98 feet. Its temporary regulations permit an overall length of 105 feet.24 The New York State Thruway Authority reportedly permits the following maximums: Single axle, 22,400 pounds; tandem axle, 36,000 pounds; gross weight, 127,400 pounds; overall length, 98 feet. Similar vehicular operations reportedly are permitted on the Ohio and Indiana toll roads.

Information coming to our attention toward the close of the study indicates that certain experiments evidently are being conducted on "triple bottoms." Unfortunately, perhaps, since this information came to our attention, there has not been sufficient time to make further inquiry into this development as a basis for a more complete coverage of it in this report.

4. Effect of vehicular size and weight on highway costs

Much has been written as to the effect of vehicular size and weight on highway costs. There are certain highway costs which are attributable solely to the size of the large motor vehicles. To illustrate, on a 12-foot-wide highway lane at least 1 foot, and possibly as much as 2 feet, of the surface width can be attributed to the 8-foot width of large motor vehicles. Hence, the entire cost of providing a highway strip, from 1 to 2 feet wide, including the full thickness of the subgrade and the surfacing, is chargeable to the wide motor vehicles. Similarly, the wide motor vehicle also makes necessary 10-foot-wide shoulders where 8-foot-wide shoulders would be adequate for passenger cars and other light vehicles. In other words, even if large motor vehicles should not require other special features in highways, all costs involved in providing additional subgrade pavement and shoulder widths attributable to their needs should be assigned to them, not to other highway users.

There are other features of highway system design and construction for accommodation of large motor vehicles attributable primarily to their heavier axle weights and/or their inability to accelerate rapidly. These include:

(1) Additional thickness of subgrade.
(2) Additional thickness of pavement.

(3) Additional strengthening of bridges.

(4) Reduced gradients and increased radius of horizontal curves to permit suitable sight distances and sight-passing distances. Also, in rolling and mountainous terrain, special "climbing lanes" are made necessary solely to prevent large motor vehicles from blocking free movement of other highway traffic.

(5) Longer acceleration lanes on controlled access highways. Because the braking capability of large motor vehicles is generally similar to braking capability of smaller ones, the large vehicles do not require special features in deceleration lanes.

(6) Stronger subgrades and surfacing and to a lesser extent larger parking areas per vehicle unit at publicly provided rest

areas.

24 Kansas Turnpike Authority, letter to Gen. John P. Doyle, Staff Director, Transportation Study Group, dated Mar. 2, 1960.

5. Coordination of motor carriers and other transport media All of the developments described above have occurred in recent years. They merit careful scrutiny, particularly in relation to the results of the various studies now being completed by the Bureau of Public Roads. In addition, there is the broader question of coordinating motor carrier transport with other modes. For example, because there are economical and safety limits to motor vehicle sizes and weights, it is generally recognized that highway transport is low cost for short-haul movements but not for movements over long distances. In addition, cargoes hauled by other modes frequently move by highway at some time during the movement from their point of origin to their ultimate destination. Hence, the question of maximum permissible sizes and weights of motor vehicles no longer can be viewed as a matter arising solely within highway transport and highway finance. It must be viewed in the overall relationship of the various modes of transport to each other. In other words, the composite picture of the actions and interactions of all the modes in all areas of promotion and regulation should reflect as nearly as possible the overall public interest with respect to making needed transport service available at the lowest possible cost.

To facilitate feasible cost reductions in overall transport cargocarrying containers of highway vehicles should be standarized. The standards actually developed should permit interchangeability of containers among carriers by highway, airway, railway, and waterway. Much work already has been done toward development of such standardized containers. It appears that some progress toward that objective is being made by the American Standards Association, which has organized sectional committee MH-5 to study and recommend suitable standard sizes and methods of handling for all sizes of containers. Promulgation of such standards might be forthcoming from the American Standards Association within the next year or so.

RECOMMENDATIONS

The relationships of size and weight of motor vehicles to highway costs, and to the overall cost of transportation, necessitate specific recommendations on the subject. In the absence of specific data which should become available in the form of official reports to the Congress, some of the recommendations must be stated in the alternative.

(1) The Congress should provide a suitable highway user charge system to insure that each class of vehicles pays its proportionate share of highway costs. The owners of passenger vehicles and light trucks should not be called upon to subsidize highway costs attributable to heavy vehicles any more than the latter should be expected to subsidize the former.

(2) If the pending report of the Department of Commerce, Bureau of Public Roads, on the maximum sizes and weights of motor vehicles should recommend an increase in the single-axle maximum above 18,000 pounds, or the tandem-axle maximum above 32,000 pounds, we recommend that adoption of the suggested maximum loadings be deferred until legislative action has been taken, to insure that heavy motor vehicles pay not only for

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their equitable share of new highway facilities but also the share of the cost of improving existing highways, including bridges, attributable to accelerated need for replacement resulting from use thereof by the heavier axle loadings.

(3) If that pending report should be recommend retention of the maximum single-axle loading of 18,000 pounds and the maximum tandem-axle loadings of 32,000 pounds, Federal legislation should provide for adoption of such maximums notwithstanding the existence of State laws presently allowing heavier axle loadings. Recognizing that heavier allowable axle loadings in some States has led to private investment in motor carrier equipment based on such higher loadings, two policy alternatives should be explored. The first involves permissive continuation of the presently allowable maximum axle loadings under State law for a transitional period of not more than 5 years to permit opportunity for full use of the potential capacity of that equipment during the remainder of most, if not all, of its useful life. The second policy alternative calls for having the maximum allowable axle loadings under Federal law become effective immediately. This alternative should be followed if it should be found that monetary value of the road and bridge deterioration which would result from continued permissive operation of the heavy vehicles under State law, during the transitional period, is greater than the loss suffered by them resulting from operations under the reduced axle weight limits. In this event, accelerated amortization should be allowed on the oversized equipment legally in use at the time restrictions become effective.

(4) Maximum allowable axle loadings should be rigidly enforced. In view of the capability of American technology to develop new equipment to meet new situations, exceptions to those loadings should be expressly prohibited. Penalties for violations should be adequate to deter.

(5) Increased Federal leadership should be provided to stimulate and encourage the actions underway toward adoption of standardized containers. Appropriate legislative or executive action should provide, for example, that where appropriate to the shipment and all other factors are equal, the Federal Government will favor those carriers who will move goods shipped under Government bill of lading in a standardized vehicle or container.

CHAPTER 9. PIGGYBACK AND CONTAINERIZATION

In transportation circles "piggyback" is the generally accepted nickname for the movement of loaded or empty highway trailers on railroad flatcars. Another designation is "trailer on flat car" (TOFC). Other terms such as "fishyback" and "birdieback" are used to describe the movement of trailers or containers by water and air carriers, respectively.25

In this chapter policy considerations affecting piggyback apply equally to containerization as this more advanced tool of coordination and economy comes into wider use. Similarly, policy applicable to piggyback applies in general to trailers and/or containers carried in or on vehicles of other modes.

1. Background

(a) The need for coordination.-The need for physical coordination between segments of our national transportation system has long been recognized. The national transportation policy states that an aim of the Interstate Commerce Act is to bring about the "developing, coordinating, and preserving a national transportation system by water, highway, and rail, as well as other means ***" 26 [Emphasis added.]

Perhaps the most significant failure in achieving the congressional goals has occurred in the area of intermodal coordination. As far back as 1906, by passage of the Hepburn Act, the Congress recognized the vital importance of coordination between carriers. That act provided that it was the duty of carriers subject to the act to establish through routes and just and reasonable rates applicable thereto. The act gave power to the Interstate Commerce Commission to bring this objective about, but it so hedged the power with reservations that the Commission could not effectively carry out the congressional mandate. Since 1920, the Commission may require that one carrier permit the use of its terminal facilities by another carrier under defined circumstances. Today, section 15 (3) of the Interstate Commerce Act provides that the Commission may require the establishment of through routes and joint rates between rail and water carriers, but section 15(4) restricts considerably the Commission's power to establish through routes, as we explained more fully in part IV, chapter 2 of this report. Only motor carriers which are common carriers of passengers have the duty of establishing reasonable through routes with other passenger common carriers and to establish just and reasonable joint rates with them. The end result of all this is that, although coordination has been regarded as vital for well over half a century, most joint rates are still the result of voluntary agreements between carriers and very little coordination exists except between railroad carriers.

Finally, however, in this latter half of the 20th century, the emergence of piggyback as a popular means of moving freight which is mutually beneficial to carriers of different modes and to shippers and the public provides a tool to bring about the close coordination between modes which has been regarded as desirable and which neither legislation nor administrative action has been able to achieve since 1906.

(b) Piggyback-No recent innovation. There is little new in the concept of piggyback. As far back as 1843 sectionalized canal boats. were transported by rail in Pennsylvania as part of a combined waterrail service and in 1885 so-called "farmer's trains" hauled loaded produce wagons (and teams) from Long Island points to the East River. Freight laden highway trailers have been transported on flatcars since 1926. During the 1930's and 1940's, piggyback service was conducted at various times by several railroads, with varying degrees of

success.

The railroads experimented with several rate bases for the early container service. They discovered that rates on a per-mile basis,

6 54 Stat. 899; 49 U.S.C., preceding secs. 1, 301, 901, and 1001.

with a maximum charge per container, was the most practical basis. This basis of ratemaking was drawn into litigation before the ICC, whose decision in 1931 prescribed a new formula based upon classification of the freight in containers. Shippers did not demand container service on the basis prescribed, and this resulted in the end of the container service for that era.

The decision above referenced is No. 21723, In the Matter of Container Service, decided April 14, 1931.27 A pertinent part of this decision is quoted:

The proposed rates, moreover, cannot be approved because they are or would be unjustly discriminatory or unduly prejudiced * * We need only add that as we interpret section 2 of the act, and as it has been interpreted by the Supreme Court, we cannot approve varying rates based on the weight of the lading offered for container shipments except upon a record which established that charges so determined are warranted by differences in the cost and quality of the service * * Necessarily if container service is to be conducted at one rate for the entire container content, some disruption in present relations will have to take place, but the fact that the service is new and different from that heretofore rendered, or recommends itself as effective in meeting truck competition, is not sufficient reason for disregarding this portion of the law

It is interesting to note that economy was denied in favor of compliance with rate tradition. Cost related ratemaking, had it been our policy, would have fostered this progressive step in 1931.

2. New phase begins in 1936

In No. 4186-Trucks on Flatcars Between Chicago and Twin Cities, decided on June 20, 1936, under a tariff which became effective in July 1936, the Great Western began transporting highway_trailers between Chicago and St. Paul at a charge of $42.50 per loaded trailer, subject to a maximum lading of 20,000 pounds per trailer and to a minimum charge of $85 when less than two vehicles were offered for shipment in 1 day 28 They were loaded by the shippers, generally two trailers to a car. Empty returned vehicles were carried at half the foregoing charges. An additional charge was made for weight in excess of 20,000 pounds. Under this tariff the service was available to the general public. This will be referred to as open-tariff service. The Great Western's primary purpose in establishing trailer-onflatcar service was to induce its use by motor common carriers, but it was also contemplated that others might use it, including private shippers who operated their own highway vehicles and freight forwarders. In conformity with its primary purpose of attracting common-carrier vehicles, a tariff was filed, to become effective on June 8, 1936, naming joint motor-rail-motor class and commodity rates between points roughly comprising trunkline and central territories and a substantial part of Western trunkline territory. Under the joint-rate arrangement the railroad was to receive as its division the same amount per trailer as the charge previously published in its open tariff. The joint-rate tariff received the Commission's approval in Motor-Rail-Motor Traffic in East and Midwest, decided November 17, 1936,20 soon after the Motor Carrier Act, 1935 (now part II of the act) became effective.

27 173 I.C.C. 377-450.

28 216 I.C.C. 435-445.

29 219 I.C.C. 245.