Mr. Graves emphasized in his rejoinder yesterday, December 21, 2009, that Advocates had misrepresented the facts on overweight truck fuel use. In addition, Mr. Graves asserted that there were no studies showing that truck drivers were the preponderant reason for car-truck crashes. In fact, it is Mr. Graves who is putting out misinformation, not Advocates. We always document our claims down to the study and page number.

American Trucking Association: Bigger Trucks Use Less Fuel: In fact, it is Mr. Graves who is mistaken about heavier trucks and fuel use. Take a look at Table IX-1 of the Western Governors Scenario Analysis showing miles per gallon consumption by truck configuration and weight. The gross vehicle weight configurations modeled at indexed at 60,000, 80,000, 100,000, 120,000, and 140,000 pounds. The table clearly shows that, as gross weight increases for every configuration, miles per gallon worsen. For example, the 6-axle semi-trailer combination championed by many parts of the trucking industry, including ATA, shows a decline in fuel economy from 4.76 miles per gallon to 4.27 miles per gallon. This represents more than a 10 percent decrease in fuel economy for a truck 20,000 pounds heavier than the current federal gross weight limit on the Interstate highway system. P. IX-3. In addition, the Analysis stated: "Fuel savings are not directly proportional to VMT reductions because fuel economy decreases as vehicle weight increases.” P. ES-8 (emphasis added). In fact, the U.S. DOT in this study concluded that heavier trucks do not increase trucking productivity – U.S. DOT determined that increasing gross truck weight contributes little to overall freight transportation productivity. P. XI-3.

Mr. Graves states: “There are no studies showing that the majority of truck car crashes are the result of the truck driver. None.” To the contrary, several studies have shown that truck driver actions are the primary trigger for car-truck crashes. Also, FMCSA’s main agency representative on the causes for truck crashes, Dr. Ralph Craft, stated at the November 2005 International Truck and Bus Safety & Security Symposium that trucking industry representatives speaking at the conference were continuing to misuse FARS codes, and that there was no legitimacy to their claims based on FARS that car driver actions were the major cause of car-truck fatal crashes.

To these disclaimers of assignments of fault to car drivers may be added the following study findings:

►Shao (1986) studied highway interchange crashes and found that truck drivers were primarily responsible for the majority of these collisions.

►Schwartz and Retting (1986) found that passenger car drivers violated truck drivers’ right of way for 73 percent of cut off/lane change collisions, but that more than half of rear-end collisions resulted from truck drivers’ failures to stop in time for slowing traffic.

►Preusser (1994) found that nonfatal lane change crashes on the Washington, D.C. Interstate Capital Beltway were twice as likely to be the result of a tractor-trailer changing lanes rather than a light vehicle lane change.

►Council et al. (2003) found that in all crashes between trucks and light vehicles, trucks were more likely to be the “contributor” to the crash than light vehicles by 48 percent to 39 percent, and trucks were more responsible than light vehicles in backing, rear-end, right-turn, left-turn, and sideswipe collisions.

Jackie Gillan’s unwarranted criticism of Bob Poole’s post cannot be left unanswered. Such a misrepresentation of the facts should not be allowed to poison the debate over this critical issue. I will attempt to answer each of her major charges individually.

Gillan: Mr. Poole ignores the reality of extra-heavy rigs increasingly penetrating more highways of lower class road systems, such as minor arterials and major collector routes. So, heavier trucks will not be more gentle to the pavement because heavier trucks will also result in more trucks applying more and heavier axle loads than ever before on more roads where they formerly were barred. Take a look at Maine’s two-lane, two-way roads that have been beaten to pieces by 100,000-pound, 6-axle rigs.

Response: First, Maine’s secondary road system has not been “beaten to pieces” by heavier trucks. Maine’s secondary roads are about average nationally in terms of the percentage of pavement in poor condition, which is surprising given Maine’s snowy climate. However, Ms. Gillan makes a good point – secondary roads were not built to handle high volumes of heavy trucks – Interstates were, which is why the legislation to allow these trucks to travel on Interstates and avoid secondary roads makes profound sense. The legislation won’t cause more trucks to use secondary roads – they are already allowed to use them and they do. Instead, these trucks will now use Interstates, which were designed to handle their weight and numbers.

Gillan: The hidden, assumed premise in Mr. Poole’s argument is that bigger, heavier trucks will result in fewer trucks on the road -- and we know that's not true. Every time states or Congress have raised truck weights over the past several decades, the result was more, bigger, heavier trucks than ever before. Therefore, raising truck weights while more bigger, heavier trucks are allowed on more surface miles of highway than ever before, including being allowed on routes formerly closed to them, will produce more pavement damage, not the same or less. This is what happened earlier this year in North Carolina.

Response: A few months ago North Carolina authorized a small weight increase for trucks carrying certain commodities. There is no way data would be available this soon to allow a conclusion that this had an adverse impact on pavement. The number of trucks and truck VMT has increased due to a growing economy and population, not because of size or weight increases. In fact, it’s logical to assume that there would be more trucks were it not for those increases. By Ms. Gillan’s logic, carpooling and buses should be banned because their use puts more vehicles on the road since the overall number of vehicles on the road has increased since buses and carpools were put into practice. Her conclusion that authorizing the use of trucks with more carrying capacity actually increases the number of trucks defies common sense.

Gillan: Much heavier trucks will dramatically accelerate bridge damage and deterioration at a time when thousands of bridges are beyond their useful and safe service lives, and the states have almost no money available to reconstruct them.

Response: Increased bridge deterioration is probably the one legitimate concern with higher truck weights. However, increased weight limits are unlikely to “dramatically accelerate” bridge damage if proper bridge management is employed by state DOTs. It is also important to understand that bridge costs are just one factor in a cost-benefit analysis. For example, a recent study for the Wisconsin DOT found that allowing 6-axle, 98,000 lbs trucks on their highways would increase annual bridge maintenance costs by $8.5 million. However, the state would realize a net yearly economic windfall of more than $150 million. ATA supports higher user fees for trucks that take advantage of increased weight limits in order to pay for any increased bridge costs.

Gillan: As for more economical ton-miles of travel from multi-trailer trucks, it just isn't true, as was demonstrated in the 2004 U.S. DOT Western Governors Scenario report, among other studies and analyses. The trucking industry’s arguments on reduced costs per ton-mile of travel don't hold water, and rail fuel costs per ton-mile of travel are dramatically lower than the costs for transportation by triples and turnpike doubles.

Response: In fact, the Western scenario study found an 11 percent reduction in fuel consumption resulting from the expanded use of longer combination vehicles, and annual shipper cost savings of more than $2 billion. Other studies similarly found positive energy consumption and economic benefits from the use of more productive trucks. In some cases, the use of alternative modes, such as rail or water, may produce greater fuel savings. The reality, however, is that if use of these alternative modes was more economical, and practical for the shipper, then these modes would be utilized. The fact is, most truck shipments are on trucks because an alternative mode is either unavailable or impractical. All modes, including trucks, must operate at optimal efficiency in order to meet current and future freight demands, which are substantial.

Gillan: Mr. Poole also completely ignores the underpayment of equitable fees for highway use and destruction as trucks progressively increase weights and axles above 70,000 lbs. gross vehicle weight, as shown in the 2000 updated Addendum released by FHWA on its earlier Cost Allocation Study. That underpayment has grown through the years that federal user fees have stayed unchanged since 1984 at $550 for the heaviest registered trucks. And this heavy truck dramatic underpayment of its fair share of highway damage was corroborated in the Congressionally mandated report released in late 2007, Transportation for Tomorrow, produced by the National Surface Transportation and Policy Revenue Commission, as well as by the 1997 and 2000 updated Highway Cost Allocation Study released by the Federal Highway Administration. This federal subsidy of chronic heavy truck user underpayment is one reason why truck freight costs have remained low for many years, while rail freight transportation does not enjoy such a subsidy.

Response: The reports Ms. Gillan cites use data that is now nearly 15 years old. Since then, the percentage of highway user revenue paid by trucks has increased fairly dramatically. A new federal cost allocation study is due to be released by FHWA soon. ATA has expressed a willingness to support fuel tax increases provided the money is invested in critical highway projects. As for rail, I think we’re all aware of the massive public subsidies that railroads have enjoyed throughout their history, and any subsidies that trucks may have been given likely pale in comparison. Even today, railroads are lobbying for subsidization of track and equipment, including from state and federal funds paid for in part by the trucking industry. While the trucking industry pays around $37 billion in state and federal highway user fees, plus billions more in tolls, the railroads pay exactly nothing.

Gillan: Mr. Poole blames the drivers of small passenger vehicles for their own deaths, claiming that “more often than not it is the car driver, rather than the professional truck driver, who bears primary responsibility.” Mr. Poole is helping to protract the long propaganda war waged by the trucking industry to supposedly “prove” that the majority of passenger motor vehicle - large truck crashes is the fault of the drivers of the small vehicles. That claim is really based on only a single study, which the author repudiated a few years ago, and is countered by several other studies showing that these crashes are more often the result of truck driver actions than by the drivers of small cars.

Response: There are no studies showing that the majority of car-truck crashes are the result of the truck driver. None. There are, however, several studies which clearly show that most car-truck crashes begin with the actions of the car driver. This includes independent analyses by the Federal Motor Carrier Safety Administration, the AAA Foundation and the University of Michigan. Publicizing this information is not part of a “propaganda war” by the trucking industry. Rather, it is an attempt to identify and address the real causes of highway crashes. Ms. Gillan does no favors to car drivers by distorting the role that they play in accidents involving trucks.

Ms. Gillan is entitled to her opinion on the size and weight issue. She is not entitled to make up her own facts in the process. The preponderance of the evidence, based on decades of research and experience in the U.S. and other countries shows unequivocally that implemented properly, size and weight increases will have positive safety, environmental and economic benefits. I can understand that some commenters have financial interests to protect and it is unfortunate that, in the process, they choose to perpetuate some of the same false propaganda as Ms. Gillan. However, it is perplexing that somebody who purports to protect the public’s interest in this debate would choose to take a position that is clearly detrimental to the public welfare.

I have watched with great interest the opposing opinions posted in response to the question of “Should Heavier Trucks Be Allowed On Interstate Highways?” This is not a new question so, not surprisingly, many of the responses are simply old answers that have been endlessly recycled. With the exception of Bob Poole's posting, they do little to encourage the examination of a broad range of possible solutions, thereby doing a disservice to all surface transportation stakeholders and, for that matter, the entire nation.

The challenges facing our transportation system are complex. The ability to move people and goods in a safe and efficient manner is not optional if we are to maintain our personal freedom and economic vitality. Even modest annual growth rates in population and economic activity will continue to strain all modes within our transportation system. For that reason alone, it is important we remain open to serious consideration of a wide range of options. Increasing truck weight where appropriate is just such an option. Legitimate concerns exist (government policies to protect railroad profits is not one of them), but do not automatically mean they cannot be resolved. For example:

· Significant safety improvements can be achieved utilizing new safety technologies such as anti-rollover stabilization, lane departure warning systems and active cruise control.

· Pavement wear can be minimized by using different pavement types, low rolling resistance tires with proper inflation levels, different truck axle placement and/or increasing the number of axles.

· Instead of looking at the environmental effects of a single heavier truck, consider the effect per ton/mile, as is done with rail freight. The resulting improvement is significant.

· There is no rail service to 70% of our communities; so simply saying we should shift highway freight to rail is impractical, even if the railroads had capacity (which they don’t) on existing routes.

· Truckers are on record that they favor fuel tax increases that will go back into highway infrastructure and have stated frequently that they are willing to pay their fair share.

We are at an interesting time when infrastructure constraints, environmental concerns, funding shortfalls, and a poor economy combine in a way that requires new thinking to find new solutions. Bob Poole’s notion of truck only lanes was born of that spirit. Unfortunately, it will be extremely expensive and take many years to become a reality. As much as opponents don’t want to hear this, reasonable increases in truck size and weight are the quickest, least disruptive, least costly, and most practical way to begin to addressing these issues. One thing is certain: when answering this question, unwillingness to seriously consider this or other potential solutions to our transportation woes is not only unacceptable, it is irresponsible.

Increasing truck size and weight would lead to more damage to our nation's highways and bridges and more harm to the environment.

According to the U.S. Department of Transportation’s Highway Cost Allocation Study, trucks weighing 80,000 to 100,000 pounds pay just half the cost of the damage they cause to our highways. The study also found that trucks weighing more than 100,000 pounds pay even less — only 40 percent of the damage they cause. While the trucking industry claims that increases in truck size and weight will improve productivity and reduce logistics costs, those improvements will come at the expense of taxpayers.

These truck subsidies put other modes of freight transportation at a distinct disadvantage as well. As the Government Accountability Office (GAO) noted recently, “From an economic standpoint, this ... distorts the competitive environment by making it appear that heavier trucks are a less expensive shipping method than they actually are.” Increased truck size and weight limits would inevitably lead to more freight on trucks and less on railroads. Traffic diversion would mean that railroads would have less money to reinvest in their networks. This would lead directly to reduced rail capacity and poorer rail service.

Increased truck size and weight limits will also impact the environment. According to a recent independent study for the Federal Railroad Administration, railroads on average are nearly four times more fuel efficient than trucks. Any policy that leads to more traffic on roads and less on rails is not in the public interest.

America's freight railroads unequivocally oppose any increase to truck size and weight in the upcoming reauthorization of SAFETEA-LU.

I reviewed Bob Poole’s advocacy piece about bigger, heavier trucks, and our staff prepared the following response to his arguments:

Bob Poole’s point about highway pavement damage allegedly being reduced by allowing bigger, heavier trucks ignores the fact that some trucks will be operating at greater weights than the current maximum axle weights linked to pavement damage. For example, current Maine weight law and regulations allow 88,000 lbs. 5-axle rigs, which produce far more pavement damage than 80,000 lbs. 5-axle rigs with the maximum weights for single and tandem axles allowed by federal law (23 U.S.C. Sec. 127(a)). This is well known and is based on the 4th power principle of pavement damage, although some recent research has found that pavement damage rises exponentially at a rate that actually lies between the 4th and 5th power. Also, Poole fails to mention that these overloaded trucks are more prone to longer stopping distances and have higher rollover propensity, factors that increase crash risk. A major Transportation Research Board study released several years ago said that it had no basis to give a clean bill of health to the safety of bigger, heavier trucks with more axles.

Mr. Poole ignores the reality of extra-heavy rigs increasingly penetrating more highways of lower class road systems, such as minor arterials and major collector routes. As a result, axle weights increasing pavement damage, even by 6-axle rigs, isn't a zero-sum game: more, heavier trucks = more ESALs (Equivalent Single Axle Loads), the classic engineering rule of thumb used in all AASHTO policies and guidelines for quantifying heavy vehicle pavement damage. So, heavier trucks will not be more gentle to the pavement because heavier trucks will also result in more trucks applying more and heavier axle loads than ever before on more roads where they formerly were barred. Take a look at Maine’s two-lane, two-way roads that have been beaten to pieces by 100,000-pound, 6-axle rigs.

The hidden, assumed premise in Mr. Poole’s argument is that bigger, heavier trucks will result in fewer trucks on the road -- and we know that's not true. Every time states or Congress have raised truck weights over the past several decades, the result was more, bigger, heavier trucks than ever before. That fact is well documented. Therefore, raising truck weights while more bigger, heavier trucks are allowed on more surface miles of highway than ever before, including being allowed on routes formerly closed to them, will produce more pavement damage, not the same or less. This is what happened earlier this year in North Carolina. The Reason author is just wrong, and his argument is forged in an operational and political vacuum.

As for bridges, Mr. Poole is right. Advocates has been demonstrating for many years the infrastructure damage inflicted on bridges by increasing truck gross weights. This damage dramatically decreases bridge service lives, leads to bridges posted for lower weights, and increases the chances of structural failures. And this problem isn’t just the issue, as Mr. Poole states, of “97,000 lbs. and heavier rigs exceed[ing] current limits of the FHWA’s bridge formula.” Mr. Poole actually underestimates how badly overweight trucks destroy bridges.

In fact, the federal bridge formula is inherently mistaken and has led to the operational rationalization that more gross weight can be allowed on certain trucks just by adding more axles within the same wheelbase. That belief is dead wrong and has led to severely overloading bridges all across the U.S. Studies recently published by the National Academy of Sciences, commissioned by the states’ highway departments, have shown that bridge formula B is mistaken and underestimates bridge damage. Much heavier trucks will dramatically accelerate bridge damage and deterioration at a time when thousands of bridges are beyond their useful and safe service lives, and the states have almost no money available to reconstruct them.

As for more economical ton-miles of travel from multi-trailer trucks, it just isn't true, as was demonstrated in the 2004 U.S. DOT Western Governors Scenario report, among other studies and analyses. The trucking industry’s arguments on reduced costs per ton-mile of travel don't hold water, and rail fuel costs per ton-mile of travel are dramatically lower than the costs for transportation by triples and turnpike doubles. For this reason, Congress, the states’ departments of transportation, and environmental organizations are strongly involved in achieving a balanced, multi-modal surface transportation system. If Mr. Poole were truly interested in “economies of scale,” promoting increased long distance freight movement by rail and water clearly provide greater benefits at lower costs. We have beggared our national rail freight system with a destructive, unsafe emphasis on more bigger and heavier trucks as the myopic answer to efficient freight movement.

Mr. Poole also completely ignores the underpayment of equitable fees for highway use and destruction as trucks progressively increase weights and axles above 70,000 lbs. gross vehicle weight, as shown in the 2000 updated Addendum released by FHWA on its earlier Cost Allocation Study. That underpayment has grown through the years that federal user fees have stayed unchanged since 1984 at $550 for the heaviest registered trucks. And this heavy truck dramatic underpayment of its fair share of highway damage was corroborated in the Congressionally mandated report released in late 2007, Transportation for Tomorrow, produced by the National Surface Transportation and Policy Revenue Commission, as well as by the 1997 and 2000 updated Highway Cost Allocation Study released by the Federal Highway Administration. This federal subsidy of chronic heavy truck user underpayment is one reason why truck freight costs have remained low for many years, while rail freight transportation does not enjoy such a subsidy.

Heavy trucks get nearly a free ride at the federal level and in state after state where they have destroyed pavement and bridges at an astounding rate, as well documented in many states’ recent cost allocation studies showing radical heavy truck underpayment for the use and destruction of state highways. And the underpayment by heavy trucks of their fair share of highway damage is largely covered by overpayment by the owners and operators of small passenger motor vehicles. But this overpayment is still not enough to overcome the enormous, costly destruction wreaked by giant, overweight trucks.

So the alleged economies of scale from of bigger, heavier trucks not only are untrue, but the increased highway safety crash risk, increased use of scarce fossil fuels, increased imbalance of our national freight transportation system, and increased transportation infrastructure damage inflicted by bigger, heavier trucks will be disproportionately paid for by the public who will have to dig even deeper into their pockets than ever before to subsidize the use of these behemoths.

That reality also heavily impacts Mr. Poole’s argument for dedicated highway lanes for bigger, heavier trucks. The U.S. right now does not know how to pay for a highway reauthorization bill that is aimed at not allowing further highway and bridge deterioration. Funds are not available for substantial reconstruction, including procurement of new right-of-way that would be necessary for truck-only lanes. The Highway Trust Fund is broke and many states are broke.

And trucks weighing one hundred fifty thousand (150,000) pounds?! Pavement structures on many thousands of miles of highways and thousands of bridges would have to be radically upgraded to support such weights, and you can be sure that the trucking industry will not ante up the money to cover the actual cost of such improvements. Adding truck-only lanes will also require substantial reconstruction of adjacent lanes, not just the lanes built only for the gigantic trucks. Such a public works enterprise would also require hundreds of new entry and exit ramps to access these dedicated lanes that currently do not exist on Interstate highways. Such dedicated lanes are just truck-based versions of railroads running on pavement instead of on tracks. One hundred fifty thousand-pound trucks would muscle rail freight transportation even further out of the way and further tilt the scales towards overwhelmingly dominance of freight movement by large trucks at a time when our nation needs a freight policy that runs in the opposite direction.

Most discouragingly, Mr. Poole blames the drivers of small passenger vehicles for their own deaths, claiming that “more often than not it is the car driver, rather than the professional truck driver, who bears primary responsibility.” When the occupants of a small car tangle with a large truck in a collision, 98 percent of the people who die are in the small vehicle. This isn’t a metaphorical exaggeration – it actually is 98 percent of the people who are killed are in the small motor vehicle, and it doesn’t vary from year to year. Mr. Poole is helping to protract the long propaganda war waged by the trucking industry to supposedly “prove” that the majority of passenger motor vehicle - large truck crashes is the fault of the drivers of the small vehicles. That claim is really based on only a single study, which the author repudiated a few years ago, and is countered by several other studies showing that these crashes are more often the result of truck driver actions than by the drivers of small cars.

Mr. Poole’s argument for giant, overweight trucks on mile after mile of new, stronger pavement throughout the U.S. is a recipe for more deaths, more highway and bridge destruction, even more of an imbalanced national freight policy, and the use of bigger, heavier trucks that are even hungrier for fossil fuels.

More than 4,800 Americans were killed in crashes involving large trucks in 2007, according to Advocates for Highway Safety. Further, trucks at the current maximum weight, 80,00 pounds, are 50 to 100 percent more likely to be involved in a fatal crash than a truck weighing between 50,000 and 65,000 pounds, according to an analysis by the Michigan Transportation Research Institute. We do not need a pilot program to learn what already is clear: as trucks get ever larger, they put everyone else at risk.

James Hoffa explains it well: bigger trucks obstruct traffic, inflict more damage and are less able to respond quickly in accidents. We also know that bigger trucks do even greater damage to our highway system, depleting infrastructure and requiring extra dollars to patch it up. From an environmental perspective, as Rob McColluch notes, trucking already is America's fastest growing source of transportation pollution. Continuing to emphasize highways over rail as the future of goods movement – as encouraging larger trucks inevitably will do – will mean still more pollution and oil consumption. Trucking uses four times the amount of fuel to move a ton of freight per mile than rail.

Meanwhile, too many commuters remain trapped on highways, surrounded by large trucks, because there are so few alternatives available. Advocates of more and larger trucks might find a more receptive audience if safer options such as commuter rail, dedicated busways and high speed rail existed. But until that is true, most Americans will not even begin to contemplate larger, heavier, more dangerous trucks traveling through our cities and towns.

I’d like to correct some of the remarks and general misconceptions that other contributors included in their posts about the effects of more productive trucks.

The FY 2010 appropriations bill allows trucks in the state of Maine that weigh up to 100,000 pounds to use interstates, and allows trucks in the state of Vermont that weigh up 90,000 pounds to travel on interstates. The state of Vermont can also permit trucks hauling certain products such as unprocessed milk, forest products or quarry products to weigh up to 99,000 pounds – not the 120,000 pounds that some contributors cited on this blog.

Maine and Vermont already allow trucks with heavier weights on secondary roads. The one-year pilot program in the appropriations bill allows these heavier trucks to use safer federal highways that were designed to handle heavier trucks. The University of Michigan Transportation Research Institute found that trucks above 80,000 pounds have a lower fatal accident rate than trucks of less weight. There is no credible evidence to back up claims that heavier trucks pose a greater safety risk. Class of roadway is in fact the leading factor in truck-involved fatal accidents. Allowing heavier trucks onto interstates instead of forcing them to use more accident-prone secondary roads will help improve highway safety.

Our nation’s interstates were engineered and constructed for commercial and military use and can easily handle weights much higher than the current federal restrictions. Interstates are safer than state highways because they are wider, have shoulders, have more flat inclines and declines, and better engineered curves. Also, the addition of the sixth-axle preserves stopping distances by adding braking power, and lessens pavement damage by improving weight distribution. ATA supports the use of heavier trucks only on roads and bridges that are engineered to handle the load.

One contributor said that “history shows that more trucks end up on the road every time truck weights have been increased.” Well yes, as our nation’s economy has grown, so has the number of trucks that deliver the products we use on a daily basis. Over the past 20 years, 1987 – 2007, there has been a 52 percent increase in registered trucks on the road and a 70 percent increase in truck miles travel. In addition to commuter traffic increases, ATA expects overall freight tonnage in the U.S. to increase more than 26 percent by 2020. Bringing our nation’s truck size and weight in-line with the rest of industrialized world will reduce the rate of truck growth and help mitigate traffic congestion from this economic expansion.

The increase in registered trucks and truck miles traveled also highlights the impressive strides the trucking industry has taken to improve safety. According to the U.S. Department of Transportation statistics, truck crash rates, injury rates and death rates are the lowest they have been since the department began tracking those numbers in 1975.

The Environmental Protection Agency (EPA) agrees that more productive truck combinations can reduce emissions when compared to standard trucks. “Longer Combination Vehicles: A freight truck using longer or multiple trailers can haul more cargo than a standard combination truck, potentially saving up to $5,000 in fuel costs and 34 tons of carbon dioxide on a ton-mile basis annually,” said the EPA. Another study by the Maine Department of Transportation found that expanding the federal gross vehicle weight exemptions to additional portions of the Maine Interstate system would make trucks more fuel efficient and emit less particulate matter and nitrogen oxide as a result.

Today’s trucks are delivering life essentials safer and cleaner than ever before. The 2007 truck engine reduces particulate matter emissions by 90 percent, and new 2010 truck engine standards will reduce nitrogen oxide gas emissions by a similar amount – making them as clean as, or cleaner than trucks powered by natural gas.

In response to another contributor’s comments about shifting freight from truck to rail, the trucking industry recognizes the value of railroads as part of the freight network. Trucking companies are among the railroads' best customers, and place freight on railroads whenever the distance of travel and nature of the cargo make an intermodal rail-truck freight movement more economically viable for the customer. However, these opportunities are extremely limited and make up less than 2 percent of the freight market. Each shipping need must be looked at holistically to determine the best mode of transportation, or combinations of modes, depending on what is best suited to the specific task.

Trucks are the only viable option for most delivery destinations. At best, railroads serve only 20 percent of U.S. communities. Trucks, by comparison, deliver virtually all consumer goods that make our lives comfortable and about 70 percent of overall freight tonnage in the United States. Even if rail was more accessible, trucks are a more effective shipping option for lower density loads. In today’s just-in-time logistics system, trucking offers its clients reliable service with more flexibility than any other mode of transportation.

ATA supports using heavier trucks only on roads and bridges that are engineered to handle the load. State highway departments are in the best position to make these determinations and should have the ability to do so. Reforming federal truck weight and size regulations will make our highways safer, will reduce the rate of truck growth in the future, and will make the supply chain more efficient and reduce logistics costs for businesses and consumers.

John Runyan, executive director of the Coalition for Transportation Productivity, sent us the following response:

Since the current 80,000-pound weight limit was set in 1982, trucks have nearly doubled the miles they travel each year in an effort to keep up with consumer demand and a six-fold increase in gross domestic product. With the U.S. Department of Transportation predicting truck freight will double by 2035, new and innovative interstate weight regulation is a critical step to securing a safe, efficient future for America’s transportation network.

To keep our goods moving safely and efficiently, we must allow states to consider local conditions and set weight limits that make sense for interstates within their borders – just as Sens. Collins and Leahy have done with their respective pilot projects.

The Safe and Efficient Transportation Act (H.R. 1799), sponsored by Reps. Mike Michaud (D-Maine) and Jean Schmidt (R-Ohio), would give all states the opportunity to safely boost shipping efficiency. Under the bill, each state could raise its individual interstate weight limit to 97,000 pounds for trucks outfitted with a sixth axle. These heavier trucks would be restricted to roads and bridges that can safely handle them – even in states that authorize the higher weight limit.

It’s important to note that these higher productivity trucks would be no bigger or longer than trucks currently traveling on interstates. The reality is that many trucks carrying heavier goods now travel with significant space left in their trailers, forcing companies to use more vehicles and fuel than necessary.

Opponents tend to ignore the fact that these heavier trucks will be outfitted with a sixth axle for safety. The additional axle actually maintains current braking capacity and weight-per-tire-distribution while minimizing pavement wear. The U.S. Department of Transportation estimates that by cutting the number of trucks needed for shipments, the proposal would save $2.4 billion in pavement restoration costs over 20 years.

It’s clear that the number of vehicles will continue to increase with economic and population growth. What the Safe and Efficient Transportation Act and the Maine and Vermont pilot projects will do is safely minimize the trucks and fuel necessary to meet demand.

At the same time, academic studies and empirical evidence have consistently demonstrated that permitting heavier, six-axle trucks on interstates actually leads to fewer highway accidents while minimizing fuel use and emissions.

It is important to note that vehicle accident rates are strongly tied to vehicle miles traveled, or VMTs. Consolidating freight on fewer vehicles would eliminate VMTs and make roads safer. International Paper found that fully implementing this proposal would allow one of its southern paper mills to reduce the number of outbound trucks needed each week from 600 to 450, eliminating some 94,000 VMTs per week.

Many European countries, Canada and Mexico have already safely increased weight limits for properly equipped vehicles. The United Kingdom raised its gross vehicle weight limit to 97,000 pounds for six-axle vehicles in 2001. Since then, more freight has been shipped, while VMTs have leveled off and fatal truck-related accident rates have declined by 35 percent. Likewise, a 2009 Wisconsin Department of Transportation study found that if a law like the Safe and Efficient Transportation Act had been in place in 2006, it would have prevented 90 truck-related accidents in the state that year.

The Safe and Efficient Transportation Act would also allow the American shipping industry to reduce its carbon footprint. It’s a fact that six-axle trucks carrying 97,000 pounds get more ton-miles per gallon than trucks currently on our interstates. The U.S. Department of Transportation estimates that raising the federal weight limit would save 2 billion gallons of diesel fuel annually. And that’s not all. A recent study by the Northeast States Center for a Clean Air Future found that these trucks achieve a 15.3 percent fuel and emissions reduction for high density freight.

Now is the time for carefully crafted truck weight reform – legislation that recognizes the diversity of our country and its population and infrastructural needs.

Through an innovative proposal like the Safe and Efficient Transportation Act, each state can customize more efficient freight corridors and make highways safer, greener and more productive in the years ahead.

How can we resolve the conflict between highway safety and increased goods-movement productivity from larger trucks?

The first requisite is to turn to the findings of independent transportation researchers, not special interest groups with a stake in the outcome—whether freight carriers or highway safety groups. In terms of pavement damage, we know that six-axle configurations can distribute a heavier load in a way that would do no greater pavement damage than today’s 80,000-lb five-axle rigs. But we also know that 97,000 lbs. and heavier rigs exceed current limits of the FHWA’s bridge formula, an issue being brushed aside by the trucking industry’s current campaign.

The safety picture is mixed. While car-truck accidents cause thousands of deaths per year, mostly to those in cars, more often than not it is the car driver, rather than the professional truck driver, who bears primary responsibility. And the occupants of a Honda will be just as dead if hit by a 97,000 lb. truck as by an 80,000 lb. truck.

Then there are “economies of scale” issues. Larger truck rigs—not only 97,000 lb. six-axle semis but especially long doubles and triples—produce more ton-miles per driver hour and more ton-miles per gallon of fuel. That mean they reduce the unit cost of goods-movement by truck—and they also reduce truck freight’s carbon footprint.

Thus, transportation research tells us there are difficult trade-offs involved. Rather than accepting the simplistic positions of any of the traditional interest groups, I think we can realize the productivity, fuel-savings, and GHG-reduction potential of larger and heavier trucks without compromising either highway safety or the integrity of America’s highway bridges. Here’s how.

As major long-haul Interstate routes approach the need for reconstruction, those that are important truck corridors should be rebuilt with barrier-separated truck-only lanes. The pavement and bridge structures on these specialized lanes would be designed for much higher total gross weights—perhaps 150,000 lbs.—to facilitate the operation of turnpike doubles and triples. By keeping these longer and heavier rigs separated from personal vehicles, car-truck collisions on these routes would be virtually eliminated, enhancing highway safety. Those Interstate routes would no longer have their useful lives shortened by the relentless pounding of even today’s 80,000 lb. big rigs.

To be sure, rebuilding select Interstate routes with truck-only lanes will be expensive. But rebuilding major Interstates was going to be expensive anyway. Some combination of increased fuel taxes and tolls will be needed to fund such projects. But virtually the entire goods-movement industry now agrees that America needs greatly increased highway investment—and is willing to pay more to get it.

Instead of another same-old battle over bigger trucks on existing highways, let’s think outside the box for once and implement something better.

Highway drivers are never happy to see a 120,000 pound, six-axle rig come barreling along side them at 70 mph. The reason is simple: they’re dangerous.

Study after study shows that bigger trucks have a greater risk of crashing. And when they do crash, they’re more likely to kill someone.

Heavier trucks require longer stopping distances, so drivers needing even more reaction time to stop. On today’s overcrowded highways they don’t have that reaction time. Heavier trucks also need longer merger lanes to get up to speed with oncoming traffic, which they don’t have on our existing highways.

They’re also destructive. We know that these huge trucks put severe stresses on our roads and bridges. Additional axles do not mitigate the extra truck weight and strain placed on bridges. Billions of dollars are being spent right now under The American Recovery and Reinvestment Act to rebuild our crumbling infrastructure. It makes no sense to undo all that work with bigger, heavier vehicles.

The trucking industry is now claiming that these huge trucks are somehow “greener.” They don’t like to acknowledge what we all know to be true: big trucks are far less fuel efficient than smaller trucks. And history shows that more trucks end up on the road every time truck weights have been increased.

Sure, there might be some tiny gain in productivity if we allowed these dangerous rigs on our highways. But those gains aren’t worth compromising safety and destroying our roads and bridges. The current restrictions on the size and weight of trucks that travel the U.S. highways should stay as they are.

They damage highways and bridges, the safety, highway design and operating issues involved in allowing bigger trucks are not worth the negligible gains in productivity they might realize.”

States and federal government agencies don’t have enough funds to properly repair, maintain and expand our infrastructure to meet growing transportation needs, let alone build out the reinforced infrastructure necessary to operate longer and heavier vehicles on the current system.

Considering that they not only own the trucks in their companies, but quite often also operate those trucks themselves, small business truckers have a particularly astute perspective on the truck size and weight debate.

On average, the small business truckers who comprise the membership of OOIDA operate their vehicles well over 100,000 miles on U.S. highways each year. To say the least, they have a significant vested interest in safety on those highways as their lives and livelihoods literally depend on it. They know from firsthand experience that further increases in sizes and weights of commercial motor vehicles can endanger highway users and hasten the deterioration of our nation's roads and bridges. As such, OOIDA has long been an opponent of increases to federal truck size or weight standards.

While private sector advocates of increased truck weight and length limits often point towards unsubstantiated productivity and environmental benefits, they ignore both the safety risks and the added strain on highway infrastructure that would accompany heavier or longer vehicles. These factors more than offset any theoretical efficiency or environmental gains.

Increases to current standards could seriously jeopardize the safety of both automobile and commercial truck drivers. Simply put, the heavier the vehicle, the more problems it has interacting with other vehicles on the roadway as its stability, mobility and maneuverability are substantially reduced. Amongst other problems, heavier vehicle weight also increases stopping distances, exacerbates brake fade on downgrades and slows vehicle ascent on hills.

In addition those safety concerns, we as a nation can ill afford the added stress that heavier or longer vehicles will place on our decaying highways and bridges. Considering the current financial dilemmas being faced by the federal Highway Trust Fund and state transportation budgets as well as the overall condition of our nation's roadways, the last thing we need is to accelerate the deterioration of our infrastructure.

Also, if weights or lengths of trucks are increased, the already limited number of workable routes available to commercial motor vehicles would be further diminished. Efficiency in the trucking industry would actually be lost, not gained. As the size of vehicles increase, the number of highways and bridges that are designed to accommodate them become fewer. With vehicle weight and length increases, many trucking routes as well as pickup and delivery points would become totally inaccessible without substantial, costly upgrades to accommodate vehicles larger or heavier than currently allowed under the Federal rules.

Increases to allowable weight standards will also hasten the deterioration of trucking equipment. Strain on the engine and other drive train components, structural stresses on frames and suspensions, and accelerated tire and brake wear are just a few issues that are caused by hauling heavier loads. While these issues may not be of great concern to large corporate motor carriers who turnover their equipment on a regular basis, it would correspond to significant cost increases for the small business truckers that comprise the vast majority of the trucking industry in the U.S. Upgrading to vehicles equipped with heavier-duty components is a cost prohibitive proposition for small businesses. The increased wear on equipment is not only a costly maintenance issue, but also a serious safety concern.

If truck size and weight restrictions are set aside, a select few shippers may benefit, however, it is highly doubtful that the public would gain any economic relief or environmental benefit from those shipper's ability to utilize larger vehicles. Short term, limited economic benefits enjoyed by a few would pale in comparison to the increased costs associated with the loss of life and property as well as with accelerated deterioration of equipment and of our nation's transportation infrastructure.

Bigger trucks are bad for living things in just about every respect. Big, heavy trucks already double the risk of fatalities in accidents. In their wake, they also damage our highways at a geometrically higher rate - for example, increasing the weight of a heavy truck by 10 percent increases road damage by 33 percent - making our roads and bridges, many of which are in poor shape to begin with, even more unsafe. Finally, they will only increase pollution and oil dependence, counter to trucking industry claims of fuel savings and reduced pollution.

Bigger trucks have and will mean more trucks on the road, not fewer. Since 1982, when heavier trucks were permitted on our highways, the number of trucks on the road has grown by 37 percent - higher than both population and rail freight growth. The trucking industry is now America's fastest growing source of transportation pollution, generating more than 220 million tons of carbon dioxide per year.

There are better ways to carry freight long distance than heavy, dirty trucks. Trucking uses four times the amount of fuel to move a ton of freight per mile than rail. The trucking industry recently unveiled an ad campaign featuring train tracks in our malls and grocery stores, suggesting that rail can't get goods to market like trucks can.

This is true to a certain extent - but the real answer is a balanced freight system that maximizes efficiency among modes. We can't lay train tracks to the corner market. By the same token, we shouldn't unleash thousands of trucks that weigh as much as locomotives on our highways - killing more drivers, wrecking more roads, releasing more pollution and making us more dependent on oil.

Increasing allowable truck size and weight limits on our Interstate Highways will benefit our nation's economic productivity, reduce emissions, and improve safety.

At a recent conference hosted by the University of Michigan Transportation Research Institute, transportation experts from around the world discussed a soon to be released study that finds the U.S. is lagging in truck productivity, safety and sustainability when compared with Europe, Canada, Australia, and Mexico due to our overly restrictive size and weight limits.

ATA supports allowing more productive vehicles to operate on the Interstate Highway System, consistent with sound engineering standards and safety. At present, 6-axle trucks weighing 97,000 pounds are used extensively throughout the industrialized world. Bringing our federal regulations more in-line with international competitors will reduce logistics costs for businesses and consumers, allowing them to better compete in the global economy.

Making trucks more productive is not a new idea. In 1974, Congress used a Bureau of Public Roads (BPR), forerunner of Federal Highway Administration, study to formulate the current Interstate Highway System axle weight limits, bridge formula and even vehicle width. That BPR study called for truck weights up to 105,500 pounds on the Interstate, without need for special permits. So, the actions in Maine and Vermont are just a step closer to the original Interstate design.

Also, many states already permit trucks with weights higher than the federal 80,000-pound limit to operate on state highways. Allowing heavier trucks to use Interstates instead of forcing them onto more accident-prone secondary roads will improve safety. Using more productive trucks also decreases the number of trucks needed to haul the same amount of freight, reducing accident exposure, lowering pavement maintenance costs and mitigating traffic congestion along critical freight corridors. The addition of the sixth-axle preserves stopping distances by adding braking power, and lessens pavement damage by improving weight distribution.

The trucking industry is safer than ever before. Large truck crash, injury and fatality rates have reached their lowest point since the U.S. Department of Transportation began recording statistics in 1975. In 2008 the number of fatalities in truck-involved crashes experienced a record low in a continuing trend that can be expected to accelerate if size and weight reform is accomplished. Safety would improve because truck miles traveled would grow more slowly and result in less crash exposure.

Furthermore, several configurations supported by ATA have the best safety record of any truck. A study sponsored by the Federal Highway Administration found that longer combination vehicles (LCVs) - double and triple-trailer trucks - have a crash rate which is half that of the more common trucks they replaced. These statistics are confirmed by data collected by our members who operate these vehicles.

In addition to safety benefits, the Environmental Protection Agency (EPA) identified the use of more productive trucks as an effective strategy to reduce vehicle emissions as part of its SmartWay Transport Partnership Program. Truck size and weight reform will increase fuel efficiency because fewer trips are needed to deliver the same amount of freight. In fact, the American Transportation Research Institute (ATRI) found that a 97,000-pound truck is 17 percent more fuel efficient than an 80,000-pound truck when load capacity is factored in. LCVs are up to 39 percent more fuel efficient.

In another study, ATRI and the Maine Department of Transportation found that expanding the federal gross vehicle weight exemptions to additional portions of the Maine Interstate system would make trucks more fuel efficient and emit less particulate matter and nitrogen oxide as a result.

With U.S. freight tonnage expected to grow 28 percent by 2018, more productive trucks are needed to accommodate this increase. In today's just-in-time logistics system, trucks will continue to haul 70 percent of freight tonnage in the U.S., and nearly 100 percent of consumer products.

To increase productivity, ATA supports allowing 6-axle vehicles to carry 97,000 pounds and allowing states to permit use of longer combination vehicles where appropriate. Making these reforms will allow trucks to deliver the food, clothes, and medicine that we use every day in a more safe, and efficient manner - reducing logistics costs and decreasing the industry's carbon output.

The approval of the trucking industry’s big rig amendment to the 2010 FY Appropriations bill is a major setback for highway safety and a balanced national transportation policy. This special interest measure, which was quietly slipped into the FY 2010 Transportation, Housing and Urban Development, and Related Agencies (THUD) Appropriations bill without any public hearing, authorizes a one-year pilot program permitting trucks to exceed the federal weight limit by at least 20,000 pounds on all Maine Interstate highways and by up to 40,000 pounds on all Vermont Interstate highways.

The trucking industry is gleeful about this special interest measure using the spurious argument that it will lead to a safer, more efficient transportation system. Nothing could be further from the truth. In reality, the trucking industry pushed this amendment in order to overwhelm Maine and Vermont roads and bridges with overweight trucks at the expense of the safety of the motoring public. The trucking industry understands well that a one-year “pilot program” simply gets a big foot in the door that will be difficult to dislodge. This maneuver is an old strategy by trucking interests to ratchet up the sizes and weights of big trucks in one state after another. When some states resist raising their weight limits, the trucking industry will run to Congress crying out for federal pre-emption that overrides these refusals and compels all the states to raise their big truck weight limits to or above 100,000 pounds.

Bigger trucks are not safer trucks. Each year, about 5,000 people are killed and more than 100,000 are injured in truck crashes. The chances of a big truck crash resulting in deaths and serious injuries increase with each extra ton of weight over the 80,000 pound gross vehicle weight limit in federal law. A big truck weighing even a legal 80,000 pounds is 50 to 100 percent more likely to be involved in a fatal crash than a truck weighing 50,000 to 65,000 pounds. Overweight trucks also put tremendous pressure on roads and bridges, which could result in a safety disaster. How can we forget the horror that occurred on August 1, 2007, when the world watched the aftermath of the I-35 Bridge collapse in Minnesota killing 13 people and injuring nearly a hundred people including 22 children? No one anticipated the collapse of a major Interstate bridge in Minnesota, and increasing truck size and weight limits throughout the country will only add to the risk for similar disasters.

Truck size and weight increases serve to thwart and delay achieving our national goal of a balanced and efficient transportation system. Past increases in truck size and weight have never resulted in fewer trucks, fewer trips, or fewer miles traveled. In fact, according to statistics from the U.S. Bureau of the Census and the Federal Highway Administration, the number of trucks on U.S. highways has consistently grown over the past few decades even after federal and state increases in both the sizes and weights of large trucks.

The THUD bill indicates that it is “business as usual” when it comes to the trucking industry getting its way on unreasonable and unsafe demands that jeopardize the safety of everyone. This should be a warning sign in the upcoming battle over the surface transportation reauthorization bill. The trucking industry wants to roll giant, overweight trucks throughout the U.S. regardless of the severe consequences to safety, the environment and our infrastructure. This is why we need to enact federal legislation like the Safe Highway and Infrastructure Preservation Act (SHIPA), S. 779 and H.R. 1618.

The purpose of SHIPA is to prevent constant increases to truck sizes and weights on the non-Interstate roads and bridges of the National Highway System (NHS) so that both the Interstate system and the major non-Interstate routes of the NHS are protected from destruction by bigger, heavier trucks. H.R. 1618 is co-sponsored by more than 121 Democratic and Republican Members of Congress. SHIPA is strongly supported by national and state highway and truck safety groups, victims and survivors of truck crashes, as well as leading environmental and public interest organizations.

It is the most effective solution to preventing American motorists from being subjected to the never-ending cycles and dangers of increases in truck size and weight on our major highways. The big rig appropriations amendment was a giant step backward for safety and protection of our crumbling infrastructure. Enacting SHIPA will be a big and essential step forward for the health and safety of American families.