The National Tank Truck Carriers, Inc. seeks a 10% axle-weight tolerance for commercial motor vehicles transporting dry bulk cargo (plastic pellets, corn kernels, flour, etc.). This would allow axles to hold an additional 3,400 lbs. for a total of 37,400 lbs. but would not change the maximum total weight for the CMV.

Due to these cargoes' size and structure, they shift during transport, disproportionately collecting in the front portion of the tank trailer. This happens because physical forces on the truck push the cargo as a whole towards the front of the trailer while the driver is braking. Small, individual units of the dry bulk cargo collect in the front of the trailer. This increases the axle-weights for the front of the CMV while decreasing the weight for the rear. The light physical forces that push towards the rear while the truck is in motion do not compensate for the greater forces during the short times while the truck is braking.

When dry bulk collects in the front of a trailer, drivers can take steps to smooth out the weight across axles while waiting for roadside inspection or to be weighed. They do so by allowing the vehicle to move forward a very short distance and then immediately hard braking. The resultant force redistributes the load more evenly across axles. Unfortunately, it can also result in slow speed collisions with other CMVs waiting for inspection. Hard braking also wears out brakes more quickly than proper operation.

- NTTC does not seek to increase the maximum total laden weight
- NTTC does not seek to increase bridge formulas or any exemptions that would allow higher axle weights for traveling across bridges.

NTTC asks that CVSA either endorse or choose not to engage on our request on this issue.