Semi truck registered as a motorhome

I have an 88 cabover can I put rv plates on it to pull gooseneck camper trailer no commercial use

 

In my state it's easy to title a commercial truck as an RV. it has to have a bed a sink and a toilet. Not sure how you would accomplish the sink and toilet in a cabover tho? They also warned me that if I did Title as RV that it can't be switched back to commercial vehicle . The rules seem to vary state by state .You need to contact your state for the qualifications.

 

I'm in a similar situation and can't get solid answers in writing from any authorities. I have been running my personally owned and operated 2008 F450 for years pulling my 40ft gooseneck race car box/toy hauler conversion (15k gvwr) and my gooseneck flatbed (25k gvwr) for several years and I have never been stopped. In Maryland my 25k gooseneck flatbed is registered as a freight trailer because it is over 20k gvwr. I have non-restricted class-A CDL.

Below is some painful dialog with an online IFTA "expert" channel that I have recently had relating to my Pete 579 that I recently purchased to complement my F450 personal use case:
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Me 2 days ago:
Hello. I live and work full time as an engineer for the DoD in Maryland. I am not a trucker nor do I own a business or have any revenue associated with my vehicles or other personally owned equipment. I do have a class-A CDL for hauling my gooseneck toy hauler and gooseneck flatbed around with my F450 for moving my privately owned toys and equipment between my primary home in Maryland and a second home (log cabin) project that I have been working on for years in Virginia. I recently bought a mini excavator to work on my private property and needed a larger rig to haul it with the same gooseneck trailer so instead of getting a larger medium class truck, for a fraction of the cost I recently purchased a heavy class 8 sleeper road tractor rig and have it insured through Progressive Commercial for personal non-business use only. I am not a commercial motor carrier nor am I associated with any form of business so I do not have a DOT number. After 3 hours of discussion the MVA representatives issued me standard MD class-F license plates for a class-8 road tractor but said that I couldn't cross state lines with a trailer in tow without risking fines which I think is incorrect. I understand that Maryland and many states have provisions for registering heavy rigs (having factory sleepers) as class-A motorhomes because they have at least 4 out of 6 RV living provisions that also technically meet the DOT’s definition for a motor home RV and exempt from DOT, IRP, and possibly IFTA. Reference 49 CFR 571.3 - Definitions. It is worth noting that, given the low miles that I put on my truck, it would actually be cheaper for me to have apportioned plates under IRP but you need to be a company (business) and have a DOT number to enter into IRP. If I were to set up an LLC to operate or qualify under IRP the business would be flagged as a hobby by the IRS because there would be no revenue associated with the business and the insurance cost would be 10 times more. So the question is do personally owned and personally utilized heavy rigs require IFTA? From everything that I have researched and been told a DOT number and IRP are not applicable to my personal use case. So many people loosely conflate heavy rigs as commercial when they are not commercial unless they are used in a commercial enterprise and/or owned by a company. I should not have to register my rig as an RV to cross state lines because I am not involved in any commercial enterprise or activity. Thanks

IFTA "Expert" channel 1 day ago
Hey! Thanks for watching and great question! I understand how all of this can be a bit tricky. If your vehicle's gross weight is over 26k pounds and you’re crossing state lines with base plates, you’ll need to get temporary trip and fuel permits. If you’re going to be crossing state lines regularly, you’ll need to establish an IFTA and IRP account with your base jurisdiction. I hope this helps!

Me 1 day ago
Ok thanks, I may be getting closer to an answer. The NMCSA site indicates that I don't qualify for a DOT number or require one because I am not involved in interstate commerce or business. Same for IRP. My employer EIN is the DoD which has nothing to do with with my personal vehicles. If I could register with IRP privately I would so it looks like short term permits are the only available options, absent titling and registering my rig as a motor home.

You do understand that commerce is defined as "the conduct of trade among economic agents referring to exchange of goods, services, or something of value between businesses or entities." Me hauling my personal junk around in a privately owned rig doesn't constitute commerce - right? Thanks and sorry for my frustration.

Me 1 day ago
I got hold of a Maryland IFTA application and it requires a Maryland business, DOT number, and IRP account. Permits that I found online for Virginia require a business or company name and DOT number at a minimum. I called Maryland IFTA and they said that I can't apply for an IFTA license because I don't have a business or DOT number and thus isn't required because I don't qualify. From what I have researched thus far none of this is required unless I am for higher or involved in a business activity, which I am not. I don't need operating authority to operate or haul my own private property in my personally owned rig, nor am I subject to DOT spot vehicle inspection like commercially registered DOT vehicles are. I do need annual inspection and have to go through scales and keep paper logs. A private non-commercial non-DOT rig can't be taken out of commercial service if it never was in commercial service.
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But wait - here's more discussion I had with an experienced online trucker channel:
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Me 2 weeks ago
I have a few unusual questions that you might know the the answers to. I recently picked up a late model cream puff Peterbilt 579 at auction. I was able to attain private use (not for higher) commercial insurance on this truck. The plan is to pull my own race car trailer or gooseneck flatbed when I need to move my excavator to other property that I own. My hope is that I can avoid having to get a DOT number, IRP and IFTA. eLog is another requirement that I feel I should be exempt from but some friends have told me that I will have to have an eLog installed. I have an unrestricted class-A CDL and work full time as a engineer. I do not have a business nor am I involved in commerce but fear that the public servants at my local DMV are going to try and pin that mess on me regardless. The DOT CDL manual that I have more or less defines commerce as hauling anything around in a commercial motor vehicle, either intrastate or interstate, and doesn't mention private or for higher use of the commercial motor vehicle. The DMV tried to pin me with apportion plates when I registered my F450 but I convinced them otherwise during that effort. Any comments or wisdom would be helpful. Thanks

Trucking channel 2 weeks ago
I would try to plate the truck with non commercial plates since it's not for commercial use. Motor homes of the same weight plate privately all the time. I'm sure it will be a bit of a struggle and the local DOT won't like it. How far away is your second property? If it's less than 100 miles away, you won't need a log book even if plated commercially, just a vehicle inspection book.

Me 2 weeks ago
Will do. Thanks for that info. It helps clarify things. My other property is 75 miles away but I will periodically stray out to my cousins place about 150 miles out so I will plan to keep a paper log. I assume that a paper log should be sufficient if I'm private use and not for hire and can show I work full time elsewhere.

Me 1 day ago
Here's my latest update with some info that might be helpful to others. Forgive me for rambling but her's where I'm currently at: As anticipated the public servants at my local MVA (Maryland) are lacking competence regarding what commerce is and how it relates to vehicle use, registration, and insurance. It took me almost 4 hours and the MVA reps making several phone calls to their main office before they finally gave up on trying to stick me with apportioned plates under IRP. The most accurate definition I can find online for commerce is: "Commerce is the conduct of trade among economic agents. Generally, commerce refers to the exchange of goods, services or something of value, between businesses or entities."

To get my truck home from Indianapolis I accepted Maryland class-F tags (for combination heavy truck tractor applications) but they said that I would have to stay inside Maryland if I pull anything or be subject to fines. I think they are only half right on that assertion because I would not be engaged in business or commerce. Moving ones privately owned stuff around in a privately owned rig is not commerce because there is no trade or exchange taking place, nor is any revenue involved. Regardless of state lines. I'm sure that I will need to make my case to DOT officer or a judge someday.

As an example, my position is that when I purchased my excavator online that constituted an eCommerce transaction or electronic Business to Customer (B2C) transaction for exchange of goods. That transaction was closed when the CFO of the business signed the invoice as paid in full. After that the excavator is my personal property sitting at their out of state location and me going to pick up my personally owned equipment with my personally owned rig is not commerce, it is me moving my own private stuff unrelated to a business (ie. there is no revenue associated with me hauling my own junk around). If I paid a motor carrier to haul my excavator home than that involves commerce for the exchange of services and has revenue associated with it...at lease that would be my position in front of a judge.

Also worth mentioning is that I have my class-F tags registered at a GCWR of 54k because I removed the class-8 hitch and replaced it with a class 6 gooseneck ball hitch to pull my gooseneck trailers with. The maximum vertical pin load for the ball hitch and coupler is 10k so as configured the combination weight rating remains well below the federal heavy highway use tax that starts at 55k. My gooseneck flatbed is rated at 25k GVWR having two 10k axles but if I put 10k on the pin it really can be used as a 30k GVWR trailer...a bit much for my F450 but no problem for my Pete 579. The base frame on my manufacture's late model gooseneck trailers is designed for 30k to 40k depending on the gooseneck coupler insert and what axles they put under them.
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Clear as mud? I'm going to roll with my class-F registration for now. I may have to make my case to a judge at some point.

 

Is it just as expensive to register or insure a semi as a rv? I didn't know one could do this. I'm very interested!

 

As long as your not for hire you should not have a problem.

 

No I pay $1100 for a year on mine and it is high because of the additional coverage I added.

 

My yearly premium with Progressive Commercial for non-business personal use of my 2016 Pete 579 and 2019 Diamond C (25k) trailer combination is $1550 for 100 mile (average) radius. That includes $50k of collision for the Pete 579 and $500k/$500k liability and $500 deductible. The trailer contributed a whopping $18 to the total. When I inquired about adding my 40ft Pace American race car/toy hauler trailer they had to define it as a cargo trailer in their commercial system and the quote on that addition was $140.

I still use my F450 for lite medium duty so two of my trailers will be double insured at some point because in Maryland any trailers over 10k GVWR have to be insured and tied to the power unit policy.

Here's a link relating to DOT motorhome definitions.
https://www.govinfo.gov/content/pkg/CFR-2010-title49-vol6/pdf/CFR-2010-title49-vol6-sec571-3.pdf

Side note. The DOT really should start a tailored pilot program to better enable personal use operators and commercial (for higher) hot-shot carriers a sanctioned means to derate class-8 rigs that have been decommissioned and auctioned off (when their warranty runs out) by major commercial carriers. I see so many commercial hot-shot operators pushing their rigs to the max when they would be much better off with a full size sleeper rig when pulling medium weight loads between 30k and 45k. Many late model class-8 rigs have extremely efficient power-trains and can get around 10mpg pulling medium loads. Most important to me as an engineer and private operator is the service brake margin and engine braking margin is 10 times what my F450 has to offer. In a panic situation too many (tail wagging the dog) hot-shot rigs are running dangerous combinations. My used cream puff 2016 Pete cost less than $20k and a new F550 costs nearly $100k for a fraction of the capability and the fuel mileage pulling hills loaded is actually worse with the F550.
Electronic Code of Federal Regulations (eCFR)

 

Regarding IFTA, I managed to email and speak to the Assistant Director of the Field Enforcement Division for the Comptroller of Maryland (very smart and helpful guy). Below is a quote from his first email for reference.
"Personal ownership is not a factor in determining whether or not a qualified commercial motor vehicle requires an IFTA license and decals, or, a valid trip permit.

Basically, if a CMV has two axles and an operating or registered gross vehicle weight that exceeds 26K pounds, and it travels interjurisdictionally, the requirement is met. A three axle vehicle qualifies regardless of weight, and farm trucks are exempt unless the GVW exceeds 40K pounds.

There are a few other exceptions.

Probably best to give me a call when convenient for you , and we can further discuss your concerns."

After a fairly long phone discussion and several follow-up emails below is a quote from my concluding email.
"It turns out the online chat that I had yesterday with FMCSA must have been an automated chat bot because it was incorrect regarding it being possible to apply for a DOT number without being affiliated in a business. The NMCSA's Unified Registration System (USDOT application pages) require an established legal business and all the identifiers associated with it. So MDOT for intrastate in Maryland or USDOT and IRP for interstate hauling are not possible without an established legal business (commercial enterprise activity).

So technically it looks like the only thing I need for personally owned and used heavy hauling across state lines is a fuel permit but I'm gong to get both IRP and fuel permits just to cover my myself in the event I encounter an aggressive DOT guy."

Though RV's are exempt from IFTA and IRP, I would rather keep my generic Maryland class-F (Truck Tractor) registration and pay for out of state trip permits as needed because it allows me to pull my flatbed and personal equipment around without risking getting nailed for improper registration. If I were to re-title and register my truck as a Maryland class-M (multipurpose vehicle) class-A RV I believe the probability is high that I could be ticketed for improper registration if I was pulling my flatbed hauling personal equipment.

When registering as a class-M in Maryland the GCWR field is left blank and this could be a problem when pulling my flatbed because it is classified as a freight trailer in Maryland because it's GVWR is over 20k which zero's out the weights fields on the trailers registration and I believe the power unit pulling it needs to have a defined GCWR that can handle the trailer for the combination to be legal from a registration standpoint.