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

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12 C H A P T E R 2 2.1 Overview of OSOW Transportation OSOW loads come in all shapes and sizes. The loads may be oversize, overweight, or both, and use truck, rail, or marine, or a combination of modes, to reach their destination. In the context of trucking, OSOW loads are defined as those that are beyond the legal truck size and weight limits. OSOW movements trigger permitting and operational restrictions on travel. Oversize/Overweight Transportation Truck Size and Weight Limits1 Truck size and weight limits vary by state. Generally, for a semi-trailer confugura- tion, trailers are 48 ft to 65 ft long, 8 ft 6 in. wide, and 13 ft 6 in. to 15 ft high.2 Colorado and Iowa have set the legal height of trucks at 14 ft 6 in. and 13 ft 6 in., respectively. Weight limits are typically around 80,000 lbs. Federal truck size and weight regulations are applicable to specifically designated roadway networks. Federal length and width limits apply to the national net- work which is about 200,000 miles (which constitutes about 5% of all mileage). Weight regulations only apply to the interstate system, which consists of about 47,000 miles (which constitutes about 1% of all mileage).3 State exemptions based on grandfathering or state-specific legislation affect truck size and weight regulations. State departments of transportation (DOTs)4 and local governments are responsible for regu- lating the movement of OSOW loads on roads to ensure safe operations and to minimize infra- structure wear and tear, among other aims. Once a truckload surpasses legal weights and dimensions, it typically needs approval in the form of a permit from the state DOT to travel on state-maintained roadways and a permit from the city or county to travel on city- or county-maintained roadways. 1 Unless explicitly stated, the dimensions used in this report are for a loaded trailer, meaning that the reported height includes the height of the load and the height of the trailer. 2 Federal Highway Administration Should Conduct Research to Determine Best Practices in Permitting Oversize Vehicles. Govern- ment Accountability Office. http://www.gao.gov/assets/670/668711.pdf. Accessed November 3, 2015. 3 Federal Highway Administration Should Conduct Research to Determine Best Practices in Permitting Oversize Vehicles. Govern- ment Accountability Office. 4 OSOW permits are generally issued by state DOTs, but in some states other agencies such as the Department of Motor Vehicles, Department of Revenue, or state law enforcement issue permits. DOT information on bridge and roadway characteristics are key in these states in forming permitting policies and assessing whether to permit an OSOW load.

Oversize/Overweight Transportation 13 There are no comparable governmental permitting requirements for the movement of OSOW loads by rail or water, though there may be technical, operational, or commercial barriers to using these modes. Multi-state OSOW transportation—which is the focus of this report—can be particularly chal- lenging for road transportation. OSOW truck carriers and their customers are frequently subject to inconsistent treatment of the same load as it crosses jurisdictional boundaries. One carrier con- cluded, “Each U.S. state has their own oversize load restrictions. From a heavy-haul point of view, it is like there are 48 countries under one flag.” Appendix A provides an inventory of state OSOW permitting requirements for the transportation of OSOW loads by road. State DOTs have over- sight of OSOW loads moving by road as compared to loads moving by rail or water, which gen- erally do not fall under state DOT jurisdictions. Therefore, the process of moving OSOW loads by truck is first explored, and then the movement of OSOW loads by rail and water is assessed. 2.2 OSOW Load Permitting There is no standard definition for the types of OSOW loads and often the thresholds are dif- ferent by jurisdiction. A study conducted by the New Jersey DOT in 2011 found that states have between one and 23 different types of permits with an average of six per state.5 The following OSOW typology was developed for this research project, which generally categorizes three dif- ferent types of permits: • Routine OSOW load permits • Superload permits • Megaload permits Each category is progressively more restrictive by either triggering additional regulations or by increasing the depth of oversight, analysis, or planning required before and during the move. Each state defines the weight and dimensions of routine OSOW loads, superloads, and mega- loads differently, as exemplified in Figures 2-1 and 2-2. Generally, states west of the Mississippi require permits once loads reach larger dimensions and higher weights compared to states east of the Mississippi. Similarly, routine OSOW loads and superloads start at higher thresholds in the west. Megaloads are defined on a case-by-case basis encompassing the largest OSOW moves, often taking months if not years to organize. Each permit type begins at the maximum weight and dimensions in the previous category, triggering permits and restrictions on movement. The threshold between superloads and mega- loads is ambiguous, with very few states defining separate permits or restrictions for megaloads. OSOW regulations differ by state and the overall size of OSOW loads. The following discussion is provided as a general overview of some of the major OSOW regulations encountered during the permitting process and the movement of OSOW loads, referred to as operations going forward. • Load configuration regulates the maximum allowable axle weights, trailer configurations, including the positions of lift axles or special restrictions on lift axles, and the use of special dual lane trailers. • Frost/spring/thaw restrictions limit the maximum allowable weight for axles depending on the time of year. • Escorts require one or more vehicles to accompany the load through the route. Escorts may be civilian or police and may require state certification for operation or additional equipment such as a height pole for identifying overhead obstacles. 5 Titze, C. Oversize/Overweight Permitting Practices Review. New Jersey Department of Transportation, 2011. http://www.nj.gov/ transportation/refdata/research/reports/NJ-2011-002.pdf. Accessed November 16, 2015.

14 Multi-State, Multimodal, Oversize/Overweight Transportation Divisible Load versus Non-Divisible Load While OSOW freight is largely thought of as large, non-divisible loads, many states issue OSOW load permits for divisible loads. Non-divisible loads are defined by FHWA as loads that if separated would: • Compromise the intended use of the vehicle, • Destroy the value of the load or vehicle, or • Require more than 8 hours to dismantle.6 Divisible OSOW load. Source: Lehr Logistics Divisible load permits are often available for specific commodities, such as forestry products, milk, containerized cargo, and cotton, and are often implemented as a weight exemption. For example, the figure above displays multiple steel products on one trailer. One or more of the steel products could be removed in a reasonable amount of time without compromising the vehicle or the load. Therefore, the load would be classified as divisible, but allowed to travel in states with a divisible load permit on steel products. Divisible load permits allow the carrier to operate under specific dimensional limits, such as over the legal weight, but under the legal length, width, height, and overhang dimensions. According to FHWA’s 2013 Annual Freight Data, from 2008 to 2012, non-divisible trip permits accounted for 75% of the loads measured.7 • Permitting identifies the length of time it takes to process a permit application to the total number of days a permit is valid. Other issues in permitting relate to whether a state allows for extensions or revisions to the filed permit and the total fees for issuing the permit. • Minimum clearance is the minimum distance from the top of the load to the bottom of an overhead obstruction. • Hours of travel restrict travel during specific times in a city, county, or state. These restric- tions typically involve restricted travel at night or on holidays. They may also restrict travel on weekends partially or completely. 6 Oversize/Overweight Load Permits. Federal Highway Administration, 2014. http://www.ops.fhwa.dot.gov/Freight/sw/ permit_report/index.htm. Accessed November 3, 2014. 7 Freight Facts and Figures 2013. Federal Highway Administration, 2014. http://www.ops.fhwa.dot.gov/freight/freight_analysis/ nat_freight_stats/docs/13factsfigures/pdfs/fff2013_highres.pdf. Accessed October 27, 2014.

Oversize/Overweight Transportation 15 • Utility notification requires OSOW carriers to notify utilities along the route to identify over- head lines that will need to be lifted during the move. Figure 2-3 displays the regulatory and permitting differences between states for each permit type. Many of these regulations differ across state lines. Appendix A explains each permit, pro- vides examples of how each permit is implemented, includes a national map of regulations and permitting requirements by state, and explains how each regulation may contribute to delaying an OSOW load at state borders.8 Permit Type Length Width Height Weight Legal 75  8  6 in. 14  80,000 lbs Roune load 150  16  17  250,000 lbs Superload Over 150  Over 16  Over 17  Over 250,000 lbs Megaload Case-by-case Case-by-case Case-by-case Case-by-case Source: Perkins Motor Transport Figure 2-2. Permit weights and dimensions west of the Mississippi (typical). Permit Type Length Width Height Weight Legal 65  8  6 in. 13  6 in. 80,000 lbs Roune OSOW load 100  14  6 in. 15  6 in. 120,000 lbs Superload Over 100  Over 14  6 in. Over 15  6 in. Over 120,000 lbs Megaload Case-by-case Case-by-case Case-by-case Case-by-case Source: Perkins Motor Transport Figure 2-1. Permit weights and dimensions east of the Mississippi (typical). 8 To develop descriptions and maps, the research team scanned existing literature and regulations. As a starting point, the team used SC & RA’s permit manual, data collected for a study of OSOW harmonization funded by FHWA for AASHTO SCOHT, and state DOT permit manuals. The data was then validated through a survey of state permitting offices conducted in September 2014. The permits are ordered based on priorities identified by SC & RA through member feedback and the consensus of its permit policy committee. Roune OSOW Load Superload/Megaload Civilian Escorts Civilian Escorts Hours of Travel Police Escorts Axle Weights Hours of Travel Bridge Posngs Axle Weights City and County Permits Bridge Posngs Construcon City and County Permits Frost/Thaw Restricons Construcon Frost/Thaw Restricons Ulies Configuraons Source: CPCS research Figure 2-3. Regulatory and permitting differences between states.

16 Multi-State, Multimodal, Oversize/Overweight Transportation Additionally, because each state issues permits for its state alone (with the exception of regional permits), carriers must interface with each state separately, taking construction, infra- structure restrictions, and regulatory differences into account when planning their route. Asym- metry between neighboring states increases the chances of higher operating costs or delays in following compliances. 2.3 Routine OSOW Loads Routine OSOW load permits include single-trip permits and multi-trip permits for com- mon loads. Routine OSOW permits face less restrictions on their movement and the need for escort vehicles, and require less coordination and planning to facilitate movement between jurisdictions. 2.3.1 Single-Trip Permits Routine single-trip permits are used by carriers to move a load one time from origin to destina- tion. Routine single-trip permits can be issued for loads that are larger than the loads that require multi-trip permits, but the loads must be smaller than superloads.9 These permits are generally applied for individually within each state of travel and are valid for a set number of days along a specific route. The size of routine single-trip permits coincides with the thresholds for one or two escorts, a height pole on the lead escorts, and restrictions on the hours of travel in many states. State DOTs begin to place a greater level of scrutiny and additional operational requirements when OSOW loads begin to exceed state-specific thresholds. Depending on the state, route, and dimensions of the load, a routine single-trip permit can be issued instantaneously or take a couple of weeks, if a route or bridge analysis is required. In general, as the dimensions of the load increase, difficulty in obtaining a permit also increases. This is directly related to concerns over safety, impact on infrastructure, and the possibility that the load could disrupt the flow of traffic. Figure 2-4 displays the relative number of permits issued for both single trips and multi trips in the United States during 2012. Single-trip permits (encom- passing routine load, superload, and megaload permits) make up the vast majority of permits issued, identified through FHWA’s commercial vehicle enforcement activities. Multi-trip permits allow for more than one trip per permit, which could result in more than one OSOW trip travel- ing under the same permit compared to single-trip permits. 2.3.2 Multi-Trip Permits Multi-trip permits, also known as annual or seasonal permits, are typically issued for specific commodities or industries, or for repetitive loads that are only slightly over the legal weight or dimensions. In many cases, multi-trip permits have minimal oversight from permitting offices and have minimal restrictions on their movements. For example, one of North Carolina’s multi- trip, non-divisible permits allows for unlimited travel on all North Carolina highways if the load is less than 12 ft wide, 105 ft long, and 13 ft 6 in. high and subject to the maximum axle weights. The load doesn’t require escorts and may travel at all times if it is within legal dimensions and less than 112,000 lbs; otherwise it is restricted from sunrise to sunset Monday through Saturday. North Carolina’s multi-trip permit is similar to multi-trip permits issued by other states, making it easy for these loads to travel throughout the state.10 9 Superload permits generally begin at 100 ft to 150 ft length, 14 ft 6 in. to 16 ft width, 15 ft 6 in. to 17 ft height, and 120,000 lbs to 250,000 lbs weight. 10 Oversize/Overweight Permit Handbook. North Carolina Department of Transportation. https://connect.ncdot.gov/business/ trucking/Documents/Oversize%20Overweight%20Permit%20Handbook.pdf. Accessed November 17, 2015.

Oversize/Overweight Transportation 17 Therefore, while multi-trip permits are important to the industries that use the permit, the carriers are likely not experiencing significant inefficiencies in multi-jurisdictional movements, especially within the state. In many jurisdictions, the primary intention of multi-trip permits is to facilitate movements of economically important goods. Many states use multi-trip permits to increase the efficiency of important state industries. These permits allow industries such as agriculture, forestry, steel, construction, or energy to apply for permits for heavier weights or loads that are only slightly larger than the legal limits. Additionally, some multi-trip permits allow for divisible loads, often acting as a weight exemption for the shipper (Figure 2-5). States may require a minimum number of axles for an overweight load in order to meet the axle weight specifications. For instance, North Carolina Source: Freight Facts and Figures 2013 Note: Multi-trip permits are also known as annual permits. 79% 6% 4% 11% Non-Divisible Single Trip Permits Non-Divisible Annual Permits Divisible Single Trip Permits Divisible Annual Permits Figure 2-4. Distribution of routine OSOW load permits in 2012. Source: Tony Fischer Photography Figure 2-5. Divisible OSOW load.

18 Multi-State, Multimodal, Oversize/Overweight Transportation allows 90,000 to 132,000 lbs depending on the number of axles in a multi-trip sealed-container permit.11 Many states allow for the permitting of international cargo containers shipping international commerce above the legal gross vehicle weight under an OSOW permit. 2.4 Superloads When a load extends beyond the maximum dimensions or weight of a routine single-trip permit, it is subject to additional permitting requirements and possibly to a superload specific permit. Superload permits often trigger additional requirements, including route surveys, bridge reviews, additional civilian escorts, police escorts, longer permit processing times, limited hours of travel, and utility notification and involvement. Some states have a special permit for superloads and other states use the same permit for rou- tine OSOW loads but add restrictions on loads that are above state-specific weights and dimen- sions. Superload permits are often more expensive than routine OSOW permits because of the incremental cost structures by weight, distance traveled, or dimensions. Additionally, carriers often use more expensive equipment to carry superloads, which increases the cost. OSOW shippers and carriers may move superloads using rail, but often the dimensions, primar- ily the width, do not fit the envelope for rail. According to the Railway Industrial Clearance Asso- ciation, most railroad infrastructure is constrained between 13 ft and 13 ft 6 in. width. Additionally, OSOW loads more than 12 ft 6 in. wide are often difficult to move by rail. Water transportation is often limited by the lack of water access near the origin and destination of OSOW loads, as well as the adequate landside infrastructure to move loads in and out of the port. Superloads require significantly more preparation from both a permitting and an organiza- tional standpoint. Depending on the size of the load and the route, a superload can take anywhere from a few days to several months to be permitted. Superload permits may require a route survey, which involves a personal verification of vertical and horizontal distances to ensure clearance and turning radius. As the weight of a load increases, bridge analysis is often required, which increases permitting time and cost. Superloads also require additional support vehicles such as police escorts, bridge monitors, and lift trucks needed to move overhead wires (Figure 2-6), as well as extra civilian escorts. Superloads often have additional restrictions on their hours of travel, which limit their daily progress. Each additional restriction adds to the time and cost needed for planning and executing the move. These restrictions are in effect to ensure that the increased size of superloads do not substan- tially increase the risk of an accident. From a carrier perspective, as the number of people needed for each move increases, the overall cost of equipment used increases, as does the cost of delay. 2.5 Megaloads Megaloads encompass all loads above the superload category and often take months or years of planning and coordination. Megaloads can be well over 800,000 lbs and require five trucks doing a combination of pushing and pulling to move down a roadway. By virtue of their size and weight, megaloads often use the entire roadway to spread out the weight of the load over hundreds of tires. In addition to being heavy, megaloads are often long due to the space needed to accommodate the number of axles and tires. Carriers and permitting 11 Sealed Ship Containers. North Carolina Department of Transportation, 2014. https://connect.ncdot.gov/business/trucking/ Documents/Sealed%20Ship%20Container%20Permits%20C-11.pdf. Accessed October 27, 2014.

Oversize/Overweight Transportation 19 Source: Perkins Motor Transport Figure 2-6. Lift truck clearing overhead wires for a superload. 1.8 Million-Pound Transformer Move A transformer for a wind farm in Utah was constructed in China. It weighed 1.8 million lbs and was 415 ft long and 25 ft wide. The load was transported by boat to Houston, Texas, where it was loaded onto a train and traveled to New Mexico. The transformer was then trucked from New Mexico through Arizona to finally arrive in Monticello, Utah. The transformer took six trucks and a crew of 17 to move from New Mexico to Utah. The load traveled through Arizona at 12 miles per hour, according to the Arizona DOT. Extensive planning and organization were needed to ensure that the large configuration could navigate each turn and hill and safely pass over each segment of the roadway.12 Megaload using dual lane loading, trunnion axles, and push trucks. Source: Rocky Mountain Power 12 1.8 million-pound oversize load set to move through Arizona. Arizona Department of Transportation, 2015. http://www.azdot.gov/ media/blog/posts/2015/10/28/1.8-million-pound-oversize-load-set-to-move-through-arizona. Accessed November 17, 2015. offices must map and analyze all portions of the move to ensure that the equipment and mega- load can safely traverse intersections, wires, and the roadway. Megaload planning and execution is truly customized, requiring special provisions for traffic management, routing, and restric- tions on speed. Similar to superloads, megaloads are limited in their multimodal options due to their size, availability, and the constraints of rail and navigable waterways, sometimes leaving roadways as the only option for moving these critical loads.

20 Multi-State, Multimodal, Oversize/Overweight Transportation 2.6 Trends in OSOW Transportation OSOW freight is among the fastest growing segments of freight. Some states have reported a 30% to 50% growth in the number of permits issued for OSOW loads between 2000 and 2010.13 FHWA data shows a 26% increase in the total permits issued from 2005 to 2012 (Figure 2-7), despite the dip experienced during the Great Recession.14,15 Comparable OSOW statistics are not available for rail and marine transportation, though con- sultations with carriers almost uniformly suggested that the number of OSOW loads was increasing along with the overall size and weight of the loads. Sectors such as wind energy, road and bridge construction, heavy machinery, oil and gas production, specialty services, and project cargo16 have contributed to the growth in OSOW loads in recent years.17 13 Adams, T., E. Perry, A. Schwartz, B. Gollnik, M. Kang, J. Bittner, and S. Wagner. Aligning Oversize/Overweight Permit Fees with Agency Costs: Critical Issues, 2013. http://wisdotresearch.wi.gov/wp-content/uploads/WisDOT-CFIRE-project- 0092-10-21-final-report.pdf. Accessed October 27, 2014. 14 Freight Facts and Figures 2013. Federal Highway Administration, 2014. 15 Freight Facts and Figures 2008. Federal Highway Administration, 2008. http://www.ops.fhwa.dot.gov/freight/freight_analysis/ nat_freight_stats/docs/08factsfigures/pdfs/fff2008_book.pdf. Accessed October 27, 2014. 16 In this project, cargo is broadly defined as the transportation of large, heavy, and valuable pieces of inputs or equipment for use in construction projects. Examples include pieces of mining equipment, generators, boilers, pipe modules, etc. 17 Adams, T., E. Perry, A. Schwartz, B. Gollnik, M. Kang, J. Bittner, and S. Wagner. Aligning Oversize/ Overweight Permit Fees with Agency Costs: Critical Issues, 2013. Source: Freight Facts and Figures 2013 0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000 2005 2006 2007 2008 2009 2010 2011 2012 N um be r o f P er m its Total Permits Non-Divisible Trip Permits Other Permit Types Figure 2-7. Number of permits counted annually.

Oversize/Overweight Transportation 21 OSOW Movement of Wind Towers Global supply chains that deliver wind turbine components from the factory to the construction site are complex and multimodal—crossing state and juris- dictional boundaries en route from the port or the manufacturing plant to the installation site. This complexity is exacerbated by the variety and size of the components. For example, shipping an entire 150-megawatt turbine can require up to 689 truckloads, 140 rail cars, and eight vessels, including aggregate trans- portation needs for the foundation.18 Transportation of a wind turbine blade. Source: Perkins Motor Transport Wind tower components often require OSOW permits to move to the job site. The challenge of installing a wind tower is navigating OSOW permitting require- ments and on-the-ground execution of the move, especially as the carrier crosses state and jurisdictional boundaries. Any piece of the wind tower could be delayed by weather, a permitting mistake, or missing the hours a permitted load is allowed to move, thus delaying the project. These challenges will only increase as the industry designs and builds larger wind towers to increase efficiency. OSOW carriers encounter similar challenges when they transport other large loads, such as bridge girders, power plant boilers, and oil rigging equipment. 18 Neff, M., and Y. Bai. Developing a Multi-Modal Freight Movement Plan for the Sustainable Growth of Wind Energy Related Industries. Mid-America Transportation Center, 2012. http://matc.unl.edu/assets/documents/matcfinal/Bai_ DevelopingaMulti-modalFreightMovementPlanfortheSustainableGrowthofWindEnergyRelatedIndustries.pdf. Accessed May 25, 2016.