multi-trailer rigs, such as persuading a state to allow turnpike doubles or triples
where only Rocky Mountain doubles operated before (a 45- or 48-foot long semi-trail-
er pulling a 28-foot long "pup"), the industry has instead exploited the fact that the
1982 STAA set no ceiling on what the states could allow on the DNN. This legisla-
tive deficiency will continue to plague us until Congress acts in accordance with the
concept advanced in H.R. 4644 to set a maximum trailer length nationwide on key
highways.

We cannot continue to restrict the use of LCVs without also putting a cap on trail-
er length. The trucking industry is adept at using increases m length as the basis
for arguments that weight limits on the Interstate system must be increased. Once
those limits are increased, as they were in 1974, further increases in trailer length
are used as the pretext for appeals to Congress for federal statutes that increase
the limits on axle and/or gross weights.

And even more powerful arguments are now being brought to bear, Mr. Chair-
man. With the advent of the North American Free Trade Agreement (NAFTA), the
industry has a new, international lever to use in pressing for higher federal weight
limits. Both Mexico and Canada have far higher axle and gross weight limits that
we do, and Mexico has recently amended its weight laws to allow higher maximum
gross weights for a variety of rigs in that country, including the standard "eighteen
wheeler." Furthermore, both Canada and Mexico allow more axles in a group on the
Interstate system than we do, including triple- or triaxles, as well as higher axle
weight limits for single, tandem, as well as triple axles.

Right now, the Land Transportation Standards Subcommittee is conducting meet-
ings among the three countries' representatives for the purpose of "harmonizing" tri-
lateral trucking regulations. The biggest part of "harmonization," Mr. Chairman, is
getting agreement on what will be the biggest, heaviest rigs that will be allowed
legally to traverse all three countries. And just as some of our own states resisted
the demands of the trucking industry for longer, wider, heavier rigs on more roads,
often facilitated by cheap overweight permits, it is now the U.S. which is in the
unenviable jjosition of holding the line on our domestic weight and size limits.

Our negotiators got clear instructions from the Senate a year ago that under no
circumstances were U.S. weight limits and safety regulations up for grabs in
NAFTA truck harmonization discussions. We deeply appreciate your pivotally irn-
portant role, Mr. Chairman, in foreseeing the threat of^ NAFTA for truck safety in
the U.S. However, I'm sad to report that, despite this absolutely unambiguous in-
struction, the agency which has direct oversight responsibilities for enforcing Con-
gressional weight limits on Interstate highways and bridges is trying to find ways
to bring back a message to Congress that it is in the national interest to lift the



35

ceiling on axle or gross weights. The alternatives being discussed include eliminat-
ing the 80,000 pound gross weight cap and letting the statutory bridge formula con-
trol maximum wei^ts in accordance with current single and tandem axle limits,
or allowing the use of LCVs beyond the ISTEA freeze limits, such as through ex-
panded use in the western U.S. or by creating special "NAFTA corridors." One of
these scenarios — currently illegal under the ISTEA LCV freeze — is called
"Canamex" which would operate Rocky Mountain doubles from Alberta Province
through the western U.S. into Mexico.

Even if this effort at "harmonizing" our federal weight laws at higher levels or
allowing the widespread use of LCVs doesn't succeed in the short run, you may be
sure that the border states, especially those abutting Mexico which have mostly fed-
eral weight limits on both their Interstate and non-Interstate highways, are prime
candidates for persuasion by the trucking industry that it is their interest to lift
their size and weight limits on those non-Interstate highways that would prove at-
tractive to cross-border truck traffic.

In most instances, these non-Interstate highways would be NHS candidates. This
is why it is so crucial for both houses of Congress to look into the future and to
see the need now to control truck sizes on the NHS. Without the controls of the
Interstate system extended to the other 115,000 miles of priority routes forming the
NHS, it is inevitable that the trucking industry will increase the pressure on the
states to raise the size and weight ceilings on these roads and then to use an argu-
ment that appeals to the absurdity of bigger, heavier trucks operating on the non-
Interstate highways of the NHS while only lighter trucks are allowed on Interstate
highways.

Let me return to the issue of the LCV freeze. I mentioned earlier in my testimony
that the recent GAO report may be interpreted to vindicate the virtues of LCVs. But
is it true that the GAO report has endorsed an end to the LCV freeze?

I don't believe that a close reading of the arguments and considerations of the
GAO support this view. GAO reports on transportation are well-known for the care
and circumspection behind any conclusions and recommendations that are placed
before Congress for its consideration. The current report on LCVs follows not only
two previous reports devoted to LCVs, but also a host of other reports on infrastruc-
ture and highway user cost responsibilities in which the GAO explicitly considers
the role that heavy trucking plays in both safety and highway damage. I would like
now to review the findings of the GAO's August 1994 report on LCVs and to place
those findings within the context of the observations and recommendations of a
number of other recent GAO reports that address the issue of bigger trucks on our
roads and bridges.

First of all, Mr. Chairman, I think I should point out here at the start of this
review what the trade press thinks of the import of the GAO LCV report. For exam-
ple, here is the headline and initial sentence of the August 22, 1994, issue of Traffic
World:

GAO REPORT OFFERS TEPID SUPPORT, SOME WARNINGS ON EXPANDING USE OF LONGER

TRUCKS NATIONWIDE

Twin 48-foot and triple 28-foot trailers would be a productivity bonanza to
some truckers but would be costly for governments to assure they run safely.
P. 19. Now, this is, of course, not the way the report was characterized in the sto-
ries of Transport Topics or the Journal of Commerce, Mr. Chairman, to no one's sur-
prise. But let's allow the GAO report to speak for itself and then place GAO's find-
ings in the context of its other reports that bear on trucking policy and practice.
This should let us see if it is true that the GAO is recommending an end to the
LCV freeze.
Right at the start of the report is a summary which states the following:

LCVs could also generate costs for public authorities who provide and pay for
the infrastructure used by the trucking industry. * * ♦ [AJccording to the Fed-
eral Highway Administration's (FHWA) analyses, nationwide use of LCVs on
the interstate system could require additional investments of $2.1 billion to $3.5
billion to replace bridges, improve interchanges, and provide staging areas for
the breakdown and assembly of LCVs. Much of the projected infrastructure
costs would be incurred in the more densely populated areas of the country. If
LCV expansion were limited to carefully selected routes away from major popu-



36

lation areas, the cost impact would be limited, but the benefits would also be
reduced."*
Our quoted GAO summary appears to be a model of restraint and caution. But
let's allow GAO to continue speaJting for itself on the LCV issue:

Any decision to allow the expanded use of LCVs involves safety concerns as
well as economic factors. The limited data available on the safety record of
LCVs show that they have not been a safety problem on the western highways
and eastern turnpikes where they currently operate. However, GAO's previous
reports identified operational characteristics of LCVs that could make them a
greater safety risk than single-trailer combinations if allowed on more-con-
gested highways.''
Furthermore, "GAO has previously reported that LCVs have operational charac-
teristics, such as trailer sway, that make maneuvering in traffic more challenging
than for single-trailer vehicles."^

Advocates does not agree with the assessment that LCVs have not been a safety
problem. As we will show in other GAO quotations, it is well known that separate,
accurate data on LCV mileage and crash involvement is quite poor'' and that real
ingenuity has to be applied to existing data bases on truck registrations and crashes
to extract reliable conclusions on LCV safety.^

We believe that LCVs, on balance, are more dangerous. Advocates and other safe-
ty organizations presented our findings, including data analyses, to Congress on the
eve of Intermodal Surface Transportation Efficiency Act (ISTEA) passage in 1991
documenting the safety problems of LCVs. I would be pleased to submit this infor-
mation to the Subcommittee.

But GAO itself has a cautious view in its 1994 LCV Report of the safety con-
sequences of LCVs, especially what could occur in expanded operations:

LCVs have operating characteristics that can reduce their stability and ma-
neuverability compared with those of single-trailer combinations. Stability is
more of a concern for triples than for doubles, but heavier doubles can present
problems when merging into traffic because of their slow acceleration and can
also be very slow-moving on grades.

Triples operating at highway speeds tend to exhibit trailer sway — a side-to-
side movement of their multiple, relatively short trailers. This can be caused
by a driver's sudden steering movements, poor maintenance of the converter
dollies that connect trailers, rutted highways, or wind gusts. Rearward amplifi-
cation of trailer sway — often called the "crack the whip effect— is usually initi-
ated when drivers make sudden steering movements to avoid obstacles and is
also more pronounced for triples. TumpiJte doubles ♦ * * are slower to acceler-
ate and move with traffic. Unless tractor power is significantly increased, speed
differentials can present a hazard in traffic, especially on grades.^
Furthermore,

Under less-than-ideal conditions * * ♦ LCV braking can be less efiective.
Out-of-adjustment brakes, the most commonly found defect in roadside inspec-
tions, would be more serious for LCVs because of the greater number of brakes
that must be properly adjusted and must work in the proper sequence. Also, if
the last trailer is empty or lightly loaded, chances are greater that the trailer's
brakes will lock and cause it to swine out to the side.^°



■•1994 LCV Report, p. 1. One of the trucking industry major consulting groups recommended
a few years ago that one of the ways we could get these staging areas nationwide, especially
in more densely populated areas where land adjacent to the Interstate system is prohibitively
expensive, is to get Congress to allow public rest areas to be converted to staging yards for put-
ting together and breaking down giant triples and Turnpike Doubles. No further comment
should be needed on this idea.

«Id., p. 2.

6Id., p. 6.

''GAO points out in the 1994 LCV Report that it "previously reported that most states that
allow LCVs do little to monitor their operations, regulate drivers' qualifications, or inspect the
vehicles." Id.

^GAO recognizes this:

[T]he lengths of trailers are rarely recorded on accident forms, making it impossible to sepa-
rate accidents involving turnpike or Rocky Mountain doubles from those involving the double
28-foot trailers o[)erated nationwide. Also, very little mileage data on LCVs are available, thus

making it diflicult to compare accident rates of LCVs with those of single- trailer trucks.

♦ ♦ ♦

[Llittle is known about the safety of doubles, particularly Rocky Mountain doubles. The latter
are operated * * * on a wider network of roads — many of these two-lane roads.
Id., p. 43.
»Id., p. 42.
10 Id., p. 43.



37

This concern over the roadside inspections accorded LCVs is well-taken: the GAO
stresses that it "found the out-of-service rate for doubles combinations exceeded that
for all trucks inspected in 8 of 12 states" and that there is evidence that "the longer
combinations have been underrepresented in roadside inspection programs." ^^ As
far as driver compliance with traffic regulations, the GAO points out that "because
traffic citations do not specify vehicle configuration, states cannot monitor the per-
formance of LCV drivers and their compliance with permit requirements." ^^

In sum, the GAO has serious doubts and misgivings about the safety of LCVs,
including a concern that "[a] wider use of LCVs could bring them in proximity of
major metropolitan areas and on more-heavily traveled highways, whicn would en-
tail greater risks to the passenger traffic with whom trucks share the highways." ^^
If the evidence on LCV safety is either unknown or adverse to their expanded use,
how does the GAO assess the impact of these multi-trailer rigs on our infrastruc-
ture, including ramps and interchanges, and destruction of roads and bridges? In
its 1994 LCV Report, it found that:

The longer LCVs have difficulty negotiating some interchange ramps and also
need staging areas where they can be assembled or broken down for delivery
as shorter combinations. Modifying interchanges and building staging areas to
provide LCVs regular access to and from the interstate system could be a costly
undertaking, depending on the number of access points deemed necessary.

Because of their length, some LCVs off-track, or "cut corners", more than sin-
gle combinations. This restricts their ability to negotiate intersections ♦ * ♦ Be-
cause of of!lracking, the longer LCVs also have dimculty with some interchange
ramps.

Turnpike doubles have the most problems with ofT-tracking * * * Figure 2.3
illustrates the difTiculty that a turnpike double has with cloverleaf interchanges
* * * According to a survey done by AASHTO in 1985, state highway officials
estimated that as many as 75 percent of the interchanges on the interstate sys-
tem were inadeauate for turnpike doubles, 66 percent were inadequate for Rocky
Mountain doubles, and 57 percent were inadequate for triples. It should be noted
that respondents considered half the current interchanges to be inadequate for
48- foot trailers as wellM
You will note that half of our Interstate interchanges could not accommodate a com-
bination with a 48-foot semi-trailer. Let me stress in this connection that the cur-
rent "industry standard" for semi-trailer length is now set at 53 feet.^^

The GAO in its 1994 LCV Report quotes a FHWA 10-year old estimate of $750
million to $2.2 billion on the cost to reconstruct these ramps and interchanges, and
provide other access changes, to meet the needs of all current types of LCfVs.i^ In
addition, it investigates costs from the correlative damage inflicted on roads and
bridges by big trucks, including LCVs. For bridges, the GAO calculated two different
load capacity ratings to use for bridge improvement cost estimates, the well-known
inventory rating forming the basis ofreporting to the federal National Bridge Inven-
tory, and an "intermediate" rating of the GAO's own construction which is more de-
manding than the operating rating, but less so than the inventory rating. The GAO
was unable to use the more liberal operating rating because FHWA claimed that
state reporting of operating ratings were inconsistent.^'^

The use of the conservative, that is, inventory rating, produces projected replace-
ment costs of over $5 billion for rural interstates and over $13 Dillion for urban
interstates. The cheaper rating scheme was found to generate a cost of $248 million



11 Id., p. 44.
i^Id.

13 Id., p. 45. This GAO understanding of the enormous safety costs associated with the oper-
ation of big trucks appears repeatedly and consistently in its reports on safety and infrastruc-
ture. For example, in its 1992 report Intermodal Freight Transportation: Combined Rail Truck
Service OfTers Public Benefits, But Challenges Remain (GAO/RCED-93-16, December 1992), the
GAO points out early in its considerations that

While the public has benefited considerably from the performance of the trucking industry,
this has not come without a cost. * ♦ ♦ In accidents involving medium or heavy trucks with
another vehicle in 1990, 220 truck occupants were killed compared with 4,057 occupants of other
vehicles. Congressional concern over the safety impact of growing truck traffic has been reflected
in ♦ ♦ ♦its 1991 freeze on routes authorized for double- and triple-trailer combinations.

Pp. 8-9.

14 1994 LCV Report, p. 26 (emphasis supplied).

i^In informal discussions with highway officials. Advocates estimates that a significantly
higher percentage of interchanges would be deemed deficient for the current crop of "industry
standard" 53-foot long semi-trailers, probably in excess of 60 ptercent.

i« 1994 LCV Report, p. 2.

"Id., p. 18.



38

for rural interstates and $1.1 billion for urban interstates.^^ These are costs that
would have to be borne by the states as a direct result of expanded use of LCVs.i^
The use of even the "intermediate" capacity rating to project costs, that is, the rat-
ing that intervenes between the stringent inventory rating and the more generous
operating rating, "shows that use of doubles and triples increases bridge replace-
ment costs more than 50 percent; use of inventory rating increases replacement costs
by more than 400 percent.'^^

I should point out here that other, federal considerations bear directly on whether
one should use a more conservative rating to gauge bridge and pavement replace-
ment costs to ensure that capital investments in infrastructure last longer and are
made with cheaper dollars at an earlier opportunity. FHWA recently put out a no-
tice asking for comments on its preliminary policy on life-cycle costing. Aimed at
correcting the mistakes of the past 20 years when the federal government was in
the business of pouring money into short-lived, thin pavement overlays on both
roads and bridges, this Federal Register entry emphasizes a cautious, conservative
approach to designing long-term quality into our roads and bridges because "[tjotal
life-cycle costs of specific facilities may be many times the initial construction costs
when user costs are considered." ^i "It is essential that a long term perspective be
taken in programming improvements, selecting among alternative maintenance, re-
habilitation, and reconstruction strategies, and designing pavements, structures
[i.e., bridges], and other highway elements."^^ In particular, the logic of life-cycle
cost analysis

may favor selection of improvements with higher initial costs in order to achieve
significant long term savings in overall investment requirements. It may indi-
cate, for instance, that more projects warrant reconstruction rather than reha-
bilitation strategies * * * or that somewhat higher designs or levels of service
may be appropriate for some facilities. * * *

Life-cycle cost analysis will help agencies to identify and explain the real
costs borne by transportation users of inadequate transportation funding. ^-^
Unfortunately, the investment logic of life-cycle cost analysis, including tne reas-
sessment of the contribution to road and bridge damage made by different classes
of vehicles, forms no part of the GAO's 1994 LCV report. The penny- and pound-
wise investment scenarios generated by life-cycle cost analysis dictate a hard look
at using more conservative measures of infrastructure restoration costs, such as
bridge capacity inventory ratings, to select project designs. FHWA, in particular,
stresses the importance of these considerations in making project design and fund-
ing decisions for the NHS. It points out that:

longer design lives should be considered for improvements on the NHS and
other high volume urban roadways because future agency and user costs associ-
ated with maintenance and rehabilitation activities may be so high. For pave-
ment improvements on the NHS, design lives of 50 years may be reasonable
while bridge and tunnel improvements may have design lives of 100 or more
years. '^'*
Advocates does not believe that these kinds of fiscally responsible project decisions
for bridge renovation can be made using capacity ratings more liberal than the in-
ventory rating. But it is necessary to point out the downside to using more conserv-
ative, more durable project designs: they inevitably will be exploited by the trucking
industry which right now, despite a $130 billion backlog of unmet bridge needs,^^



'^Id., p. 5. GAO pKjinted out in its 1991 report on bridge infrastructure needs that "[wjhen
bridge needs are assessed in terms of the cost p)er system U) impnwe * * ♦ the primary system
would require the greatest investment level to improve its critically deficient bridges — $3.3 bil-
lion, or 4b percent of the proposed investment." See Bridge Infrastructure: Matching the Re-
sources to the Need, GAO/R(^RI)-91-l67, July 1991, p. 19. Primary arterials are, of course, the
majority surface mileage in the planned NHS.

'Bid,, p. 24.

^ Id., p. 25 (emphasis supplied).

â– 'I 59 VR 35404, 35405.

22 Id. at 35405.

M|d.

2^ Id. at 35406 (emphasis supplied).

2* In his 1992 testimony, Transportation Infrastructure: Major IVogram Revisions Present
Challenges (GAO/T-RCKI)-92-9;), September 17, 1992), Kenneth Mead, Director of the Transpor-
tation Issues Resources, ('ommumty, and Kconomic Development Division of the (^AO, asserted
early in his statement that:

|0|ur basic surface transportation infrastructure is aging and in need of costly repairs. For
instance, the Department of Transportation reported to the ('ongress in September 1991 that
the funding backlog for bridges that are either structurally deficient or functionally obsolete to-
taled $91 billion in 1990. Furthermore, the cost of repairing or replacing these bridges could



39

claims that even present bridge designs on the Interstate system warrant higher
truck weights. More responsible project design selection will almost certainly fuel
more demands for even greater truck weights.

The GAO at points in its 1994 i>CV report recognizes, however, that its bridge
repair figures based on an "intermediate" capacity rating might be too parsimonious.
For example, it points out that "ln|ationwide use of LCVs could generate additional
costs to reconstruct bridges because the gross weights of LCVs may exceed levels con-
sidered safe on some bridges."^^

Moreover, all of these considerations on projected infrastructure costs pivot on the
assumption that LCVs will not increase axle weights in excess of those already per-
mitted under federal law. But the GAO recognizes that this may not be true. It
points out in the 1994 LCV report that "Nevada * ♦ ♦ had observed that LCVs were
averaging higher axle loads in the state than conventional tractor-trailers and, con-
sequently, were assumed to be causing more pavement damage."-^'' Triples are par-
ticularly prone to be a serious offender in axle weight violations since "lijf heavily
loaded, Itheyl could be more damaging than five-axle tractor-trailers because they
use single axles rather than tandems under their shorter trailers."*'"

Other, recent GAO reports place in bold relief the problems of pavement damage
resulting from extra-heavy big trucks, especially because of excessive axle weights.
The GAO points out in its 1992 report on intermodal freight movement that:

The increasing ton-miles of highway freight traffic have also generated con-
cern about accelerated highway deterioration. On the basis of a truck weight
survey on rural interstate highways, the Federal Highway Administration
(FHWA) has estimated that equivalent axle loadings increased more than 350
percent between 1970 and 1990. An equivalent axle loading represents the dam-
age caused by one pass of an axle bearing 18,000 pounds. This relative damage
factor increases geometrically with increased weight on the axles, so that a
heavy truck accounts for many more axle loadings than a passenger car. FHWA
estimated that 91 percent oi the equivalent axle loadings on rural interstate
highways in 1990 were from tractor trailers with five or more axles. ^^
P. 4. Mr. Mead emphasized that this meant that "ISTKA's challenge is to sustain