April 22, 2019
The Honorable John Barrasso
Chairman, Committee on Environment and Public Works
United States Senate
307 Dirksen Senate Office Building
Washington, D.C. 20510
The Honorable Tom Carper
Ranking Member, Committee on Environment and Public Works
United States Senate
513 Hart Senate Office Building
Washington, D.C. 20510
Dear Chairman Barrasso and Ranking Member Carper:
As you consider an infrastructure and highway bill, the undersigned organizations ask that you support the inclusion of a provision which would grant a 10% axle-weight tolerance for laden trailers specifically designed to transport dry bulk products, but leaves the maximum gross vehicle weight limit at 80,000 lbs.in most States. We make this request because the dry bulk freight loads regularly shift during transport and can cause an overage of the tandem-axle weight limit, while the overall gross weight limit for the vehicle is not exceeded.
Most trailers’ front axle weights are capped at 34,000 lbs., though federal law provides a formula to ensure that certain specialty trailers and configurations can operate when they do not pose road degradation dangers. When it comes to the transportation of dry bulk freight, the freight itself can often shift, causing a specific axle group to be overweight at enforcement scales, even though the product was appropriately distributed during loading. Allowing for a 10% axle-weight tolerance for a specific axle group, while preserving the current gross vehicle weight limit would ensure that dry bulk freight shippers and their customers are not unfairly penalized for the incidental movement of their freight during transport while also preserving high quality road infrastructure without impacting safety for the traveling public.
Dry bulk freight products include plastic pellets, flour, grain, corn kernels, and other solid substances with small individual particles that comprise the substance as a whole. Shippers load dry bulk freight products by blowing them into the rear of the trailer. When dry bulk freight products are loaded onto cargo tank commercial motor vehicles, they often collect at the portion of the trailer immediately behind the tractor. Unlike a liquid, which naturally levels itself out, the dry bulk freight products can remain unevenly distributed throughout the tank trailer, in spite of incidental movement while in transit.
Our proposed provision would modify federal law to recognize the reality of transporting dry bulk freight. It would make no changes to the maximum gross vehicle weight limit; nor does it require changing the bridge formula. This provision would not disrupt the modal playing field. This provision simply adjusts present law to ensure dry bulk freight carriers and shippers are not unfairly penalized for a process of loading dry bulk freight products which is unique to the industry and the incidental movement of that freight in transit. We urge you to support the inclusion of this provision in an infrastructure and highway bill.
Sincerely,
AgriBusiness Association of Kentucky
Agricultural and Food Transporters Conference
Agriculture Transportation Coalition
Alamo Cement Company
Alamo Transit Company
American Chemistry Council
American Trucking Associations
Brewers Supply Group
Bulkmatic Transport
Buzzi Unicem, USA
California Grain & Feed Association
Chicken & Egg Association of Minnesota
Colorado Motor Carriers Association
Council on the Safe Transportation of Hazardous Articles
Galata Chemicals
Georgia Poultry Federation
Grain and Feed Association of Illinois
Hoffman Transportation
Honeywell International
Imerys S.A.
Indiana State Poultry Association
Industrial Millera Association – North America
International Vessel Operators Dangerous Goods Association
Iowa Poultry Association
Iowa Turkey Federation
Kansas Agribusiness Retailers Association
Kansas Grain and Feed Association
Kentucky Poultry Federation
LafargeHolcim, USA
Liteflex
Michigan Allied Poultry Industries
Minnesota Turkey Growers Association
Mississippi Poultry Association
National Council of Farmer Cooperatives
National Grain and Feed Association
National Grange
National Tank Truck Carriers
National Turkey Federation
Nebraska Grain and Feed Association
North American Millers’ Association
North Carolina Egg Association
North Carolina Poultry Federation
North Dakota Grain Dealers Association
Ohio AgriBusiness Association
Oklahoma Grain and Feed Association
Oklahoma Trucking Association
Pacific Egg & Poultry Association
Pacific Northwest Grain & Feed Association
PennAg Industries Association
Pfister Bulk Transport
Plastics Industry Association
Renew Kansas
Reusable Industrial Packaging Association
Rocky Mountain Agribusiness Association
South Carolina Trucking Association
Tennessee Poultry Association
Tennessee Trucking Association
Texas Grain and Feed Association
Texas Poultry Federation
The Fertilizer Institute
The Monarch Cement Company
The Northeast Agribusiness and Feed Alliance
Transportation, Elevator, & Grain Merchants Association
Truckload Carriers Association
U.S. Poultry & Egg Association
Virginia Trucking Association
Washington Penn Plastic Co.
Wayne Transport, Inc.
Wisconsin Agri-Business Association
Wyoming Trucking Association
Wyson Trucking
