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

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22 C H A P T E R 3 3.1 Anatomy of Multi-State OSOW Moves Multi-state OSOW permitting and operations involve numerous interrelated steps that share a similar structure but differ in implementation throughout the United States. Whether a load is subject to an OSOW regulation and to what degree the regulations impact cost and fluidity depends on the route, weight, and dimensions of the load. To illustrate the differences between states, an overview of the planning and operational process of moving OSOW loads is provided. Consultations with industry veterans suggest that OSOW carriers rely heavily on individuals who have worked in OSOW shipping for many years on how to plan routes and navigate the permitting landscape. Similarly, companies create their own databases and rely on permit manu- als for a consolidated store of information. One respondent noted that it was difficult to stay informed because the rules changed often and the permit manuals, such as the one maintained by the Specialized Carriers and Rigging Association (SC & RA), did not always include the most recent changes. 3.1.1 Permitting Process Generally speaking, the permitting process goes through the same steps in every state. The permitting process can be divided into four phases: contracting, application, scheduling, and mobilization. Contracting The permitting process begins with contracting, which covers the shipper’s request for a quote, the bid, and the final contract signed with the carrier. During the contracting phase, the carrier analyzes the load and the origin and destination of the load to decide on a trailer configuration. The carrier also assesses different route options as well as the potential for a multimodal move. Route selection is contingent on a couple of factors, the primary one being the dimensions and weight of an OSOW load. As the dimensions and weight of an OSOW load increase, the ability for a carrier to choose a route decreases because of infrastructure restrictions such as bridges and over- head structures along a route. When multiple routes are available, the key drivers of route selection highlighted in consultations were primarily cost-focused, such as the maximum axle weights which impact the trailer configuration, cost of permits, and escorts needed balanced against the difference in total route mileage. Safety assessments based on experience were also suggested as a key driver. The choice between two roadway routes is more than a comparison of miles, but depends on the restrictions and the associated cost of compliance, potential delay, and safety. Once the configuration and best route are identified, the carrier estimates the permitting fees, civilian or police escorts, utilities, and the amount of time it will take to get through each state, Multi-State Oversize/ Overweight Transportation

Multi-State Oversize/Overweight Transportation 23 accounting for hours of travel restrictions. Estimates of all OSOW requirements are compiled and sent to the shipper for consideration. Once the bid is accepted and the contract signed, the carrier begins the application process. Application Once the contract is signed, the carrier finalizes the configuration and determines how to place the load to minimize height and weight. The final configuration is checked against the route identified in the contracting phase to ensure that the load can navigate infrastructure restric- tions along the route; if not, the configuration is redesigned or the route is remapped. Carriers may route around states that will not permit their configuration. The route is also checked for construction near the origin and destination, which would substantially affect the route. Once the route is planned, a route survey is done, if required. The route survey identifies infrastructure impediments that may require a change in the route. At this point, the carrier uses the route to estimate the schedule for the load, which is needed to apply for the permit. The schedule must account for the various sources of delay in OSOW operations, including police escorts, utility involvement, weather delays, hours of travel restrictions, and driver hours of service restrictions to inform the start and end dates of the OSOW movement. The carrier can now apply for all OSOW permits. Once carriers have applied and received state permits, carriers notify and apply for the city and county permits along the route. Filling out the permit application can be one of the shorter steps in the application process compared to the time spent compiling the information needed for the application and the actual process- ing time. While permits are being processed, the carrier moves to the scheduling phase of the permitting process. Scheduling If the carrier is confident that the route it has proposed will be approved by states and local jurisdictions along the route, it may need to contact utilities to arrange for their escort under low wires as needed. Carriers provide utilities with the route, and the date and estimated time they will need assistance. During this phase, carriers also contact cities, counties, railroads, or local organizations to schedule the movement, which may require the removal of wires and signs along the route. During the scheduling process, all permits are received and the carrier contacts any police and civilian escorts that will be hired for the route. The scheduling process relies on the ability of the carrier to accurately estimate the progress of the load, to make sure that wires and signs are removed before the load arrives, to negotiate railroad crossings effectively, and to ensure that escorts are ready to depart when the load arrives. Mobilization During the mobilization phase, the carrier plans its route to the load or hires an independent carrier to bring the equipment to the origin of the load. Trailers may be in one piece, requiring an OSOW permit, or taken apart and shipped in pieces. Once mobilization and permitting are completed, the carrier moves the equipment to the origin of the load, loads the trailer, and is ready to depart. Timeline As the size of an OSOW load increases, the number of steps and the amount of time spent on each step also increase. Figure 3-1 displays the permitting process along with the estimated time it takes for each step for routine OSOW loads, superloads, and megaloads.

24 Multi-State, Multimodal, Oversize/Overweight Transportation Routine OSOW load permits have the fewest steps and requirements for permitting relative to superloads and megaloads because they are below the thresholds for many regulations. For example, in most states routine OSOW loads do not need to complete a route survey, undergo bridge analysis, require district review; and, due to their size, they are more likely to stay on state- maintained highways, limiting the number of permits to local and county jurisdictions. A superload can take much longer to complete the permitting process relative to a routine OSOW load. Though the steps are roughly the same as a superload, a megaload’s extreme size requires more in-depth analysis in nearly every step. Additionally, a megaload will require more civilian and police escorts and will likely be routed off state-maintained highways, which requires more utility, city, and county coordination. 3.1.2 Operational Process OSOW operations include normal travel and compliance with permitting regulations along the route. The ease of travel for a routine load is directly related to the size, route, and regula- tions governing its movement. OSOW carriers must stay in contact with third-party support entities such as utilities, local jurisdictions, railroads, and police and civilian escorts to ensure that the load is in compliance with the relevant regulations and can safely traverse the route. As a load progresses, the carrier notifies the third-party of the support that it requires in the next jurisdiction. In the case of a delay, the carrier must also watch the effective dates of the permit Key Steps in Planning OSOW Moves Sign a contract. Request and accept a bid for an OSOW shipment. Carriers assess multimodal options and define the best route after considering state restrictions, permitting fees, travel time, and escort provisions to estimate a cost. Finalize configuration and load drawings. Receive finalized load drawings and assess trailer options to meet state weight maximums and allow the load to travel the outlined route. Apply for state permits. Identify and route around construction along the route, undertake route survey if required, develop load schedule accounting for all hours of travel restrictions, and apply for permits. Apply for city, county, and toll road permits. When necessary, notify and apply for permits in cities and counties along the route. Contact utilities, sign and signal organizations, and railroads. Contact and schedule utilities, cities, counties, and railroads to remove utilities, signs, signals, and railroad crossings. Set up civilian and police escorts. If civilian or police escorts are required to accompany the load, organize their availability for each jurisdiction. Mobilize trucks and trailers to the origin of the load. Move personnel and equip- ment to the job site. Also route and order permits if equipment is larger than the legal dimensions. Load truck. Place and secure load onto the trailer.

Multi-State Oversize/Overweight Transportation 25 to ensure it is traveling on a valid permit. If a permit expires, the carrier needs to refile or extend the permit in order to keep moving.1 3.1.3 Cost Structure OSOW trucking companies have standard costs, including the cost of the truck, trailers, drivers, repair and maintenance, tires, insurance, and fuel.2 In addition to the standard costs, Source: Perkins Motor Transport Figure 3-1. Approximate timeline of the permitting process. 1 States have various approaches to permitting extensions, ranging from allowing extensions for weather or mechanical issues during movement to not allowing extensions, which results in carriers having to refile their permits and wait until permission is granted. 2 The research team used the American Transportation Research Institute’s (ATRI) “An Analysis of the Operational Costs of Trucking: A 2014 Update” as the basis for the cost of operating a legal truck. ATRI uses a survey of trucking companies to estimate the cost per mile of operating a truck.

26 Multi-State, Multimodal, Oversize/Overweight Transportation OSOW trucking companies have costs that are a result of their size, including civilian and police escorts, permitting fees, utility involvement, and jurisdictional delay. Figure 3-2 displays the approximate per mile cost of legal trucking operations in 20133 and the cost of operating OSOW trucks as the loaded width increases. The research team focused on width in this example, but the overall stepped-cost function of operating an OSOW truck is comparable for length, height, and weight. Incremental Permit Cost States charge variable prices and employ various calculations to determine the cost of OSOW permits. Generally speaking, the majority of states charge incrementally once a load exceeds a specified threshold. The threshold may be based on weight or the dimensions of the load. For instance, Missouri charges $20 for every 10,000 lbs above the legal weight and adds an incremental bridge analysis fee of $425, $625, or $925 for loads over 160,000 lbs. The bridge analysis fee is calculated based on the number of miles traveled in the state. Oregon charges a per mile cost based on the number of axles and the weight. Ohio uses a per ton–mile cost ($0.04 cents) over a specified weight (120,000 lbs). The cost per mile is stepped for OSOW carriers because costs increase as a load crosses regulatory thresholds. The first step shown in Figure 3-2 is at 8 ft 6 in. wide, where a load needs a per mit to operate. The cost function steps again at 12 ft and 14 ft wide as civilian escorts are required. The last step in OSOW operating cost is at 16 ft wide, where states often require a police escort. The total cost per mile of operating an OSOW truck is at least 4.5 times more than the cost of operating a truck carrying a legal load. OSOW trucks cost more because of higher driver salaries 3 Torrey, W. F., and D. Murray. An Analysis of the Operational Costs of Trucking: A 2014 Update. American Transporta- tion Research Institute, 2014. http://atri-online.org/wp-content/uploads/2014/09/ATRI-Operational-Costs-of-Trucking- 2014-FINAL.pdf. Accessed May 10, 2015. Source: CPCS analysis of data provided by ATRI and Perkins Motor Transport $0.00 $1.00 $2.00 $3.00 $4.00 $5.00 $6.00 $7.00 $8.00 9' 10' 11' 12' 13' 14' 15' 16' 17' M ar gi na l C os t P er M ile Loaded Width Legal OSOW Figure 3-2. Cost of OSOW operations based on width.

Multi-State Oversize/Overweight Transportation 27 and benefits, increased fuel cost as weight increases, higher cost of specialized OSOW equip- ment, increased maintenance costs, and other regulations. 3.2 Examples of Multi-State OSOW Moves In order to demonstrate the impact of weight and the loaded dimensions of OSOW trucks on their operations, the research team identified a routine load, a routine load/superload, and a superload. As each load increased in size and/or weight, it triggered different OSOW regula- tions throughout the country, which significantly affected the flow of the load. The three multi- state moves are outlined in this section as examples of the challenges encountered when OSOW freight travels across multiple jurisdictions. 3.2.1 Move 1 Move 1 was a routine OSOW load traveling from Azusa, California, to Savannah, Georgia, carrying a large air purifier. Figure 3-3 displays the weight and dimensions of the cargo and the overall weight and dimensions when loaded. The fully loaded dimensions for Move 1 were within the legal length, weight, and height but outside the legal width. Therefore, the load needed an OSOW permit. Move 1 used a five-axle configuration (three truck axles and a tandem trailer). Move 1 was within the legal height, which eliminates the potential for overhead structures to interfere and allows the load to travel mainly on the interstate. Figure 3-4 displays the route from California to Georgia. The load is routed primarily on interstates, moving through California, Arizona, New Mexico, Texas, Oklahoma, Arkansas, Tennessee, Mississippi, Alabama and finally into Georgia. The dimensions of the move allowed for an unimpeded routing from origin to destination because the load did not need to route around overhead structures or weak bridges. Figure 3-4 also displays how the escort requirements changed as Move 1 traveled from California to Georgia. Of the 10 states covered, six states (Arizona, New Mexico, Texas, Arkansas, Tennessee, and Mississippi) did not require a civilian escort, three (California, Oklahoma, and Georgia) required one escort, and one (Alabama) required two escorts. Figure 3-5 displays the operational timeline for Move 1. The load took nine days to transit the entire route. Other than the Federal Motor Carrier Safety Administration’s hours of service regulations, the load was able to move unimpeded on days 1 through 5. On day 6, the load was limited to traveling by daylight until noon in Alabama because of Saturday hours of travel restrictions. Alabama did not allow any OSOW travel on Sundays, resulting in no travel on day seven. Following the hours of travel restriction in Alabama, the load traveled two days and arrived in Savannah on day 9. Figure 3-6 displays the miles permitted, permit cost, and civilian escorts required in each state. The permitting fees ranged from $10 to $60, and only Alabama required more than one escort. Characteriscs Cargo Loaded Length 45  65  Width 12  1 in. 12  1 in. Height 8  13  6 in. Weight 45,000 lbs 80,000 lbs Figure 3-3. Weight and dimensions of Move 1.

28 Multi-State, Multimodal, Oversize/Overweight Transportation Figure 3-4. Route of Move 1 from Azusa, California, to Savannah, Georgia. Figure 3-5. Operational timeline of Move 1. Figure 3-6. Permitting and operational requirements of Move 1. State Permit Miles State Permit Cost Civilian Escorts California 234 $20 1 Arizona 368 $15 0 New Mexico 372 $25 0 Texas 173 $60 0 Oklahoma 354 $44 1 Arkansas 286 $22 0 Tennessee 20 $15 0 Mississippi 118 $10 0 Alabama 218 $10 2 Georgia 303 $38 1 Total 2,446 $259 5

Multi-State Oversize/Overweight Transportation 29 The number of escorts is a function of both size and type of roadway. The move traveled largely on interstates, which require fewer escorts than two-lane roadways. Overall, the move faced very few impediments from California to Georgia. 3.2.2 Move 2 Move 2 highlights an international move from Houston, Texas, to Fort McMurray, Alberta. Figure 3-7 displays the weight and dimensions of the cargo and the fully loaded trailer. The loaded weight and length increase by a factor of two and three respectively, compared to the unloaded cargo. Move 2 used a 13-axle configuration (nine axles on the trailer and four on the truck). The trailer used rear steering that steers independent of the truck to maneuver around corners on two-lane roadways (shown in Figure 3-8). The 13-axle configuration was used to ensure that the load remained under the 20,000 lbs maximum axle weight allowed in Oklahoma. Figure 3-9 displays the route that the move took from Houston to the Alberta oil fields in Fort McMurray. Additionally, the figure also displays the shortest route from Houston to Fort McMurray to show route detours around infrastructure constraints. Figure 3-9 also displays a selection of the requirements that the move encounters while travel- ing through each state. Some of the differences in regulations were because of the route taken. If the move was able to stay on state highways, U.S. highways, and interstates the carrier would face fewer city permits, country permits, and utility notifications and assistance. Some of the escort requirements were required by cities. The police escort was required in Kansas while routing through the city of Liberal. Figure 3-7. Weight and dimensions of Move 2. Characteriscs Cargo Loaded Length 47  6 in. 142  8 in. Width 15  3 in. 15  3 in. Height 16  17  4 in. Weight 105,000 lbs 218,000 lbs Figure 3-8. Cornering with a rear steer in Move 2. Source: Perkins Motor Transport

30 Multi-State, Multimodal, Oversize/Overweight Transportation Figure 3-9. Route of Move 2 from Houston, Texas, to Fort McMurray, Alberta. 1 Mile of Travel in Nebraska to Avoid Overpass in Wyoming Routed West to Avoid Low and Weak Bridges in Oklahoma Harris County • 2 Police Escorts Required City of Liberal • 1 Police Escort Required City of Galena • Park Permit Required

Multi-State Oversize/Overweight Transportation 31 Move 2 traveled through Texas, Oklahoma, Kansas, Colorado, Wyoming, Nebraska, and Montana before entering Alberta. Low and weak bridges in Oklahoma, specifically around Oklahoma City and Tulsa, affected the routing, pushing the load west through the Oklahoma panhandle. Wires had to be lifted in Liberal, Kansas, which required coordination and man- agement of the load’s timing through the town. The load then traveled through Kansas into Colorado. After crossing the Colorado–Wyoming border, the load immediately went into Nebraska for one mile and returned to Wyoming to avoid a low overpass. Finally, the load traveled through Wyoming and Montana, crossed the U.S.–Canadian border into Alberta, and eventually arrived at Fort McMurray. The total mileage for the trip from Houston to the U.S.–Canadian border was almost 2,370 miles compared to an unrestricted routing of approximately 1,920 miles. In addition to the added mileage, the OSOW route included city and county roads, which required addi- tional permitting, hours of travel restrictions, and utility coordination. Figure 3-10 shows the operational timeline for the move. The load took 13 days to travel from Houston to the U.S.–Canadian border. Travel was stopped on day 7 and 8 because of a mechanical breakdown. The load stopped in Gillette, Wyoming, because Montana did not allow travel on weekends. Even without the breakdown, the load would have had 2 days without travel because of Montana’s weekend restriction on large loads. Figure 3-11 displays a selection of the permitting and operations requirements for Move 2, including the number of miles traveled in each state, state permit costs, the number of city and county permits required, civilian and police escorts required, utility notification and assistance, and whether a route survey was required. The move was classified as a superload in Kansas, Colorado, and Montana, which increased the restrictions it encountered during permitting and operations. Figure 3-10. Operational timeline of Move 2. Figure 3-11. Permitting and operational requirements of Move 2. State Permit Miles State Permit Cost City Permits County Permits Utilities and Jurisdictions Notied Utility Assistance Civilian Escorts Police Escorts Route Survey Texas 791 $471 1 0 5 0 2 2 Yes Oklahoma 75 $1,362 0 0 0 0 2 0 No Kansas 185 $50 0 0 13 5 2 1 No Colorado 304 $410 0 3 5 1 2 0 Yes Wyoming 436 $1,484 0 1 16 1 2 0 No Nebraska 1 $25 0 0 0 0 0 2 No Montana 575 $574 0 1 10 5 4 0 No Total 2,367 $4,376 1 5 49 12 14 5 2

32 Multi-State, Multimodal, Oversize/Overweight Transportation The cost of permitting Move 2 varied significantly from state to state. The variation in the cost of permitting is related to differences in the state permitting structure. Oklahoma uses a base permitting fee of $80 for an OSOW truck and an additional $10 per 1,000 lbs if a load is more than the legal limit, whereas Kansas charges a flat $50 permitting fee for all superloads. OSOW carriers also experience variation in the permitting of city and county roadways. Not all cities or counties require a permit to use their roadways, but travel on city and county roadways may trigger other OSOW requirements. Liberal, Kansas, did not require a permit but required a police escort, and the carrier needed assistance from two utilities to move through the city. City, county, and utility coordination is substantially affected by the number of towns on the permitted route. In the case of Kansas, the carrier needed assistance from five different utilities and notified many more to ensure there were no low-hanging utility lines along the route. In the case of Texas, each district along the route had to be notified. Most states along the route required the move to include two civilian escorts while travel- ing. In addition to civilian escorts, the carrier was required to hire police escorts in three states (Texas, Kansas, and Nebraska). Lastly, only two states required a route survey. Move 2 expe- rienced the greatest variation in permitting costs and the number of utilities and jurisdictions along the route. 3.2.3 Move 3 Move 3 was a heavy compressor skid for a chemical plant, which originated in Pittsburgh, Pennsylvania, and was destined for Rosharon, Texas. Figure 3-12 displays the weight and dimen- sions of the cargo and the fully loaded trailer. The move had a legal loaded height that allowed the load to move unimpeded by overhead structures. Figure 3-13 shows the move being loaded onto a 13-axle configuration (nine axles on the trailer and four on the truck). The trailer had a rear steer to increase maneuverability around Figure 3-12. Weight and dimensions of Move 3. Characteriscs Cargo Loaded Length 47  6 in. 142  8 in. Width 15  3 in. 15  3 in. Height 16  17  4 in. Weight 105,000 lbs 218,000 lbs Figure 3-13. 13-axle configuration of Move 3. Source: Perkins Motor Transport

Multi-State Oversize/Overweight Transportation 33 Figure 3-14. Route of Move 3 from Pittsburgh, Pennsylvania, to Rosharon, Texas. corners on two-lane roadways. The 13-axle configuration distributed the weight of the load so that no axle was above 20,000 lbs. Figure 3-14 displays the route from Pittsburgh to Rosharon, moving through nine states. The load was classified as a superload in all states except Texas because of its weight. The load’s dimen- sions, especially its legal height, allowed for a route on state-maintained roadways, reducing the number of city and county permits and eliminating utility involvement. The load traveled from Pennsylvania through West Virginia, Ohio, Kentucky, Indiana, Illinois, Missouri, and Arkansas to Texas. Move 3 traveled more than 1,570 miles on the OSOW route compared to 1,370 miles on an unrestricted route. The load detoured around Tennessee as the permit request was denied because of axle weight restrictions, and traveled through Indiana, Illinois, and Missouri to bypass Tennessee. The load also detoured around construction in Arkansas, which caused a deviation from the unrestricted route. In addition to showing the detours from the unrestricted route, Figure 3-14 displays state- to-state variation in civilian and police escorts, city and turnpike permits in Pennsylvania, as well as required bridge monitors in Ohio and West Virginia. Figure 3-15 displays the operational timeline for the move. The load took a total of 14 days to travel from Pennsylvania to Texas. The load left on a Friday and was restricted from traveling

34 Multi-State, Multimodal, Oversize/Overweight Transportation on Saturday and Sunday in West Virginia. Travel did not continue until Tuesday because the load could not get an Ohio police escort on Monday. Travel stopped again on Thursday because the load needed a police escort in Indiana. The move traveled to Belleville, Illinois, on Friday, where it sat until Monday morning. The load did not travel on Saturday because of the weather, was restricted from moving on Sunday because of its width and weight, and could not move on Monday because of the weather. From Tuesday to Thursday, the move traveled from Belleville, Illinois, to its destination in Rosharon, Texas. Figure 3-16 displays a selection of the permitting and operations requirements for the move including the number of miles traveled in each state, state permit costs, the number of city permits required, civilian and police escorts required, and whether a route survey was required. In addi- tion to the requirements shown in Figure 3-16, a truck inspection and a construction notification were required in Pennsylvania, as well as a bridge monitor in Ohio and Illinois. As with Move 2, the cost of permits for Move 3 varied substantially between states due to incre- mental charges for the weight of the vehicle. City permitting was concentrated in Pennsylvania, where two cities and one toll road required their own permits. Overall, the major impediments to Move 3 progressing from origin to destination were the weather, police escort coordination, and restrictions on weekend travel. Figure 3-15. Operational timeline of Move 3. Figure 3-16. Permitting and operational requirements of Move 3. State Permit Miles State Permit Cost City Permits Civilian Escorts Police Escorts Route Survey Pennsylvania 70 $235 3 2 2 Yes West Virginia 14 $216 0 2 0 No Ohio 135 $270 0 2 2 No Kentucky 33 $60 0 3 0 No Indiana 141 $846 0 2 2 Yes Illinois 143 $563 0 2 0 No Missouri 220 $1,330 0 2 0 No Arkansas 470 $1,660 0 2 0 No Texas 347 $470 0 1 0 No Total 1,573 $5,650 3 18 6 2