ect complement and in many cases support these efforts. These opportunities are outlined below, organized by thematic heading. Opportunities to Improve Information • Build an inventory of OSOW regulations and permitting requirements. This report and the associated interactive website, www.osowfreight.com, provide a consolidated inventory of OSOW regulations and permitting requirements. The Specialized Carriers

multi-State, multimodal, Oversize/Overweight Transportation 5 & Rigging Association has agreed to continue to update and maintain the interactive website after the completion of this research project. State DOTs should leverage this facility as a clearinghouse for information and provide updates directly to the Special- ized Carriers & Rigging Association as and when changes in regulations and permitting processes justify. • Develop state-level fact sheets on OSOW regulations and permitting requirements. Notwithstanding the interactive website, states can improve and simplify OSOW regula- tions and permitting requirements by developing and making available simplified and consistent fact sheets on OSOW regulations and permitting requirements. This could be aligned with the content and structure of the interactive website. AASHTO may be best placed to facilitate a consistent fact sheet structure. • Improve the availability of information on city and county OSOW regulations and permitting requirements. State DOTs may require carriers to seek permission to use roadways that are maintained by non-state institutions, including toll authorities, cities, and counties (local jurisdictions), but DOTs often do not provide the related details. A relatively simple solution would be for state DOTs to compile and make available Figure S-2. Case study of OSOW route from Pennsylvania to Texas.

6 multi-State, multimodal, Oversize/Overweight Transportation information on the roadway segments that require carriers to contact the local jurisdic- tions, along with the contact information of these jurisdictions. In time, this information could be included in the interactive website, www.osowfreight.com. • Improve the availability of information on physical constraints and restrictions. Car- riers take necessary steps to ensure that they can clear all physical constraints along their route. But there would be value in DOTs making available route-specific bridge clearance and maximum load information, which is not currently always available. The State of Washington’s “State Route Bridge Vertical Clearance Trip Planner” is a useful model for making such information available. • Improve the availability of information on utilities. Utility notification and involve- ment was repeatedly cited as costly and time-consuming for OSOW carriers. State DOTs could facilitate access to information on the owners of relevant utilities through city- or county-level government representatives. The Georgia National Joint Utility Notification System provides an example of a potential utility focused model. The availability of utility maps and contact information will decrease the cost of complying with utility notification requirements. Opportunities to Improve the Permitting Process • Streamline permitting processes and provide greater information on expectations. The number of steps and complexity of the permitting process typically increase with the size of the OSOW load. In certain states, there is a lack of clarity with respect to expecta- tions and timelines for obtaining permits. State DOTs should seek to simplify the process and provide more information and notifications about permitting requirements and the associated timelines. • Set clear expectations for turnaround time. OSOW permit turnaround times are key to scheduling an OSOW load and deploying equipment. States should specify and commit to the turnaround times for permits. States such as Illinois update carriers by email and on their website if they expect delays, which is a good practice. It would also be a good practice to measure and track performance with respect to permit turnaround times. • Make use of technology to facilitate permitting and route planning. Technology is increasingly being used by DOTs to automate routine permitting and to identify suitable routes. The adoption of automated permitting platforms or other electronic permitting technologies is not yet widespread across all state DOTs. There are costs associated with the adoption of these technologies, but the benefits can be significant, both for the DOTs and the industry. • State permitting fees to reflect the full cost of the move. States should ensure that the permitting fees charged for OSOW loads reflect both the administrative cost of issuing the permit and the differential damage done by heavier overweight loads. This may result in higher permitting fees, but consultations with carriers suggest that this would be welcome if it also led to commensurate improvements in the permitting process. Opportunities to Improve Communication • Build greater DOT capacity and understanding of industry needs. State DOTs would benefit from having greater knowledge of carrier operations, carrier issues, and carrier routing decision factors and this report will help to increase awareness in these areas. Beyond this and to identify important state-specific issues, it would be a good practice for DOTs to hold regular working group meetings with OSOW carriers, as is done at the Arizona Overdimensional Permit Council and Illinois’ bi-annual industry outreach meetings, to review OSOW permitting issues and updates. Another example may be the participation of OSOW carriers on state freight advisory committees.

multi-State, multimodal, Oversize/Overweight Transportation 7 • Establish direct communication with carriers and provide regular notifications. State DOTs should have regular communications with carriers on permitting updates, changes in regulations, or route issues. Illinois DOT communicates regularly by email with carri- ers and carrier associations, which is seen as a useful and simple model. Illinois DOT also uses its automated permitting program to convey messages to the industry. Oportunities to Improve Multi-Jurisdictional Coordination • Harmonize OSOW regulations and permitting processes. Harmonization efforts are taking a variety of different forms throughout the United States. AASHTO is in phase two of its harmonization initiative, which involves research and recommendations for specific OSOW issues. Harmonization requires buy-in, adoption by individual DOTs, and in some cases legislative changes. • Improve jurisdictional coordination. When states route OSOW loads within their ter- ritory, they often ignore constraints that may occur across the state line in a neighboring state, such as construction or a weak (load posted) bridge. More formalized communi- cations with neighboring states are a relatively simple way to improve coordination of OSOW permitting and route planning with those states. The Canadian New West Part- nership (NWP) model is an example of best practices. When one NWP member province proposes a change to a regulation, all members look at the regulation. NWP members also jointly look at opportunities to remove multi-jurisdictional barriers. In the United States, the various AASHTO subcommittees and subregions serve a similar function, but the relationship is not necessarily institutionalized. Institutionalized communication ensures that a base level of communication occurs regardless of changes in staffing or priorities. • Integrate local permitting. A number of states as well as other international jurisdictions have pursued the integration of local OSOW permits into their state permitting processes, whereby local permits are obtained through the state DOT. For example, local permits in Maryland are obtained from the Maryland DOT. This system is also in place in Alberta, Canada. • Improve the implementation of multi-state permits. Some states have pursued multi- state permitting for routine OSOW loads. Examples include the Western Regional Permit and the WINNDOT Cross-Border Permit. The adoption and use of multi-state permits has for the most part been limited because regulations and operational differences across state borders continue to exist. Some carriers have also noted that it is faster to obtain individual permits along a route than a multi-state permit, particularly where individual state permits are issued by an automated process. This research study suggests that the industry prefers uniformity in the requirements for permits to multi-state permitting. Opportunities to Improve OSOW Planning • Better leveraging of OSOW data obtained by state permitting offices. Some states reported that OSOW data are not used for any other purpose outside of permitting. Data obtained as part of the permitting process, including information about the origin, des- tination, routing, size, and dimension of a load, can be a rich source of data for a variety of purposes and should be better leveraged within DOTs for policy, planning, and pro- gramming functions. • Using OSOW data to identify and plan for OSOW corridors. By leveraging OSOW rout- ing data, state DOTs can identify the roadways that have the highest use, the first and last mile connectors to other modes, and OSOW generators. This data can be used to define OSOW corridors as well as help with the related planning needs and the associated engi- neering specifications for these corridors.

8 multi-State, multimodal, Oversize/Overweight Transportation Opportunities to Better Leverage Multimodal Options Some have suggested that rail and marine transportation offer potential alternatives or complementary means of moving OSOW freight long distance. Multimodal options are already being considered by shippers, forwarders, and brokers and there are no notable gaps in their understanding of rail and marine transportation options. In fact, consultations with carriers of all modes, shippers, and brokers revealed significant knowledge about competing modes, including rules of thumb for when each mode is competitive and the advantages and disadvantages of each mode. Relative advantages and disadvantages of modes in OSOW freight transportation. Road Rail Waterway Advantages Disadvantages Advantages Disadvantages Advantages Disadvantages Access Weight Weight Width Weight Speed Speed Height Height Speed Height Access Ease of Use Price Price Access Width Ease of Use Width Permi ng Mul-Piece Move Ease of Use Mul-Piece Move Price Source: CPCS analysis of modal consultations Multiple consultations suggested that while there is competition between the modes, it is limited to specific subsets of the market due to the unique access, cost structures, and infrastructure restrictions for each mode. OSOW-appropriate roadway connections to rail and marine facilities should be improved and included in the broader freight corridor planning efforts. • Regional integration of OSOW corridors. According to a survey of the states under- taken by the research team, most of the communication and data sharing on OSOW issues among neighboring states is informal and depends on working relationships. Many of these relationships have been established through activity in multi-state organizations, including AASHTO’s Regional Associations. Joint identification, coordination, and plan- ning of OSOW corridors could help in the planning of multi-state OSOW corridors. Conclusions This report identifies challenges associated with multi-state OSOW transportation and puts forward several options to address these challenges. Many, particularly within industry, believe that harmonization of state OSOW regulations and permitting practices is the obvious answer to most of the challenges. Greater harmo- nization would no doubt improve the efficiency of multi-state OSOW transportation, but harmonization is by no means easy to achieve. The level of state coordination, negotiation, compromise, and research and analysis required to advance harmonization, along with the significant associated time and cost, make this solution difficult, if not impractical as a singular focus in the short to medium term. It is also unlikely that OSOW transportation issues garner sufficient attention at state DOTs to energize a serious institutional push toward harmoniza- tion. And those on the front lines in state permitting offices have little incentive or resources to

multi-State, multimodal, Oversize/Overweight Transportation 9 push for change, particularly when such change could be perceived—correctly or incorrectly— as potentially compromising safety or infrastructure preservation. This is not to suggest that harmonization of state OSOW regulations and permitting requirements should not be a vision, nor that efforts to advance harmonization are not worthwhile. On the contrary, these represent positive steps forward and are well received by the OSOW transportation industry. But these efforts—as challenging as they are—should not detract from other, more easily achievable, and incremental opportunities to improve OSOW transportation. Improving the availability and consistency of information on physical infrastructure con- straints and restrictions, setting clearer expectations on permit turnaround times, involving OSOW stakeholders on state freight advisory committees, and including a review of OSOW needs, issues, and corridors within the scope of statewide freight plans are all relatively easy to achieve and relatively low-cost incremental steps that individual states can take to improve OSOW transportation in the short term. As an information resource, this report and the associated interactive website, www. osowfreight.com, will inform the efforts to achieve incremental improvements to OSOW transportation as well as encourage bigger, bolder, and longer-term discussions to advance harmonization. An immediate next step could be a joint summit of state DOTs and OSOW industry stakeholders to discuss the findings in this report and the opportunities to effect incremental improvements.