Email From Linwood Laughy and Borg Hendrickson to Doral Hoff, Idaho Transportation Department
August 4, 2010
August
4, 2010 To:
Doral Hoff, Idaho Transportation Department cc: Jim
Carpenter, ITD District 2 Bryan
Ness, Director, ITD Alan
Frew, ITD C.
L. “Butch” Otter, Governor of Idaho From:
Linwood Laughy and Borg Hendrickson 5695
Highway 12, Kooskia, Idaho 83539 ITD
Alert #6 Highway Damage and the Taxpayers’ Tab The
over-legal loads planned by ConocoPhillips and Imperial Oil/ExxonMobil
Canada for transport on U.S. 12 in Idaho will predictably violate state
and federal laws designed to protect highway surfaces and bridges and
result in future increased expenditure of taxpayer money to repair the
damage caused by these transports. Highway
and Bridge Facts 1.
Highway surfaces and bridges are designed for a given life span,
typically 15 years for asphalt and 50 years for bridges. Normal wear and
tear of traffic gradually produces fatigue and failure, requiring new
public expenditures for repairs and eventual replacement. 2.
In order to protect highways and bridges, the Federal Highway
Administration has adopted limits applying to all Federal highways that
address tire load, axle load, and total load on U.S. highways: a.
tire load - 600
lb. per inch of tire width b.
axle load - 20,000
lb. per axle c.
total load - 160,000
lb. 3.
While tire loads impact small areas of road surface, axle loads are
critical to larger areas of road surface, subsurface, and to bridge
fatigue and damage. Further, as clearly stated in a Washington State
Department of Highways 2006 briefing paper entitled Legal Load
Limits, Overweight Loads and Pavements and Bridges, “The
relationship between axle weight and pavement damage is not linear, but
exponential. A single axle loaded to 40,000 lbs (twice the legal load)
causes 16 times more damage than a single axle legally loaded to 20,000
lbs.” 4.
As recently pointed out to members of Governor Otter’s 15-member task
force investigating the funding of Idaho’s highway infrastructure, one
fully loaded axle on a big truck is equal to the pavement damage of
10,000 passenger cars. Any claim to the contrary, according to Batelle
Group consultant Patrick Balducci, would contradict “50 years of
research of the Federal Highway Administration.” In
summary, then, if tire, axle, and total load limits are adhered to, the
public can expect regular maintenance costs to keep the public and
commerce moving efficiently on state and federal highways. Overloading
highways and bridges causes much greater maintenance and replacement
costs and more disruption of both private and commercial travel. The
ConocoPhillips and Imperial Oil/ExxonMobil Canada Planned Shipments 1.
The engineering drawings provided in both of the above corporations’
transportation plans submitted to ITD indicate tire pressure loads
generally in the 500-600 lbs/inch range, thus leading to the oft-touted
IO/EM claim that their loads will be no more damaging to the highway
than a logging truck. 2.
The listed axle weights for both corporations far exceed the State of
Idaho’s legal loads of 20,100 lbs per axle. The IO/EM axle weights are
listed at 36,990 pounds. ConocoPhillips lists axle weights
for their Goldhoffer trailers at 36,491 lbs and for their
6-dolly transporter at 38,172 lbs. These axle weights will
predictably cause damage to road surface and substructure at least ten
times greater than a normal axle load. 3.
The overweight limit used by ITD for Western Regional overweight permits
is the Federal Highway Administration limit of 160,000 lbs. Total weight
for the I0/EM loads is 517,866 for the load and trailer alone, or
655,866 lbs for the load plus trailer plus pull and push tractors. The
CP total weight for their lighter loads is 493,892 lbs, for their
heavier loads from 646,204 – 675,500 lbs. These weights far exceed the
160,000 lbs maximum legal weight. 4.
Referring to the report to the governor’s task force as noted in #4
above, legal axle loads of 20,000 lbs per axle cause the same road
impact on the highway as 10,000 cars. ConocoPhillips configurations
indicate use of from 15-18 axles per load, the vast majority of which
are in the 36,000 to 38,000 lbs per axle range. At a legal axle limit of
20,000 lbs, a single CP shipment’s impact on the
highway would be equivalent to that of from 150,000 to 180,000 cars.
However, as explained above, because of axle weights far exceeding the
legal limit, the highway wear of a single CP load will be at least ten
times greater, or equal to 1,500,000- 1,800,000 cars according to 50
years of research by the Federal Highway Administration. The IO/EM
shipments involve 20 axles per load. Each IO/EM shipment will thus cause
wear equivalent to that of 200,000 cars. The 207 IO/EM shipments will
thus predictably provide the equivalent wear and tear on U.S. 12 as that
of approximately 35-40 million automobiles. These
calculations do not address the structural stress these shipments will
place on bridges and unstable road shoulders. As we explained
in our ITD Alert #5, miles of unstable shoulders exist on U.S. 12, many
within a few feet of the Clearwater and Lochsa Rivers. According
to the Washington State Department of Transportation briefing report on
overweight loads cited above, “Tire
and axle limits are imposed for a number of reasons; foremost is to
ensure that loads carried by trucks are transported safely. Having
defined load limits allows engineers to design pavements that will hold
up under anticipated truck traffic with minimal maintenance required for
fixing cracks, ruts, and potholes. Load limits are also necessary for
protecting bridges from structural weakening or fatigue, preventing
unsafe conditions and early replacement of bridge structures. Current
information shows that even slight changes in load limits have major
impacts on pavement and bridge performance.” (emphasis added) Imperial
Oil/ExxonMobilCanada has publicly stated they will pay for any damage
they cause to the highway. While this may be true in the case of
immediately obvious damage, such as the collapse of a bridge, much of
the fatigue and wear of over-legal loads occurs over time. As ITD’s
recent pilot project on granting permits for over-legal loads of from
105,500 lbs-129,000 lbs concluded, it is impossible to determine
responsibility for the increased wear on the roadway caused by such
over-legal loads. Taxpayers, in other words, will pay the long-term tab
and, in effect, subsidize the industrial shipments of giant
international corporations. ITD
regulations state the following: “The primary concerns of the
Department, in the issuance of over-legal permits, shall be the safety
and convenience of the general public and the preservation of the
highway system.” We
find it difficult to believe ITD is not aware of Federal Highway
Administration information and related professional literature on damage
to highways and bridges of over-legal loads. We find highly problematic
the fact that ITD would even consider the permitting of transports
weighing from 493,892- 675,500 lbs for travel on U. S. 12. We
have previously addressed the issues of public safety and convenience.
This alert speaks to the preservation of the highway system and to
implications of accelerated and unfair costs to taxpayers. If ITD
follows its own regulations, no permits will be issued for the transport
of these loads of illegal and unprecedented weight on U. S. 12 in Idaho. Further,
if Governor Otter cares about the quality of Idaho’s transportation
system and the future expenditure of taxpayer money in support of that
system, he will ensure that ITD does not issue any such permits. |