January 17, 2014
Jeffrey Lindley
FHWA Associate Administrator for Operations
Federal Highway Administration
Office of Freight Management and Operations
1200 New Jersey Ave. SE, E84–471
Washington, DC 20590
North Dakota Stockmen’s Association’s Comments on the Moving Ahead for Progress in the 21st Century Act (MAP–21) Comprehensive Truck Size and Weight Limits Study
The North Dakota Stockmen’s Association (NDSA) submits the following comments to the United States Department of Transportation (USDOT) regarding the Moving Ahead for Progress in the 21st Century Act (MAP–21) Comprehensive Truck Size and Weight Limits Study.  The NDSA is an 85-year-old trade organization representing approximately 3,000 beef cattle producers in the state. 
Overview of North Dakota’s Beef Industry
According to the United States Department of Agriculture (USDA), the North Dakota beef industry is comprised of 10,500 beef cattle operations which have 1,790,000 head of cattle and calves.  The state of North Dakota produces some of the best feeder cattle, which have historically been in high demand by feedlots across the country. 
Many of the operations located in North Dakota are cow-calf operations. As a result, many calves are weaned and backgrounded, loaded onto a truck and relocated to feedlots further south for finishing where the packing industry is more centrally located. After a few months of putting on weight at the feedlot, the cattle are shipped to the packing plants for processing.
Cattle are no longer shipped by rail, and nearly all of the transportation in North Dakota occurs via truck. For producers in areas far from feedlots, the added cost of shipping comes out of their profit margin. The NDSA actively supports the Safe and Efficient Transportation Act (H.R. 613) (SETA) that gives states the option to increase truck weights on federal roads from 80,000 lbs. to 97,000 lbs. with the addition of a sixth axle. Study after study (both in the U.S. and abroad) has supported this idea and we want to give our cattle-producing families the opportunity to consolidate their loads into safe and efficient means of transportation.
For more than 25 years, the federal vehicle weight limit has been set at 80,000 pounds—a regulation that now challenges our safety, economy, environment and infrastructure. Shippers often meet this limit with significant space in their trailers, and are forced to use more truckloads, miles and fuel than necessary.  This is particularly true in North Dakota where the regulations are mandated as a gross vehicle weight standard, and allow a weight of up to 105,500 pounds on some secondary highways.  You can see this as a major problem when transporting cattle through other states.
As previously mentioned, the NDSA supports legislation known as the SETA. We support SETA because numerous studies support the safety aspects it represents as well as the following comments:
      • SETA gives states the option to safely raise interstate weight limits without making trucks larger.
States would be free to set interstate weight limits of up to 97,000 pounds—but only for vehicles equipped with an additional (sixth) axle. The required sixth axle would maintain braking capacity and handling characteristics without changing the size of the truck. It would also minimize the weight-per-tire to minimize pavement wear.
     • SETA pays for itself. While the additional axle maintains vehicle safety performance and reduces pavement wear, SETA requires operators of heavier trucks to pay a slightly higher user fee—a continuation of the fee already in place. Those fees would be redirected to states and used to fund bridge maintenance.
     • SETA will allow heavier trucks onto interstate highways—the safest place for heavier traffic.  Within the U.S., more than 90 percent of states allow heavier trucks to access some or all secondary roads, but federal regulations keep them off the interstate—the safest place for truck shipments. In addition, many of the heavier trucks that are already permitted on state roads operate on five axles—instead of the safer six axles SETA requires.
Safely Modernizing U.S. Truck Weights 
     • SETA is a carefully crafted bill allowing more productive trucks to operate on interstate highways—but only under conditions that are designed to ensure safety and protection of infrastructure.
The trucks SETA allows are able to carry heavier loads for a total weight of up to 97,000 pounds, but are not bigger or longer. They must be equipped with six axles, instead of the typical five, in order to preserve safety characteristics, maintain current axle limits, and lower weight-per-tire displacement.
Optional & Selective State Participation
     • SETA is not a national mandate. The bill simply gives each state the flexibility to open all, or portions of, its interstate networks to these particularly more productive vehicles, i.e. “SETA vehicles.”
     • For these states that allow heavier trucks to access some portions of their road networks, SETA presents an opportunity to better harmonize limits so shippers can utilize heavier loads on the safest, most efficient roads and bridges which are often part of the interstate network.
     • Six-axle trucks are safer and better equipped than those allowed on many roads across the U.S. More than 90 percent of states already allow heavier trucks to access some or all road networks. Because of the current federal weight limit, many of these heavier trucks are relegated to non-interstate roads which are often less safe and efficient. In addition, many of these heavier trucks operate on five axles instead of the six axles SETA requires.
The USDOT estimates that, by 2025, the amount of freight shipped throughout the United States will increase 87 percent from what it was in 2000. That means the United States must not only increase its infrastructure, but find more efficient ways to ship goods. By consolidating shipments, there will be fewer trucks on the road overall.
In the beef industry, the safety of our animals is our top priority. The last thing our producers want to do is jeopardize the safety of their animals by cutting corners in shipping. But that doesn’t mean we should not learn from the advancements of others. Since the United Kingdom raised its gross vehicle weight limit to 97,000 pounds for six-axle vehicles in 2001, fatal truck-related accident rates have declined by 35 percent. More freight has been shipped, but the vehicle miles traveled to deliver a ton of freight has declined.
The beef industry is very diverse and relies on the safe, timely transportation of livestock from all corners of the country to keep up with global demand for a high quality product. The safety and welfare of our animals remains a top priority for NDSA and we encourage you to carefully consider these comments and listen to the concerns of the men and women who take pride in providing food for our growing nation and the world.
Finally, the NDSA actively supports the Safe and Efficient Transportation Act that gives states the option to increase truck weights on federal roads from 80,000 lbs. to 97,000 lbs. with the addition of a sixth axle.
Thank you for this opportunity to comment.
Jason Zahn
North Dakota Stockmen's Association