LCV operation could be administered under the stewardship of the BTS.
NATIONAL HIGHWAY SYSTEM IMPLEMENTATION
Question. The Department of Transportation (DOT) has unveiled its proposal for
the National Highway System (NHS) which will incorporate approximately 160,000
miles of interstate highways, State highways, and county roads. What role, if any,
should truck lengths play in implementing this new NHS/ Should the current freeze
on truck lengths oe extended to include the NHS?
Answer. The current freeze on LCV expansion is not a freeze on single trailer
lengths. However, as I discuss in detail in my written testimony, the LCV freeze
needs to be complemented by a ceiling on maximum single trailer length in all 50
states. Our current infrastructure design has been badly outpaced by unforeseen in-
creases in truck length. These increases have resulted in an "industry standard" of
53 feet in length in the U.S. The last state refusing to allow this increase from 48
to 53 feet in length, Rhode Island, conceded their use in July 1994.
Our estimates, based on the responses of knowledgeable transportation experts,
is that the majority of our existing freeway ramps and interchanges cannot accom-
modate combinations with 53 foot long semi-trailers. In many instances, elevated
cloverleaf ramps are not physically capable of negotiation by a 53-foot long semi-
trailer rig. Similarly, the excessive ofllracking of these and even longer (57, 59, and
60-foot) trailers create dangerous operating conditions because turns and sharp
curves require these extra-long rigs to move into oncoming and adjacent lanes to
execute the maneuver.
Furthermore, longer trucks will inevitably generate a demand for higher cargo
weights which will be gained either by lifting the current federal ceilings on gross
and axle weights, or by even more exploitative use of special permits for overweight
trucks. Longer and heavier trucks will overwhelm the operational capabilities of the
NHS, substantially increase the chances for serious truck crashes with passenger
vehicles, and further decrease our infrastructure funding abilities. State and even
local authorities would be forced to make extraordinarily expensive, fundamental
design changes to facilities simply to accommodate very long trucks instead of im-
proving highway conditions for other mobility and safely needs. Similarly, longer
trucks will inevitably produce heavier trucks, and our funding shortfalls to meet
even current bridge ana pavement needs will be exaggerated because of the increase
in truck-produced highway damage, especially on older non-Interstate portions of
the NHS.
The only rational approach to controlling highway finance on the NHS, as well
as crash involvement, is to control truck lengths and weights. However, it should
be pointed out here that Congress mandated larger trucks on a network of highways
far larger than the incipient NHS when itpassed the truck provisions of the Surface
Transportation Assistance Act of 1982. This Designated National Network (DNN)
94
consists of the Interstate system plus two-thirds of the arterials on the former U.S.
Primary system — about 240,000 miles or more. Many of these roads are priority
routes for heavy trucking, but will not be included on the NHS. Even with a cap
on truck lengths and weights on the NHS, these routes will be available for longer,
heavier rigs. This means that the cap on truck size and weight should be on the
1982 DNN, not just on the NHS.
NTS DEVELOPMENT BY DOT
Question. DOT is planning to submit a proposal in January 1995 for the develop-
ment of a National Transportation System (NTS) to promote the implementation of
an integrated, eflicient intermodal transportation network. Are the issues of truck
length and safety integral elements to consider in the development of NTS?
Answer. Absolutely. But, to date, the only elements addressed by the U.S. DOT
have been funding issues and a general commitment to the NTS as a fulfillment
of the ISTEA philosophy of intermodalism. No attention whatever has been paid to
truck size and safety issues. Advocates is currently preparing a detailed response
to the recent Federal Register inquiry by the Secretary's office on the issues that
are generated by the concept of the NTS. Our main emphases will be the uniformity
of design of highways for promoting better safety, and truck size and weight controls
for safety and infrastructure preservation.
NAFTA AND LCV FREEZE
Question. In light of the passage of the North American Free Trade Agreement
(NAFTA) and efiorts to establish harmonious laws regarding truck lengths and
weights, what factors should be considered to enhance economic potential without
compromising safety? What are the implications of the LCV freeze for NAFTA?
Answer. The true costs of enhancing economic potential by increasing truck sizes
and weights are measured by the considerable inflation of bridge and pavement
damage generated by even slight increases in gross or axle weights, the increases
in crash involvements and crasn severity engendered by heavier, more unstable, big-
ger trucks, and the expanded discrepancy between infrastructure deterioration and
user cost responsibilities for that deterioration. When these costs are quantified,
productivity benefits for the trucking industry will be gained, as so often has been
the case in the past, to the detriment of public safety, infrastructure preservation,
and the highway trust fund.
As for the LCV freeze, it is clear that the economies of scale that would be gen-
erated for the trucking-industry by allowing trilateral movement on a virtually con-
tinent-wide priority commercial routing network for LCVs will be a major force in
the negotiation arguments of representatives from all three countries. However,
with the LCV freeze, but without a cap on single trailer lengths nor a reinvigoration
of federal authority to control overweight permitting abuses, much of the economic
efficiencies that the trucking industries of all three nations seek can be achieved
through circumvention of the LCV freeze through the use of longer, heavier semi-
trailers.
The key issue for trucking interests in NAFTA negotiations is not the LCV freeze,
but the potential for the U.S. Congress to increase current federal weight limits on
the Interstate. If significant increases were secured, state limits on non-Interstate
routes would correspondingly be pressured for commensurate increases. Elevated
weight limits on both Interstate and non-Interstate priority trucking routes would
siphon off the intensity of interest in the trucking industry for thawing the LCV
freeze. Although it is true that the movement of certain commodities by LCVs is
still superior for cost and profit reasons over their movement by semi-trailer rigs,
much of what can be gained by a state-by-state discretional^ approach to the use
of LCVs, such as that suggested by the GAO in its 1994 LCV report, would be ac-
complished by higher weights in bigger "eighteen wheelers."
ATTACHMENT A
TABLE 1— LCV Fatalities by Year
(Source: TlFAl
LCV indicator
1980-85
1986
1987
1988
Triple
Doubles greater than 80 ft,, LCV state
8
18
4
7
7
2
95
TABLE 1— LCV Fatalities by Year— Continued
[Source: TIFA]
LCV indicator
1980-«5
1986
1987
1988
Doubles with long trailers, LCV state .
13
9
5
Total LCV fatalities (conservative)
39
71
14
10
8
20
2
12
1
8
N/A
Total for 1980 to 1987 (8 years)
Total triples 1980 to 1988 (9 years)
Ottier likely LCVs:
Truck with 2 full trailers, LCV state
Doubles with medium trailers, LCV state
18
2
9
Likely reported total LCV fatalities 1980 to 1987 (8 years)
100
TABLE 2 — Fatality Rates of Various Configurations (per 100 million miles of travel)
[Sources: TIFA and TIUSj
1986
1987
Total
Single-Trailer Combinations
6.0
97
143
5.8
8.7
82
59
Multi-Trailer Combinations
All LCVs
9.1
11 2
TIFA HIGHWAY FATALITIES RATES (FlfWA, TIUS VMT)
Per 100 Million Mllet
TIFA/FHWA
TIFA/TIUS
Tractor Semitrailers [ J Multi-trailers
TIFA: Trucks InvolvBd In Fatal Accidents
TIUS: Truck Inventory ft Use Survey
FHWA: Federal Highway Administration
' 'iPia I.: u„f; r Mingo, ej al^, "Accidpiit Knies
< • Mnlii Unii ' iinblnnlloii Vehicles Derived frnni
I.nigp .Sc.-ile I):ii ibnses" Jnmiarv iri, I9')|.
ATTACHMENT B
[Transport Topics, Oct. 3, 1994]
A Decade of Useful Life Left in Old Wilson Bridge
Short term fixes can extend the life of the obsolete Woodrow Wilson Bridge by
10 years, about the window needed to design a replacement for the Interstate 95
span, according to an engineering study.
96
The bridge is an integral link in the east coast's main street, carrying 160,000
vehicles a day — far more than it was designed to handle 30 years ago — over the Po-
tomac River south of Washington, DC.
It is also the object of controversy centered on whether to rehabilitate the existing
structure or replace it with a larger span or a pair of tunnels.
A key question is whether to restrict tuck traffic on the Wilson Bridge.
The New York engineering firm Hardesty and Hanover led a study of the bridge's
condition, finding it generally in "fair" shape but suffering excessive vibrations and
deflections, particularly from heavy trucks.
Engineers said the existing six-lane bridge would last much longer if it were re-
built and opened only to automobUe traffic. At $52 million, this would be the cheap-
est solution.
K truck traffic cannot be rerouted, they said, the best alternative would be to re-
place the entire structure — at roughly four times the cost of renovation. Increasing
capacity to 12 lanes could double costs again.
An average 17,000 trucks cross the Wilson Bridge daily. According to the study,
today's trucks weigh a good deal more than those when the bridge was designed.
Steel deck beams undergo more flexing, more often than was planned for, engineers
said.
Bridge engineers now have a better understanding of the effects of repeated load-
ings from big trucks and would incorporate updated standards in a new design.
In the meantime, $10 million of snort-term repairs to deck-supporting piers and
steel members, plus new pavement, can extend tne bridge's life oy a decade under
current traffic demands.
But that still leaves an "urgent" decision on what to do for the long run. It will
take 10 years to study, design, and construct a permanent replacement.
Question Asked by Senator Hollings and Answer Thereto by Ms. Konz
Question. Please provide the committee information regarding any study that ex-
pressly ties the safety of a trailer to its length.
Answer. As cited in the written testimony submitted, longer trucks are more dan-
gerous in that they are more likely to encroach onto another lane of traffic in turn-
ing, or "off-tracking." In studies completed by the University of Michigan Transpor-
tation Research Institute in 1986, (Sayers) and by the Ontario Ministry of Transpor-
tation In the same year (Mercer), "swing-out lane encroachment" describes the risks
when the rear wheels of a trailer do not follow the front wheels of a tractor in mak-
ing a turn. The driver then must allow the trailer to either leave the roadway on
the inside of a curve, rolling over whatever is in its path, or must steer the trailer
so that it encroaches into oncoming lanes of traffic. In the former scenario, bicyclists
or pedestrians may be in the path of the trailer. In the latter scenario, the trailer
may be in the path of an oncoming vehicle, and the driver of that vehicle may not
anticipate the encroachment, and the driver of the trailer may not be able to stop
or change its path. Further, a survey completed by the AASHTO indicate that only
about half of the existing Interstate ramps could accommodate the off-tracking of
a truck with a 48-foot trailer.
In the past year, CRASH has run its own computer simulations of the safety im-
plications of longer trucks. The results of these computer simulations are being sub-
mitted with this response and are based upon the mathematics and geo-metrics set
forth in the studies by Michael Savers and Billing and Mercer which I referenced
in my posted response. And in June, CRASH researchers confirmed these computer
results with road tests in Austin, Texas.
The problems trucks have with jackknifing, lane changes, and merging are all
well documented. While CRASH knows of no studies documenting that these prob-
lems increase with length, I believe that this is because they would simply be stat-
ing the obvious. A longer jackknifed trailer will block more lanes and be a larger
target for oncoming trafi~ic. Even when driving normally on a crowded highway,
longer trucks are more likely to cause accidents simply by changing lanes or merg-
ing into traffic. The amount of traffic flow displaced by a longer truck all too often
results in accidents as other motorists are forced to slam on the brakes.
Questions Asked by Senator Exon and Answers Thereto by Ms. Konz
car driver's concerns
Question. What type of concerns, if any, do automobile drivers express regarding
highways with single trailers and longer-combination vehicles (LCVs)?
sharing the
97
Answer. When I was first approached about becoming involved in CRASH, I
began to ask my family, friends, and colleagues about the mission of the organiza-
tion and their opinion about the risks posed by tractor-trailers and LCV's. The re-
sponse was overwhelming. EVERYONE had more than their share of stories about
trucks on the highway, and the many times their safety was threatened by trucks.
Even my father (who reportedly has been overheard as stating that I would be rich
if I got paid for all the volunteer projects I worked on, and doesn't always under-
stand my commitment to various projects) told me that I should do everything I
could to improve truck safety and halt the use of longer-combination vehicles. That
fact speaks very clearly of the attitudes toward longer trucks.
I began to realize that people not only were unaware of the limitations on the rate
at which truck drivers can adjust position or speed of the truck, they were also un-
aware of the risks imposed, and the other issues that affected highway safety. I
began to realize that people had minimized their fear to themselves, as I had, be-
cause of that lack of knowledge, and because without that knowledge, the fear
seemed to be simply a childish and immature fear of big things. That sense of fear,
I have learned, may be childlike, but it is well-founded. Passenger vehicles are very
much at risk of being involved in a fatal crash with trucks.
As I have become more informed about the issues, I have shared that information
with others. They respond with relief, and fervor. Relief that their simplistic fear,
often minimized by the trucking industry, and fervor that action be taken to prevent
the spread of highway trains that impose such a risk to travelers.
Two nationwide 1993 surveys by the polling firm Frederick/Schneiders have
shown overwhelming public opinion against raising weight increases. Twenty-three
percent of the public wanted to reduce truck lengths and 91 percent either wanted
to reduce truck length or "keep length as it is." Only six percent of the public favored
increasing truck length. The same surveys indicate that 81 percent of people believe
that longer trucks make driving conditions more difficult and 80 percent believe
that they are less safe than the current fleet. The American public also rejects the
claims that longer trucks would save them money, with 70 percent believing that
any cost savings would NOT be passed on to them. And 75 percent of Americans
support the Congress enacting a federal freeze on length limits.
PERSONAL EXPERIENCE
Question. As a citizen and volunteer, describe for the Committee your personal
experiences with tractor trailers and general highway safety, and why you feel so
strongly that truck lengths should be frozen at current levels.
Answer. Eleven years ago, when I was still in the hospital, but just released from
the Intensive Care Unit, following the single-vehicle van crash on icy roads in which
I was a passenger. My phone began to ring immediately, as people had not been
able to speak with me (I was hospitalized 300 miles away from my family, and 50
miles from the city where I had been living and going to school) since the injury
had occurred. I only remember a few moments of those first days, but I remember
one call from my older brother, who had been a truck driver for a few years, chang-
ing jobs a year before my injury. He was fighting tears during that call, telling me
how sorry he was that this had happened to me, and not to him. As a truck driver,
he had been involved in a few accidents, one involving a jack-knife of his truck on
ice, which is more likely to occur with longer trucks. He had walked away from that
accident, and the others. He, like other truck drivers I have met (including one who
was involved in a fatal crash with a passenger vehicle), know that regardless of the
cause of the crash, they most likely will survive, because of the nature of the vehicle
they drive. It is a heavy burden they carry throughout their lives.
I have spent some talking with my brother about truck safety, and the lack of
knowledge that other drivers have regarding the truck-driver's ability to change
speeds, move the vehicle quickly, etc. I witnessed these limitations around the same
time: I was driving back from Mayo Clinic-Rochester, for my own medical treatment
for the personal injury I had incurred. I had spent alot of time on that trip evaluat-
ing truck traffic and thinking about the request to take on a leadership role in
CRASH. A woman driving a car almost identical to mine in the left lane was cut
off by the truck just ahead of me, that had changed lanes and not left enough space.
The driver of that car had to drive into the median of the Interstate to avoid being
hit, and fortunately was able to keep the car from rolling over. I went home and
called the CRASH ofiice to communicate my decision to take on the task they had
asked of me.
98
DATA COLLECTION
Question. How do you quantify and use the information you gather as a volunteer
for CRASH.
Answer. The interview information I have collected in my role with CRASH has
been described in the response to the first question from the Senator.
The American Automooile Association (AAA) has also done several surveys over
the past decade. Nationally, 89 percent of AAA members were "strongly opposed"
to increasing truck wei^ts in a 988 survey. The next year 92 percent of the mem-
bers of AA/VPotomac (DC, Northern Virginia, and suburban Maryland) answered
"no" to the simple question "do you favor allowing truck lengths to be increased?"
NATIONAL HIGHWAY SYSTEM IMPLEMENTATION
Question. The Department of Transportation (DOT) has unveiled its proposal for
the National Highway System (NHS) which will incorporate approximately 160,000
miles of interstate highways, state highways, and county roads. What role, if any
should truck lengths play In implementing this new NHS; Should the current freeze
on truck lengths be extended to include the NHS?
Answer. The available information clearly indicates that longer trucks are more
dangerous and are more likely to be involved in tralTic crashes. Also, the vast major-
ity of citizens that I have spoken with regarding this issue would prefer that limits
be placed on longer-combination vehicles and the length of truck-trailers. And, since
length is related to weight of trucks, and heavier trucks are also more likely to be
Involved in several different kinds of accidents, placing a freeze on she lenqth of
trucks using the NHS will potentially save lives and reduce accidents on that sys-
tem. And the current freeze on longer-combination vehicles should also be extended
to the NHS, for the same reasons, and for the same purpose.
I would also refer the Senator to a book written by a fellow Nebraskan, "The Si-
lent Depression," by Wallace Peterson, Ph.D. (1994). Dr. Peterson addresses the eco-
nomic benefits of such an intermodal transportation system in the chapter on "In-
vesting In America" and presents a clear explanation of the benefits and issues in-
volved in developing such a system.
NTS DEVELOPMENT BY DOT
Question. DOT is planning to submit a proposal in January, 1995 for the develop-
ment of a National Transportation System (NTS) to promote the implementation of
an integrated, efficient intermodal transportation network. Are the issues of truck
length and safety integral elements to consider in the development of NTS?
Answer. Certainly the issue of truck length is integral to the success of an inter-
modal transportation system, as longer trucks may not be able to be accommodated
by the railroad and the overall system being developed. Also, as stated previously
and as described in the written testimony submitted to the Surface Transportation
Subcommittee, truck length is a key issue to improving the safety of our transpor-
tation system.
NAFTA AND LCV FREEZE
Question. In light of the passage of the North American Free Trade Agreement
(NAFTA) and efforts to establish harmonious laws regarding truck lengths and
weights, what factors should be considered to enhance economic potential without
compromising safety? What are the implications of the LCV freeze for NAFTA?
Answer. The Senate Resolution supported by Senator Exon specifically stated
that truck safety standards should not be compromised in the efTort to increase
trade between the U.S., Canada, and Mexico. As such, current truck length freezes
on longer-combination vehicles should be maintained and applied to vehicles from
all three countries traveling within the United States, especially since Mexico allows
triple trailers, and Canada allows them in certain areas. And since both countries
also allow significantly heavier trucks, they would also simultaneously need to use
longer trucks to accommodate the increased weight. With weight limits in Mexico
at 170,000 pounds, and Canadian limits at 137,000 pounds, these trucks could be
as long as 120 feet! And I cannot imagine that anyone could agree that any increase
in trade and subsequent improvement in economic conditions due to these kinds of
compromises in safety Is worth even one life. If necessary a comparison could be
made of the projected economic benefits and the costs of losing even one life because
of longer trucks, including the loss of income, the emergency services and/or funeral
expenses from such a crash, or the use of entitlement funds for the crash survivor
or for 4ffihe surviving family members of anyone killed in such a crash. I suspect
the numbers will speaK for themselves.
99
Questions Asked by Senator Rollings and Answers Thereto by Mr. Donohue
LONGER combination VEHICLES
Question. Will an increase in trailer lengths put pressure on motor carriers to re-
place their fleets earlier than they might do otherwise?
Answer. We do not expect any sweeping increases in the length of single trailers.
If there were major increases, we do not oelieve the changes will cause motor car-
riers to replace their fleets earlier.
The reason is that every one of the 48 contiguous states currently allows the oper-
ation of 53 foot single trailers. However, most states that increased the length liniit
required the trailer axles to be moved forward so that the 53 foot trailer turns in
the same radius as a 48 foot trailer. A longer trailer with this same axle require-
ment will be difficult to load with more weight because adding weight to the back
would lighten the front of the trailer and hurt the safety performance of the vehicle.
However, buying a longer trailer at current weight restrictions actually restricts
the types of cargo that can be carried by the motor carrier. For example, a 57 foot
trailer would have roughly 7.5 percent more cargo space than a 53 foot trailer. That
means that the type of cargo that completely fills a 57 foot trailer must be at least
7.5 percent less dense than the cargo that fills a 53 foot trailer. This is why longer
trailers have very limited applications and are used for such cargo as styrofoam in-
sulation, empty cans, and snack foods.
The other important factor for a motor carrier is that rates paid to transport di-
rectly from shipper to receiver are based on mileage and not volume or weight. This
means that the motor carrier gets paid the same amount for moving a 53 foot trailer