Old Topic-New Confusion - Length Limits

In the process of working with a 'Finish Builder' on a truck's fitting-design, I ran into a question that I thought would be 'simple', that has turned into a real 'interpretation' nightmare. Wondered if anyone could point me to the Federal guidelines on applicable length limits, and possibly state limits as well.

In Canada, a truck like I am having built would be called a 'Truck with Pony Trailer' combination (Category 6). The tractor is a tandem (Cummins, 18-speed, etc.), with a 34-ft frame (straight body cab-on-frame). It's getting a 115-sleeper, but behind the sleeper, it's getting a 20-ton knuckleboom crane. From the back of the crane (in stowed position), it has an 8' x 8' 'flatbed' (actually, has 2-ft steel siderails). At the rear, is an 80k pintle. Most in the Southern U.S. would see this as a 'class 8 dump truck config', without the dump bed. The truck, itself, will not be hauling freight (the 8-ft rear bed is for chain, cable, rigging, tools, compressors, etc.), but the pintle will be potentially pulling freight 'for-hire' (and this is a CMV). Again, in Canada, there is a category set aside for this type of truck, with length and weight limits. In the U.S., however, I can't find where it fits into FMV law. Does this fit the definition of a 'Tractor-semi-trailer', is this restrained by the 28-ft trailer maximum or can it pull a full 40-ft trailer, etc.? In Canada you get a pretty-decent Category 6 length allocation of 12.5m trailer (40-ft, pintle to rear dim), total box length of 20m (65-ft) and an overall max combined length of 23m (75-ft) and a Gross Weight of 90,000 lbs. Europe also has the 'Maxi-Cube' that is a similar configuration with slightly different numbers. The U.S. has NOTHING on this kind of configuration that I can find.
Anyone have ANY IDEA how U.S. DOT would look at a 'crane truck' pulling a pintle heavy-flatbed, and how they would assess lengths on this? Any info would be greatly appreciated on state and federal limits.

 

See, right from the start, this is where it breaks down. The truck (primary mover) is 34-feet (408-inches), and for all purposes, is a Class 8 trailer truck tractor with a rather long frame (air brakes, tandems, 115-inch sleeper, etc.) You could put a fifth wheel on it and call it done, or drop a hydraulic box on it and call it a 'heavy dump truck'. It (the base truck) is a 'cab-on-chassis' for a builder to finish out.

I'm American, not Canadian (but have worked a lot both there and here), that's why I know of their Category 6 classification for 'Truck and Pony Trailer'. I guess the only thing seen in America like this configuration (and why I'm having it built) is if a mobile truck-crane type-truck was pintle-connected to a flatbed trailer, and pulled it behind him. (In effect, what I am doing, as the truck itself will NOT carry cargo, the trailer behind it will, the truck is just a work platform).

Lets go with 'I'm going to tag this truck in, say, Texas', the base question starts with is 'is this a Crane, a Semi, or a Box?' In reality, the more I think about it writing this, TECHNICALLY, it is a SEMI's TRACTOR, because it relies on the trailer SOME OF THE TIME. See, as a crane truck, it can go to a site and work lifting and loading OTHER trucks without needing to carry cargo. On the other hand, it can either bring a trailer, or connect to a converter dolly and PULL a trailer (up to about 35-ft before length becomes an issue - then again, why pull a converter dolly, reducing your payload?)

As for the crane, it's a knuckle-boom (check out a Hiab or Effer to see what these look like), and folds up in a profile smaller than the back of the sleeper, once you park it perpendicular to the truck frame. Very nice, when a crane can only tie up 4-feet of your frame length, but lift 20-tons! As for the outriggers, they also tuck INSIDE the profile and sides of the truck, no more present than an average fuel tank.

See...the bottom line comes to, is it a semi tractor, where I have one set of lengths and weights, or is it a straight-body/dump truck/van body, where I have another set of lengths and weights? The reason I mentioned Canada to start with, is they have a Category for this truck and know what it is, and it has ample length and weight limits within the category. The U.S. doesn't define it at all, which means DOT harassment on lengths and weights, unless I can find a solid leg to stand on here.
Making me move to Canada just to tag my new truck (worth more than my house and all other belongings) is ridiculous.

 

Yeah, there is that #### detestable thing that it seems we are going to inherit from the European continent...that I am SO TRYING TO AVOID being classified as, and here's why. In Europe, that thing is a mail truck, a grocery truck, not a heavy utility truck. In my application, the U.S. lengths are going to annihilate me! If I can only have 60-feet of 'box', fine, but when I can only have 65-feet of TRUCK? My God, the truck alone (not counting the pintle or tongue, per their specs) is 34-feet! That only leaves me with a 31-foot trailer!

Ok, back after 4-hours of printing out the Canada MOU (note on length and weight laws) and the US Fed Laws, and comparing them, I still think I'm screwed on the U.S. length laws, but NOT SURE (trying my damnedest to make this thing 'cross-border' legal).

Ok, in Canada, this thing is a 'Truck with Pony Trailer' (Category 6), which must be less than 23-meters long and less than 20-meters of box (total), and less than 12.5 meters of tag-trailer. This value COUNTS the tongue in that 12.5 meters, though. Allowable GVWR is about 90k pounds, so good there. All the Canadian dimensions allow me to have a 40-ft trailer, a 75-ft truck (combined length, counting trailer tongue), hauling 90k max, no extra permits (5-axle setup, and hitch is rated appropriately).

In the U.S., the 'Maxi-Cube' is shorting me 10-feet of length off the Canadian specs on the 'Max Truck Length' (combined) at 65-feet max-total, though the trailer and combined 'box' lengths account to about the same numbers. In effect, the U.S. numbers work, ONLY if the truck is COE. ####, ####, ####.

Ok, so, let me look at this a DIFFERENT way...what in the U.S. says that the configuration I'm describing wouldn't qualify to be a 'Tractor-Trailer'?

See, in the U.S. Federal Regs link you sent, this is the summary (and VERY confusing) quote, right below the figure 2 picture of a conventional semi-trailer:

"A truck tractor is defined as a non-cargo-carrying power unit used in combination with a semitrailer. (ok, I qualify for this, so far) A truck that carries cargo on the same chassis as the power unit and cab, commonly known as a straight truck, is not subject to Federal regulations, but is subject only to State provisions.(ok, so per this sentence, I'm not running a 'straight truck'). Likewise a straight truck towing a trailer or semitrailer is subject only to State vehicle length regulation, except that the total length of its two cargo-carrying units may not exceed a federally established limit of 65 feet.(so, if you are driving a straight truck, you get hit with that same #### 65-foot limit as the maxi-cube does!) (See discussion of ISTEA "Freeze," on page 13.) The only instances where Federal regulations apply to a combination vehicle composed of a truck carrying cargo involve dromedaries, maxi-cube vehicles, and automobile and boat transporters, discussed later in this document."

Ok, so I guess I need to back up a LOT and ask a really stupid question...

WHAT IS THE DEFINITION (Legal) OF WHAT MAKES A TRUCK-TRACTOR, and WHAT MAKES IT A TRUCK-SEMI-TRAILER (Legal)? If it is not based on the hitch-method, then a Kenworth Class 8 is a Kenworth Class 8, but if the Truck-Tractor is defined by fifth-wheel-hitch vs 'non-truck-tractors' being 'other means', then I have a problem.

Ok, maybe I've talked myself into what I need to find out, and can somewhat rephrase the question with, 'what in U.S. Federal Regulations legally defines a 'Truck-Tractor-Semi-Trailer'? My aim is to claim this truck as a 'tractor' and with trailer (pintle-mounted) as a 'Truck-Semi-Trailer'. If I can't, I'll have to get with the builder and TOTALLY rework that last 8-ft of frame, to drop my 'gear box' off the top, put a plate on there, and OMG, figure out where I'm going to 'side box' all that crane rigging equipment!

 

Ok, for any that were in this thread, or that may find it later, I did find the answer on what Federal Regulations might apply here. The following is information from NHTSA, with my own take from what was said:

NHTSA clarifies the definition of 'what a truck-tractor' versus 'straight truck' is when they declare under 49 CFR part 571.3 the following:

“Truck Tractor means a truck designed primarily for drawing other motor vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn.” (Note: Trucks, such as ‘pickups’, ‘one ton dually’ etc., even though they may be capable of transporting cargo other than just a trailer, are considered to be a truck tractor when towing a trailer where a portion of the trailer load is supported and transported by the truck.)"

This is taken from guidelines issued in August of 2001 and refer to the Chief Counsel for the NHTSA.

Hot-shot drivers have asked for this clarification, relative to length limits when it comes to trucks and what defines a 'semi' versus a 'straight truck' (semis have no length limit federally, while straight trucks are limited by a total of no more than 65-feet of overall length).

My take-away of this (and the same understanding that Hot Shot drivers in the U.S. take from it, as well), is that if the truck, IN ANY WAY, is capable of carrying cargo at any location on the frame, then it is a straight-truck; but if the body is so built-or-designed that there is NO WAY to carry cargo, then it is a semi. Therefore, a 'hot shot' 1-ton truck (or larger) whose bed is configured to accept only a 5th wheel plate, or a larger-class truck configured so that there is no accomodation to legally place freight IN ANY WAY on the frame is therefore ruled a 'semi' for length limits (though still controlled through rated GVWR ratings for that specific vehicle or multi-vehicle assembly).

So, if you are a hot-shot driver (or building a truck like I am, described above), then to have ANY PLACE on the frame that can take cargo (POTENTIALLY), you have a straight-truck. (This means a gooseneck ball in your truck bed, an RV fifth wheel plate in your truck bed, or a flat bed Class 5 thru 8 truck with a pintle mount), then YOU HAVE A STRAIGHT TRUCK! If you have a 1-ton pickup, take the bed off, bolt on a fifth wheel plate, or if you build a straight truck that has NO BED (say, sleeper, crane, and giant tool box all the way to the end of the frame) and have a pintle at the end of the frame with trailer attached), then you are classified by NHTSA as a SEMI (that's right, a 1-ton semi with unlimited length)!

Looks like my open '8-ft box' behind the crane is about to be changed to a custom-fabbed 8' x 8' tool box with slide out cabinets that can be used to carry rigging and attachments, instead of it being simply an 'open box'. This did, however, clarify everything - and I wanted to share this with anyone who later-considered such a custom truck.

FYI, this is still a vehicle that, in Canada, could be presumed to be either a 'Truck and Pony Trailer' or a 'Semi', and neither way do I get a benefit beyond 75-ft long, however I do pick up additional GVWR declaring it a 'semi and trailer' vs a 'truck and pony' (up to the rated equipment's factory GVWR rating) by going 'semi'.

Hope this helps someone in the future...