INTERREGIONAL TRUCK OPERATIONS ON I-5 AND SR 99 AND STAA ROUTES IMPROVEMENT STUDY

The Tioga Group, Inc. Dowling Associates Inc. (Kittelson Inc.) ♦ IGIS Inc. ♦ Iteris Inc. ♦ Jock O’Connell Prepared for: Sacramento Area Council of Governments San Joaquin Council of Governments

Draft Revised - April 2013

The Tioga Group, Inc.  288 Rheem Blvd.  Moraga, CA 94556  Phone 925.631.0742  Fax 925.631.7936

Note: Information and data contained in this document are for planning study purposes only. The Study team worked collaboratively with stakeholders to identify STAA routes and operational procedures from all stakeholder perspectives. This study is not intended to be used as a reference document for Federal, State or local STAA route rules, regulations, or definitions. Rather, this Study and the conclusions and recommendations contained within are intended to assist regional and local planners and policy makers to develop new tools and processes to more comprehensively plan and prepare for future interregional truck operations in the Study area.

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Contents EXECUTIVE SUMMARY 1 Background 1 Conclusions 1 Alternatives 3 Recommendation 4 I. INTRODUCTION 6 Background 6 Scope 7 Approach 7 II. STAA ROUTE DESIGNATION 9 Legislative Framework 9 Basis for Control of STAA Routes 12 STAA Route Designation Process 13 State Level, Caltrans 13 County Level 15 Municipal Level 16 Designation Criteria 17 Signage 20 Non-STAA Truck Routes 22 III. STAA ROUTES AND FUTURE NEEDS 23 STAA Route Maps 23 STAA Terminal Routes 24 Interchange Issues 30 Mapping Issues 30 Current STAA Routes and Access Needs 31 Future Needs 39 IV. STAA VEHICLE OPERATIONS 46 Overview 46 Customer and Trucker Preferences for STAA Trailers 46 STAA Vehicle Registration 49 Locations of the STAA fleet 49 Driver Route Choice 51 STAA Truck Operating Data 52 V. STAA ENFORCEMENT 58 The Enforcement Challenge 58 Enforcement Practices 58 Enforcement Options 59 VI. STAKEHOLDERS AND PERSPECTIVES 60 Interviews 60 Trucking Companies 60 Support Service Providers 62

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Trucking Industry Associations 63 Shippers and Receivers 64 Departments of Transportation and Motor Vehicles 65 Trade and Business Organizations 65 Municipalities 65 Sacramento County Local Agencies 65 San Joaquin County Local Agencies 66 Industrial Real Estate Developers 67 Truck Routing Software Providers 68 Other constituencies 69 VRPA’s companion project 69 VII. POTENTIAL IMPROVEMENT PROJECTS 70 Background 70 Selection of Candidate Projects 70 Selected Projects 73 VIII. ROUTE AND OPERATIONAL FINDINGS 89 Overview 89 STAA Route Designation Issues 89 Problem Cases 92 Status and Signage at Freeway Interchanges 93 Terminal and Service Designations 94 Exceptions 94 Cost of Improvements 95 Commercial Considerations 95 Specifying the “last mile” 96 Service Routes and Interchange Status 96 Signage Issues 97 IX. CONCLUSIONS 99 Overall Conclusions 99 Corridor STAA Route Status 99 Corridor STAA Vehicle Operations 100 Designation Process 100 Stakeholder Perspectives 101 Signage 102 X. ALTERNATIVES AND RECOMMENDATION 103 Need for Alternatives 103 Strengthening the Current Process 103 Proactive Planning 104 Common Policy Issues 106 Recommendation 107 APPENDIX A: GLOSSARY 109 APPENDIX B: PARTIES INTERVIEWED 111 Public Agencies 111

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Trade Associations 111 Motor Carrier Trade Associations 112 Commercial Motor Carriers, California Based 112 Suppliers and Others 113 APPENDIX C: STATUS OF RAMPS AND INTERSECTING ROADWAYS AT INTERCHANGES 114 East-West Routes 114 North-South Routes 117 APPENDIX D: SUGGESTED STAA ROUTES 123

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Exhibits Exhibit 1: STAA Vehicles 1 Exhibit 2: STAA Vehicles 10 Exhibit 3: STAA Truck Dimensions 11 Exhibit 4: Turn Template Example 17 Exhibit 5: Terminal and Service Route Signage 21 Exhibit 6: Advisory Route Signage 22 Exhibit 7: Study Area STAA Terminal Access routes (April 2011) 25 Exhibit 8: STAA Terminal Access Routes – Sacramento County North (April 2011) 26 Exhibit 9: STAA Terminal Access Routes – Sacramento County South (April 2011) 27 Exhibit 10: STAA Terminal Access Routes – San Joaquin County North (April 2011) 28 Exhibit 11: STAA Terminal Access Routes – San Joaquin County South (April 2011) 29 Exhibit 12: County or City Truck-related Zoning 32 Exhibit 13: STAA routes in Woodland 32 Exhibit 14: STAA Routes in North Sacramento 33 Exhibit 15: STAA Routes in West Sacramento 34 Exhibit 16: STAA Routes in South Sacramento 35 Exhibit 17: STAA Routes in Galt 36 Exhibit 18: STAA Routes in Stockton and Central San Joaquin County 37 Exhibit 19: STAA Routes in Lathrop and Manteca 38 Exhibit 20: STAA Routes in Tracy 39 Exhibit 21: Sacramento and Yolo County Trucking Locations 40 Exhibit 22: Study Area Warehouse Locations (100,000+ square feet) 40 Exhibit 23: Study Area Retail Complex Locations (100,000+ square feet) 41 Exhibit 24: Existing and Proposed San Joaquin County Industrial and Office Developments 42 Exhibit 25: Woodland Distribution Centers 44 Exhibit 26: Sacramento County Trucking Locations 50 Exhibit 27: San Joaquin County Trucking Locations 50 Exhibit 28: Selected Yolo County Trucking Locations 51 Exhibit 29: Sacramento County STAA Vehicle Locations 54 Exhibit 30: San Joaquin County STAA Vehicle Locations 55 Exhibit 31: Central Sacramento Area STAA Vehicle Locations 56 Exhibit 32: Central Stockton Area STAA Vehicle Locations 57 Exhibit 33: Del Paso Road Project Area 74 Exhibit 34: Del Paso Road Project Area Truck Activity 74 Exhibit 35: Richard Blvd. Project Area 75

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Exhibit 36: Richard Blvd. Project Area Truck Activity 76 Exhibit 37: West Sacramento Project Area 76 Exhibit 38: West Sacramento Project Area Truck Activity 77 Exhibit 39: Mack/Elsie/Stockton Blvd. Project Area 78 Exhibit 40: Mack/Elsie/Stockton Blvd. Project Area Truck Activity 79 Exhibit 41: Twin Cities Road Project Area 79 Exhibit 42: Twin Cities Road Project Area Truck Activity 80 Exhibit 43: Liberty Road Project Area 80 Exhibit 44: Liberty Road Project Area Truck Activity 81 Exhibit 45: Turner Road Project Area 82 Exhibit 46: Turner Road Project Area Truck Activity 83 Exhibit 47: Airport Way Project Area 84 Exhibit 48: Airport Way Project Area Truck Activity 85 Exhibit 49: Austin/Moffitt/Spreckles Project Area 86 Exhibit 50: Austin/Moffitt/Spreckles Project Area Truck Activity 87 Exhibit 51: East Grant Line Project Area 88 Exhibit 52: East Grant Line Project Area Truck Activity 88

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Executive Summary

Background

The Surface Transportation Assistance Act of 1982 (STAA1) authorized motor carrier operation of 48-foot and longer semi-trailers on National Network highways. Additionally, STAA delegated to the states permitting of this class of vehicles (see Exhibit 1) on non-National Network state and local routes, subject to certain controls as administered by each state.

Thirty years later, the operation of these longer vehicles has become the norm for much of the trucking industry. This has led to a widespread need to develop safe and legal access for these vehicles for shippers, receivers, and service locations.

Exhibit 1: STAA Vehicles2

For routes outside the National Network, California employs a “designation” policy restricting STAA vehicles to “Terminal” and “Service” routes that have been designated by the California Department of Transportation (Caltrans) and along with local connecting roads, evaluated and designated by a local jurisdiction, have appropriate signage posted. This process typically relies on a bottom-up application for designation initiated at the local level. While this approach may have been workable when STAA vehicles were the exception, it has not kept pace with the influx of STAA vehicles or with the expansion of customer locations that rely on such vehicles for day- to-day goods movement needs.

Based on input from user surveys, Sacramento and San Joaquin counties appear to implement and enforce STAA requirements more rigorously compared to the rest of the state. Many of the stakeholders interviewed as part of this study perceive this level of enforcement as inconsistent with other parts of the state.

Conclusions

Local stakeholder dissatisfaction and possible lack of knowledge regarding the status, use and planning of STAA routes along the I-5 and SR-99 corridors provided the impetus for this study.

1 A glossary of relevant terms is provided in Appendix A. 2 http://www.dot.ca.gov/hq/traffops/trucks/truckmap/truck-legend.pdf

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The research team verified many of the perceived problems with STAA routes in the study area of the SACOG and SJCOG regions. Our team’s findings include:

Local/Regional Findings

 STAA routes in the study region are incomplete, disconnected, and poorly documented. This led us to conclude that the local network may be inadequate to support the region’s transportation needs.

 Municipalities and regional planners seldom take a proactive stance to have routes in their jurisdiction designated, even where roads meet STAA standards. Applicants that do seek STAA designation for specific routes are often frustrated by what they perceive as slow or arbitrary actions, and may seek intervention from elected or non-transportation officials.

State Findings

 Enforcement of STAA vehicle restrictions in the Study area is reportedly inconsistent, and is perceived by the industry as ineffective.

 The Caltrans process for STAA route designation is well organized and well documented. Caltrans offers technical and procedural guidance to local and regional applicants. The process is well understood by the Caltrans personnel involved, but it is not widely known or followed by many industry stakeholders, resulting in a serious mismatch between designated routes and long-term needs.

Universal Findings

 Knowingly or unknowingly, non-exempt STAA vehicles are frequently and widely operated on routes not designated as STAA.

 Many private industry stakeholders (truckers, customers, planners, etc.) are unaware of STAA route issues, consider them peripheral to their interests, or ignore them.

 Despite DMV Commercial Driver Handbook instructions on following STAA signage, Terminal (“T”) and Service (“S”) Route signage is perceived by the operators of STAA vehicles as no longer providing a practical approach of route designation or communication with truck drivers with the advent of handheld GPS, smart phones and software applications that provide routing instructions to drivers.

 Both restricted STAA access and perceived difficulties with designation and enforcement place the Study region at an economic disadvantage.

 Shippers, receivers, and real estate developers typically are unaware of route designation requirements or do not consider STAA access issues their responsibility. Out-of-state truckers expect to operate STAA vehicles on any route where they are not expressly prohibited by posted signs.

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 While valid and functional when followed, the current processes for designating STAA routes does not appear to be meeting the transportation needs of the SACOG and SJCOG regions. Specifically, reliance on application processes and signage to designate and mark routes does not appear to be an efficient system in an age where STAA access must become the norm for commercial, agricultural, and industrial sites. Although the STAA is the law, it may be less effective under current circumstances, possibly making the administrative and enforcement aspects more difficult for all involved.

Alternatives

This study identified two primary alternatives to current practices.

Strengthening the Current Process

If the region chooses to rely on the existing bottom-up application and designation process for STAA routes, the process could be strengthened in several ways:

Local/Regional

 Significantly more education and outreach to shippers, receivers, real estate developers, truckers, private fleet operators, municipal planners, and other stakeholders regarding STAA rules and designation processes.

 Expanded and improved signage and communications to more clearly designate STAA routes and to distinguish approved routes from routes that have been disapproved and/or not yet considered.

 Clarification and uniform interpretation of STAA route engineering and safety requirements, and of criteria for designation of Terminal and Service routes.

Universal

 Additional resources on the local, regional, and state level to facilitate the process and reduce delays.

 Development and maintenance of more effective and easier-to-use maps of current STAA routes, with on-line access and which can be linked to or embedded in industry truck routing software applications.

It is not clear, however, whether these efforts would result in significant improvement. There are thousands of shippers, receivers, service locations, and truckers who could be involved in STAA routings, and no simple or effective way to locate or reach them. There is also no guarantee that encouraging or facilitating bottom-up initiatives will yield an adequate system of STAA routes.

Proactive Planning

The potential value of a regional truck route planning and designation approach was discussed in the SACOG Phase III Goods Movement Study and is a logical alternative to either a large-scale

Tioga Page 3 permissive approach or an unsatisfactory status quo. A proactive planning approach would require cooperation between local authorities, regional planning agencies, and Caltrans to:

 Identify current and expected needs for STAA truck access.

 Determine which through-arterial routes can currently support STAA operations, and which require upgrades. Local service routes would remain a local issue.

 Designate the eligible current segments as STAA routes, and sign and/or map them as required.

 Develop and implement plans to upgrade sub-standard segments and complete a coherent STAA route network and system.

This approach would create a top-down planning process while still allowing the bottom-up application process for additions or exceptions.

A regional route planning process would require substantial time and resources. Completion of the network would require resources to upgrade routes, for which the funding could become part of metropolitan, regional, and state transportation improvement plans (MTIPs, RTIPs, and the STIP).

A particular challenge to a regional planning approach – in common with all regional planning efforts – would be reconciling the divergent and conflicting concerns of cities, counties, and other agencies and stakeholders within STAA eligibility rules. Jurisdictions and residents are concerned about legitimizing access for what they perceive as “large trucks” even when those trucks are already using the routes on an ad hoc basis.

Recommendation

The SACOG and SJCOG regions should continue to implement STAA designation as a regular part of truck route designations wherever routes meet engineering and safety criteria. An important component to this would be to work more closely with land use and transportation planning agencies to include STAA standards in planning documents. Furthermore, consistent efforts to sign local STAA-compliant routes as well as restricted routes may be. This improved signage, in combination with efforts to provide easy access to mapping across a variety of platforms, may help to alleviate some of the stakeholder issues with the STAA system documented in this study.

However, the status quo application, designation, and signage processes are increasingly unlikely to meet the region’s transportation needs in the future. Strengthening these processes will help, but may not resolve all of the issues identified in this study. STAA vehicles have become the norm throughout much of the trucking industry and the region, so it is no longer effective to treat STAA vehicles as exceptions. Instead, there is an opportunity to expand the planning process to incorporate these vehicles’ requirements. Many truck operators now operate fleets that are exclusively STAA, and it appears that the current processes for terminal access designation may need to be streamlined. Additionally, re-engineering of local roads and intersections may be required to meet the minimum design requirements necessary to accommodate these vehicles.

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Broadening STAA access can be achieved through both the “Strengthening the Current Process” and “Proactive Planning” alternatives outlined above. Strengthening the Current Process is a near-term implementable strategy, which should be followed by a Proactive Planning practice in the future. It is within the general purview of SACOG and SJCOG in partnership with the local jursidictions with the assistance of Caltrans to work towards these goals.

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I. Introduction

Background

This study was sponsored by the Sacramento Council of Governments (SACOG) and the San Joaquin Council of Government (SJCOG) using a Caltrans Discretionary Transportation Partnership Planning Grant. The genesis for the study originated from the SACOG Goods Movement Reports Phases I & II completed in 2006 and 2007 respectively, as well as discussions conducted by the San Joaquin Goods Movement Task Force (GMTF) of SJCOG. A consultant team, composed of The Tioga Group, Inc. (Tioga) in cooperation with Dowling Associates Inc. (DAI, and now a division of Kittelson Inc.), IGIS Inc., Iteris Inc., and Jock O’Connell, was selected to help carry out the project.

The federal Surface Transportation Assistance Act of 1982 (STAA) along with corresponding state and local regulations and legislation govern the operation of STAA vehicles. The STAA allowed semi-trailers 48 feet in length to operate on U.S. highways designated as the National Network (primarily interstate highways and some Federal Aid Primary Routes). The STAA legislation conceived of an integrated trucking system, with the 48-foot and over trailers primarily serving to move interstate truck freight between trans-loading facilities. Both the National Network and the Terminal Access designations were intended to characterize segments of the route the truck took from one warehouse to another. Since that time, particular sectors of the trucking industry have adopted this larger semi-trailer as a single or dominant freight conveyance. The economic expansion of freight due to NAFTA and recent changes in inventory management has resulted in a substantial increase in the number of trucks in this class on the roadways. Where acceptance of the 48- foot and over semi is least likely to occur is within the non-NAFTA export-import trade, which is a substantial component of truck freight in California. This limitation is in part due to container ships and handling facilities that have not been designed to accommodate 48-foot and larger containers.

This project is an inquiry into the nature of STAA operations and the controlling processes now that 30 years of experience have been gained. The STAA delegated the administration of designating terminal access routes to the states. California elected to follow an application process, whereby routes would be designated as Terminal Access on a demand basis, through requests initiated by the party requiring freight access to the National Network. This practice roughly met the needs of commercial customers so long as the 48-foot and larger semi was a minor component of freight transportation, and local planners and developers were aware of the requirement.

With the increasing deployment of the 48-foot and larger, increasingly 53-foot, trailers, violations and enforcement actions increased. Fines can lead to boycotts of businesses by trucking firms in jurisdictions with strict enforcement efforts. These concerns reflect regional variations in enforcement, and failure by local planners and developers to make businesses aware of the need for a Terminal Access application. Police enforcement varies across states and counties. Commercial interests operating in Sacramento and San Joaquin Counties in California have raised issues regarding the STAA law and the manner in which STAA-related regulations are being administered in California, and in these two counties. Other states subject to the same federal law and regulations use different processes as permitted by statute and as filed with the

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Federal Highway Administration (FHWA) as originally required. This study undertakes to evaluate the extent of the issues underlying these complaints and provide solutions that would be both commensurate and feasible to address shortcomings in current efforts to enforce STAA regulations, or expand the Terminal Access designation to newer connections while being mindful of public opinion and safety.

Scope

The project was focused on the I-5 and SR 99 corridors in Sacramento and San Joaquin Counties. The area was expanded north into Yolo County to encompass needs associated with West Sacramento and the I-5 corridor to Woodland in Yolo County.

Acknowledgements

The Tioga project team was supported by a Project Advisory Team made up of personnel from Caltrans Districts 3 and 10 Planning and Truck Services divisions, and the two COGs. It was strongly supported by the members of the GMTF of SJCOG. Many individuals and organizations were involved particularly through outreach to the constituents affected by the topic. Tioga is deeply appreciative of the cooperation, data, and insights of these persons. It is clear that these people and their organizations are affected by this topic and a good number are interested in learning about potential improvements to the current processes and procedures involved.

Approach

The project had a number of tasks:

 Task 1 – Delineate the Current STAA Network  Task 2 – Identify Goods Movement Access Needs  Task 3 – Truck Route Data and Access  Task 4 – Truck Data Compilation  Task 5 – I-5/SR-99 Truck Operating Issues  Task 6 – Recommendation for Improvement of the STAA processes and laws Task 7 – Recommendations for Improving On-going Truck Route Planning

As the project progressed, the tasks were revisited for scope, importance, and potential for insight and meaning.

Information was gathered from multiple sources:

 Project team observations in the field.

 Tioga personnel who have managed trucking companies and railroads that operate STAA-sized equipment.

 Interviews with public and private stakeholders.

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 Organizations including participating jurisdictions, Caltrans Districts 3 and 10, and motor carrier trade associations.

 The general public, through a Caltrans subcontract on behalf of SACOG and SJCOG with VRPA Technologies, Inc. to assist with outreach, in particular to Environmental Justice-identified communities.

 The Federal Highway Administration’s Freight Performance Measurement contractor.

In general, the research team sought to establish the facts regarding STAA routes and operations in the study area, and to understand the reality behind stakeholder knowledge and perceptions.

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II. STAA Route Designation

Legislative Framework

In the U.S., commercial motor carriers and private fleet owners may operate equipment on the public roadways as authorized by federal and state statutes. In 1982 the U.S. Congress, as part of the Surface Transportation Assistance Act of 1982 (STAA), for the first time allowed motor carrier semi-trailers to be 48 feet and over (and over, as grandfathered in this legislation) and lifted prior restrictions on the overall combination length of highway tractors and semi-trailers. To implement the Act, the Federal Highway Administration (FHWA) created rules for operation of trailers from 48 feet in length and over. Also, FHWA “grandfathered” certain prior state- authorized equipment and dimensions.

Important to California and this study were two such grandfathered provisions for truck/tractor – trailer vehicles deemed “California Legal”: 1) trailers of unlimited length, and 2) trailers with specified dimensions between the kingpin on the trailer and the center of the rear axle on the trailer. This dimension is called the kingpin-to-rear-axle length (KPRA). The KPRA dimension is limited to 40 feet on a multi-axle trailer and 38 feet on a single axle trailer when the trailer is operated in combination with a highway tractor or truck. STAA truck/tractor – trailer vehicles have no KPRA limitation when the trailer is 48-feet long, combinations with trailers 48 to 53 feet long have the same KRPA limitations as “California Legal” single trailer vehicles. As a practical matter, STAA thus allowed 48-foot and longer trailers pulled by tractors with a wheel base long enough that the overall combination length (OAL) exceeded the prior limitation of 65 feet. See

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Exhibit 2 and Exhibit 3 for dimensional data for these California-legal vehicles.

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Exhibit 2: STAA Vehicles3

3 http://www.dot.ca.gov/hq/traffops/trucks/truckmap/truck-legend.pdf

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Exhibit 3: STAA Truck Dimensions

These legislative changes had two primary outcomes. Lifting the overall length limit was intended to discourage the practice of squeezing tractor-trailer combinations into an overall 60- foot length by using a “cab over” tractor with a very short wheelbase. This overall length was increased in 1983 to 65 feet by AB 866. With the passage of the STAA longer tractors with larger cabs could be used. The advantages were, and still are, more comfort for the driver of the tractor, easier access for servicing the components of the tractor, and better industrial safety characteristics for persons accessing the tractor.

However, by extending the overall length of the combination of vehicles, it was recognized that the turning and maneuvering characteristics of such combinations would be adversely affected. To compensate for that and to set a workable standard, a process was implemented for approving

Tioga Page 12 operation of such combinations, after a review of safety and engineering considerations imposed by the new, longer vehicle combinations on the actual physical characteristics of the roadway.

In California, the operation of STAA trailers by commercial motor carriers is governed by the STAA, and state and local regulations and processes set up to control such operations. In 1982 there were only a few 48-foot semi-trailers and no 53-foot or longer trailers (other than as grandfathered). It appears that the majority of new trailers are 53 feet in length and that now a majority of the highway trailer population – over 2.6 million trailers – consists of 48- and 53- foot-long trailers.

Confining 48- and 53-foot trailers to the National Network is not possible. This is because there are virtually no customer or support service sites located directly on the National Network, which by definition is comprised of limited access routes. By all appearances the number of truck trips on the National Network plus the rest of the roadways has been increasing. Interestingly, the metric used to calculate an increase in truck trips is tons transported and dollars of revenue generated but not number of trips or vehicle miles traveled. The count of trips is private cargo hauler proprietary data and there is no known estimate of the total of all trips operated in most, if any, jurisdictions, much less those operated with 48- and 53-foot trailers.

Basis for Control of STAA Routes

When STAA vehicles were authorized by Congress, requirements and definitions were codified in the U.S. Code of Federal Regulations (CFR) and the California Vehicle Code. The applicable portions of the federal law are in:

 23 CFR Part 658 – Truck Size and weight, route designations – length, width and weight limitations  Subsections 658.5 Definitions, Terminals, 658.9 National Network criteria, 658.13 Length, and 658.21 Identification of Nation Network;  Appendix A to Part 658 – National Network—Federally Designated Routes (in particular the subsection regarding California); and  Appendix B to Part 658 – Grandfathered Semitrailer Lengths.

The applicable portion of the California Vehicle Code is Section 35401.5 Combination of Vehicles Additional Exceptions and in particular subsection (d) which provides that “The Department of Transportation or local authorities may establish a process whereby access to terminals or services may be applied for upon a route not previously established as an access route.”

The presumption by the federal government was that state, county, and city officials would adopt and proceed with an STAA route approval process as specified. However, no lead agency was identified to be responsible for planning a comprehensive network of STAA routes or a methodology for improvements to be funded and constructed. The goal may have been to have a designated party oversee the network to assure the system was complete and easy to understand for users of the system. Even though that vision is attractive, however, it was not embodied in the original application and approval process. Some state and local highway officials have incorporated this vision into the way they have implemented the rules and regulations, and so local jurisdictions have incorporated the vision into their local approval processes. There are

Tioga Page 13 some communities interested in commercial development that have implemented a network approach and use an on-going planning program to make physical upgrades to implement a coordinated STAA system of roadways. For example, the City of Tracy in San Joaquin County has a listing of STAA/shipping/receiving related improvements with locations and costs related to current and planned future development.

STAA Route Designation Process

The process for application and approval of STAA routes is well established in California. However, implementation may vary slightly by level of jurisdiction, namely state, county or municipality (city or town). How the application process is implemented in the two counties in the two corridors in the study area is described further below.

The STAA created a process for state transportation departments to allow larger tractor trailer combinations on state and local roadways subject to engineering and safety restrictions. The statute changes are embedded in 23 CFR Part 658 noted above, and in California Vehicle Code Section 35401.7 “Combination Vehicle Access Limits Exception.” The California Department of Transportation (Caltrans) administers these federal laws and regulations.

In the mid-1980s, Caltrans inventoried state routes to determine which portions did not meet the engineering and safety standards it had established. Since the mid-1990s, non-compliant portions of state highways have been classified as such. Caltrans’ policy is to upgrade the noncompliant portions of state routes to full STAA design standards when major redesign or refurbishment occurs. Caltrans does have a design exception process in place, if during planning or design it is determined that the necessary improvements cannot be accommodated due to project constraints.

Counties and municipalities follow different processes for their local roadways. For each county and municipality, an application must be made to designate a specific route as a “Terminal Access” route before STAA vehicles are allowed. Designation requires these local roads to meet the same safety and engineering criteria.

The following describes the roles of agencies at different jurisdictional levels.

State Level, Caltrans

Caltrans Website

The law, rules, regulations, and guidance are quite well explained on the Caltrans website. A link to this information can be accessed at: www.dot.ca.gov/hq/traffops/trucks/. The portion dealing with STAA rules on length are in sections 3 and 4, “Legal Truck Size & Weight” and “Legal Truck Size and Weight – Exemptions” respectively.

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Exhibit 2 and Exhibit 3 above are extracts from the website that provide a brief review of important materials and serve to orient the reader to the vehicle characteristics involved.

At this site there are also a number of sub-links to other Caltrans website pages and to the relevant pages of the websites of many counties and municipalities. In addition, at the state level there are a number of other documents. Of these, the most relevant is the Highway Design Manual, specifically Sections 404.3, 404.4 and 404.5. Also of significance is Chapter 2C – Guide Signs – Conventional Roads – Part 2 – Signs of the California Manual on Uniform Traffic Control Devices (MUTCD) at http://www.dot.ca.gov/hq/traffops/signtech/mutcdsupp/index.htm.

The Caltrans Office of Truck Services website does much more than just present regulations and procedures applicable to STAA sized trucks. However, there is so much information that users typically need to study and refer to multiple webpages in order to understand the detail and nuances of some of the material. The information is sufficiently detailed that it is likely not suitable for use by a truck driver or a motor carrier dispatcher. Rather, the material and decisions are more likely to be used by a higher level manager for a motor carrier to determine if and how they will comply with the regulations outlined in the material.

Assistance Provided by Caltrans

Caltrans actively provides assistance to the public, particularly to motor carriers, with its understanding of the STAA route requirements and procedures.

Two full-time employees at headquarters in the Truck Size and Weight Work Group within the Office of Truck Services are devoted to STAA routes. These two employees confirmed during an interview that a large portion of their time is spent on the phone and email explaining the STAA rules and processes and encouraging route designation applications. As noted above, the Truck Services website at http://www.dot.ca.gov/hq/traffops/trucks/ provides a great deal of information about STAA route requirements and procedures. One of the many good features of this website is the link to truck route maps for county and local jurisdictions, although not all jurisdictions have these maps and the graphics and data are not standardized across all maps and databases. It is important to understand that the local content and timing for information is controlled by the local jurisdictions and is not under Caltrans’ control.

Outside of headquarters, Caltrans District offices have Truck Services Managers and Truck Coordinators. These Caltrans staff members help District staff, counties, municipalities, commercial motor carriers, truck drivers and applicants for STAA route approvals understand the applicable laws and regulations, as well as the details of the process for approving STAA route designation applications. Each Truck Services Manager and Truck Coordinator has an intimate knowledge of the specifics involved in each application and the local traffic operational conditions on the proposed route. They assist all involved in seeking permissible routes and anticipating complications in route structures and the approval/denial process. Much of their time is spent not with Caltrans but in teaching county, municipal and motor carrier personnel the process, the reasons for the steps, and logic behind decisions involved with route approvals and denials.

Caltrans District 3, which encompasses all of Sacramento County, has not provided a precise count of applications, but estimates there have been over 20 involving the Sacramento Metropolitan area in the three years from 2009 to 2012. Caltrans District 10, which encompasses

Tioga Page 15 all of San Joaquin County and additional counties, reports that from January 2009 to March 2012 it has processed 70 applications; of these, 49 were approved, 19 denied, and two are pending.

Caltrans Guidance and Stakeholders

Based on interviews and interaction with many Caltrans personnel, it is quite clear that current personnel are well informed and experienced on each of the topics in this section. In particular, the personnel in the Size and Weights Department and the Truck Supervisors at the Districts have encountered every one of the issues identified in this study. Depending on the level of experience, initiative, and exposure, each Caltrans person interviewed was willing to cope with these issues and had a good sense of what was the correct and proper process and application of the rules. Further, if one had any doubt, he/she knew where to go to find out and obtain guidance.

It also is clear that the Caltrans website attempts to explain virtually all of the possible STAA route issues in a way that the public can understand. However, it was equally clear in interviews with shippers, receivers, and motor carriers that the vast majority of them do not know of the STAA requirements, do not know to use the Caltrans website (or, in the very few instances when they have done so, they find it too difficult to navigate to find the correct information in a timely manner), and elect to proceed with operations without complying with the California requirements.

Regional Level

Sacramento Area Council of Governments

The Sacramento Area Council of Governments (SACOG) is the responsible agency for regional multi-modal transportation planning and programming, including for goods movement, within Sacramento County as well as Placer, El Dorado, Sutter, Yolo and Yuba counties. SACOG actively works with its member agencies to plan and ultimately program federal/state/local transportation funds for transportation improvements. SACOG does not currently have an active Goods Movement Advisory Group. SACOG is the lead agency implementing this study in coordination with SJCOG.

San Joaquin County Regional Metropolitan Planning Organization

The San Joaquin Council of Governments (SJCOG) is the responsible agency for regional multi- modal transportation planning and programming within San Joaquin County including for goods movement. SJCOG also actively helps its member agencies to plan and ultimately program federal/state/local transportation funds for transportation improvements. Given the prevalence of goods movement in the county, SJCOG formed the Goods Movement Task Force. This committee is comprised of a mixed group of truckers, truck support services, city, and county officials, and allied groups such as the CHP, Caltrans headquarters and District employees, water and airport personnel, and trade association staff. The group periodically meets to address goods movement issues or coordinate planning/programming objectives as they relate to goods movement.

This group is informed and interested in the STAA route topic and process, and encouraged SJCOG to apply for Caltrans grant funding for this study.

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Air Districts

The Environmental Protection Agency and the California Air Resources Board address fuel and technology standards for heavy-duty trucks, while the San Joaquin Valley Air Pollution Control District (SJVAPCD) and Sacramento Metropolitan Air Quality Management District (SMAQMD) primarily address on-road truck activity (vehicle miles traveled) for purposes of emission inventory development. Given that the STAA process does not have implications for overall truck usage or activity, SJVAPCD and SMAQMD have not been a part of the STAA process. However, SJVAPCD and SMAQMD are involved in air quality and toxic air hot-spot assessments which can have a significant truck component. Since the STAA process can ultimately direct/funnel truck traffic to certain interchanges and/or routes (i.e., the STAA network) it would be helpful to SJVAPCD and SMAQMD to know where STAA Terminal and Service Access routes are located.

County Level

Each county has jurisdiction over its county roadways. Most route designation applications involve county roads and require coordination with Caltrans personnel to connect the county route to the National Network at a viable intersection, and with municipal public works departments to connect the possible route(s) to municipal routes. It is important to understand that not all applications come to the attention of the Caltrans District offices. San Joaquin County reports that it handled 62 local applications in the nine years between 2003 through 2011; however, 33 of those covered just two routes.

Neither of the involved counties has an established master plan. Rather, they handle each application on a separate basis. It appears that some county staff believe that cargo-carrying trucks of any size need to be confined to a very limited number of routes within the county. However, it appears that others think that providing local service on county routes at every shipping and receiving location is necessary for commerce, despite objections from jurisdiction staff or members of the public.

Municipal Level

Identification of local “truck routes” is not the same as the process for approval of STAA routes. Designation of a local road as a “truck route” is typically a component of a local government’s general plan circulation element. A “truck route” refers to a route with municipal restrictions that apply to all trucks and truck combinations in excess of certain stated dimensions, and may employ criteria beyond those addressed in state and federal law. Several outcomes result from designation of these “truck routes,” including: 1) avoiding trucks being a nuisance outside of appropriate neighborhoods; 2) restricting trucks to roads that are properly engineered and safe; and 3) coordinating truck travel with consistent and appropriate zoned land uses.

However, designation of a local truck route does not automatically make the route approved for STAA use. It is a common desire to limit approved STAA Terminal Access routes to a subset of routes already posted as a city’s “Truck Route.” Some stakeholder interviews provided reports of local official and other political involvement and agreements to local accommodations in this regard.

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The City of Tracy has taken a more proactive approach, and created a detailed plan identifying likely future city truck routes and acknowledging the need to make changes to upgrade the routes to STAA standards. It has evaluated a multitude of possibilities and criteria and currently has identified 10-12 specific roadway segments that it desires to improve, including upgrades to STAA requirements. The City’s intention is to address the needs of business and truck operators using larger vehicles. The City’s representative indicated that its motivation to do so includes a recognition that STAA trucks are already operating on pieces of the involved roadways.

Designation Criteria

Federal statute requires that an application for an STAA Service Access route (“S”) or a Terminal Access route (“T”) be evaluated on only two criteria: safety and engineering. Both involve science and judgment.

Engineering

To assist with the engineering evaluation, Caltrans has developed “Turn Templates” to delineate the off-tracking characteristics of various tractor-trailer combinations on specific segments of specific roadways as requested in route designation applications. AutoTURNTM, a recent computer program, performs the same function. See Exhibit 4 for an example of a Turn Template.

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Exhibit 4: Turn Template Example

Source: Caltrans Highway Design Manual, Figure 404.5B

This is quite straightforward, with one area for some judgment. The one area of judgment is the fact that the overall length and the points of articulation for tractor semi-trailer combinations can vary considerably.

STAA combinations consist of tractor, semi-trailer and full trailer – or two semi-trailers connected with a fourth unit, a converter dolly, which are usually known as short (or western) doubles. In combination, these semi-trailers are limited to no more than 28’6” in length individually, and therefore have three points of articulation. No matter the length of the tractor’s wheelbase or the overall length (OAL) of the total combination, the turning radius of the combination is quite consistent with the design of all roadways, even legacy roadway lane widths and turning radii at corners. They were included in the original 1982 STAA rules because of the relaxation of the overall length of the combination from 65’ to unrestricted. STAA “doubles” are only allowed on STAA designated routes. While such combinations are STAA vehicles when they exceed 65 feet OAL, they do not create clearance issues.

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However, tractor semi-trailer combinations using a single trailer with an overall length of 40-57 feet are another matter. In that case, the governing consideration is the distance between the kingpin on the trailer and the center line of the rear-most axle on the trailer (KPRA). When combined with a tractor with a longer wheelbase (about 144 inches), which is legal under federal law, the track of the inside wheels on the combination will cut inside the track of the outside wheels (tires) as the vehicle executes a turn. This “off-tracking” phenomenon is called the wheel or tire “tracking width” or body “swept width” in engineering terms. Another way it is described is the “drip line” of the rear of the trailer will be wider than the “drip line” of the front bumper on the tractor. The distance involved in the swept width increases as the turn becomes “sharper” (has a lesser radius). The highway engineer has to understand the amount of sweep to account for in a turn.

Technically, the distance of the KPRA can be greater on a shorter trailer (48 feet) than a longer trailer (53 or 57 feet) depending on the setting/position of the rear tandem axle assembly as it is attached to the sub-frame of the trailer. This occurs because many rear tandem axle assemblies are mounted on a sub-frame that is a “slider”. That is, the sub-frame can be positioned under the trailer in various locations, thereby making the KPRA either longer or shorter.

While it is not on a 53-foot trailer, the KPRA on a 48-foot trailer is unlimited. This is legal for 48-foot trailers and occurs most often when equipped with sliding tandems where the rear tandem axles are positioned in the rear-most position. If a 53-foot trailer has sliding rear axles, then it too can potentially be operated in excess of 40’ KPRA; however this is not a legal configuration in California. The use of the slider mechanism is desirable when the lading inside the trailer has a weight distribution that may have the combination over weight on an axle or a set of axles but not the overall gross weight of the tractor trailer combination. When so loaded, one of the easiest adjustments to make the load of legal weight is to adjust the position of the rear axles on the trailer so as to make the load of legal weight on every axle. When a trailer does not have a sliding tandem mechanism, it is a “fixed tandem,” meaning the position of the rear axles is permanently mounted in a given location, which location will always be at the 40’ KPRA position (unless the manufacturer and/or the motor carrier can get a locally approved variance which is rare).

AutoTURNTM can be used by engineers to assess any piece of roadway and any turning radius. Most engineers recognize that a skilled, aware driver can position a truck just prior to initiating a turn with the outside front wheel of the tractor at the edge of the lane, thereby clearing a point with the inside back wheel and the back door frame which might not clear in an AutoTURNTM evaluation.

A second type of lateral consideration is caused by the curvature of the surface of the road. Particularly roadways with curbs and gutters will have a horizontal curvature toward the outer edge of the roadway (typically a storm water drainage consideration). This can cause clearance considerations created by “tipping” the top of the trailer to an inward position that is nearer to the curb than the outside of the rear wheel. When this occurs, there is the issue of clearance between the top rail of the trailer and any obstacle mounted on the curb or protruding beyond the plumb line above the curb. Such considerations became more critical because they are more pronounced with the increasing height of the trailer or a steeper cross slope. Trailer edge height in California is legal up to 14’ while in most of the U.S. it is 13’6”. While 14’ high trailers are quite rare, the engineer understandably will plan as though every trailer is 14 feet in height.

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All this considered, the engineering considerations of equipment dimension are rather well understood and controlled. What is less well understood is the width of the pavement and why many truck drivers choose to leave the pavement while making a turn. The Caltrans Highway Design Manual does not allow an engineer to assume trucks will leave the pavement, but does allow trucks the use of the paved shoulder at intersections. Both highway engineers and truck drivers are concerned about the stability of the subsoil and gravel on the shoulders of the roadway. Drivers have the advantage of a visual observation of prior tire track impressions and may choose to track on to the unpaved shoulder as part of an effort to “safely” operate their vehicle. Engineers have to consider the quality of the surface and the upkeep necessary to make the surface stable and usable in all weather conditions. Often there are improvement projects that will upgrade the sub-soils and widen the pavement at corners once these areas have been identified. Usually these are accompanied by increasing the radius of curvature and setting back from the pavement edge any poles, standards, or signage that would otherwise impede a turning trailer.

In sum, the engineering considerations are rather straightforward and the engineer is heavily motivated to design and construction in accordance with the best practices. Nonetheless, there are anecdotes about “shortcuts” that some engineers may take. One of the most questionable practices occurs when a new site is being constructed and the roadway design is not up to STAA standards. The jurisdiction’s traffic engineer and the building contractor may ignore this specification and not make the necessary improvements to meet the STAA standard. In some cases, designing to the STAA standard is a requirement for a building permit, but sometimes the requirement is not enforced or completely understood by the permit-issuing office.

Safety

The engineering criteria in the section above include a safety component. One safety aspect is to avoid property damage. Primarily, property damage may be caused by either a) inadequate turn radii, causing vehicle contact with fixed objects such as curbs, hydrants, poles, signs, etc.; or b) vehicles backing into fixed objects due to the length of the vehicle combination.

The other aspect of safety is personal injury. Minimizing personal injury accidents is important, but the length of combinations is not cited in any literature or safety training materials as a discrete cause of such accidents, and according to representatives of the CHP, rarely is it captured in an accident report compiled by accident investigators from the public sector.

In an attempt to isolate the length of the vehicle combination as a potential cause of accidents of any kind, personal injury or property damage, the research team conducted interviews with CHP representatives specializing in commercial truck enforcement that confirmed several things:

 Turning radii are a cause of property damage; and the longer the combination, the more likely an incident of property damage, or infringement onto property even if no damage occurs.

 Length of the vehicle combination is not known to be a cause of personal injury accidents. The most that can be observed is that because one vehicle combination is longer than another, the time involved in the vehicle combination passing a fixed point at any given speed is very slightly longer than for short vehicle combinations.

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 Data is not kept in police records of truck-involved accidents that would define the length of the truck involved in an accident. If the length is determined, it might be a comment on the formal accident report, but such is considered rare to non-existent.

 Location of accidents is recorded. Whether an accident occurs on an approved STAA route or not on an STAA route is not normally recorded; however, the state or interstate highway and post mile are recorded, so it may be possible with some research to determine the STAA designation of a particular accident location.

 Despite the absence of records, it was easy for interviewees to cite examples of property damage caused by trucks, and some of the time, the truck-trailer combination was known to be an STAA-sized vehicle.

 However, no incident could be recalled by any interviewees where an STAA- sized vehicle was involved in an accident involving personal injury, or that something about the STAA-sized vehicle might have been the cause of the accident.

Signage

In California, Network STAA routes, once approved are to be signed. Signboards have white letters on a blue background (the color for informational signage) with either a letter T or S in a circle in the middle of the sign (Exhibit 5). T is a Terminal Access route; S is a Service Access route. However, local arterial routes are typically not signed, so a driver has an additional challenge to determine if their choice of roadway for deliveries is appropriate for the class of truck they are driving and has been previously approved, or if they should be requesting a different route from dispatch.

Exhibit 5: Terminal and Service Route Signage

Source: http://www.dot.ca.gov/hq/traffops/trucks/truckmap/truck-legend.pdf

Approved STAA signs are legally required and must be posted before STAA trucks can have access. Many of the State routes are properly marked per Caltrans standards; however, this is not always the case. During the interview portion of this study the team was able to identify a few specific concerns raised by commercial vehicle drivers and in some cases specific instances where route designations did not meet the driver’s needs. Comments provided indicate that the drivers feel there is a presumption that the truck driver will see posted S and/or T signs to know if the ramp(s) can be used. In some instances, however, signs have been mounted in a location where the driver cannot be expected to see them, such as northbound SR 99 before Arch Road where the sign was in the left median due to construction in the area, rather than on the right shoulder as is customary. Additionally, signage is not visible to any motor carrier personnel

Tioga Page 22 unless they are on site; that is, a dispatcher or manager at a remote location does not know and cannot tell if a given ramp is posted. Then there is the situation where signage is missing, such as eastbound I-205 at MacArthur where the sign was removed due to construction or on D’Arcy where it had been knocked down (apparently on repeated occasions). A more frustrating consideration is that when a route is approved, the only way for a driver to know it has been approved is to see a newly erected sign. However, signs may not be erected until as much as 3-6 months after approval has been granted. It was also found during one interview that municipal, local road, signage has sometimes intentionally not been erected for budgetary reasons.

It was observed that arterial and local roads frequently do not receive any required STAA signage once a route his been approved. If for various reasons local jurisdictions do not designate sufficient county/city roadways and sign all STAA approved roadways, drivers in the process of making deliveries can face a dilemma:

 because the local jurisdiction has not posted the appropriate signage, drivers can find themselves with nowhere to go legally at the end of the exit ramp – even if the local roadway is STAA approved;  drivers may inaccurately assume that because they have gotten off the National Network at a “T” signed ramp, they can traverse the local roadway system anywhere they feel they can safely operate their vehicle combination; or  drivers can be trapped by a roadway environment that may successfully and legally accommodate their vehicle initially, but reduces in capacity as they near their delivery location.

Improved signage and communication, along with development of a local arterial and roadway network which better meets the needs of drivers is vitally important in addressing these issues as well as reducing potential safety issues.

Non-STAA Truck Routes

Caltrans also has rules and procedures for two other types of truck routes and one other type of permit. These are not applicable in this project but are included here as they often arise in discussion of STAA route rules.

The first type of non-STAA route is for vehicle combinations known as “California Legal” (see Exhibit 2 & the glossary for a detailed description of these vehicles and routes). Basically this is a limitation on overall length to 65 feet, applicable to all vehicle combinations, including those with 48-, 53- and 57-foot trailers operating with a highway tractor of a sufficiently short wheelbase dimension so that the overall combination does not exceed 65 feet. The advantage of this is that such a combination is allowed on all roadways in the state including “Advisory routes” (see next paragraph) without prior route approval but nonetheless with the KPRA dimension not exceeding 38 or 40 feet, or less as applicable. It should be noted that under the worst case scenario, these vehicles require a larger area to accommodate truck turning by virtue of the increase in KPRA distance, than those required for STAA vehicles. This impacts both local arterials and roadways, as these vehicles are not constrained to STAA designated routes.

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Local agencies can limit truck access to designated roadways, but once again proper signage, communication and enforcement of those limitations is critical if safety is to be maintained and compliance is desired.

The second set of rules is for “Advisory Routes” which are state highways that Caltrans has posted for a tractor semi-trailer combination where exceeding a given KPRA length, usually 30 feet, is not advised. These routes are posted with yellow rectangular signs (SW 48(CA), Exhibit 6) and state the KPRA length limitation on that highway segment.

Exhibit 6: Advisory Route Signage

Source: http://www.dot.ca.gov/hq/traffops/trucks/truckmap/truck-legend.pdf

The third category is “Permit Loads” for over-dimensional permits when a vehicle and/or its load exceed any dimensional restraints applicable to it. These are commonly called “over size permits.” They are issued to a specific vehicle on a one-time only or annual basis. Caltrans personnel responsible for these permits are not the same people as those responsible for STAA requirements, which may add some small amount of confusion in the minds of some parties that deal with Caltrans permits and personnel.

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III. STAA Routes and Future Needs

STAA Route Maps

The task of publishing a map or list of approved (or disapproved) routes is complicated. Federal law in CFR section 658.19(b) makes it clear that it is the responsibility of Caltrans to have an adequate system for knowing which routes on the National Network and State Highways/Routes have been approved. However, information included on local “truck route” maps frequently depends on the recollection of someone in each jurisdiction. The position of the Caltrans District Offices is that the signage on the route is proof of the approval of the route, but not all local routes include the required signage and some of the signage is incomplete and/or removed or damaged. To turn a draft of a map or list back to the local jurisdictions for approval/verification has not worked either for lack of knowledge at the local level or lack of staff time/cooperation.

This situation is not sufficiently secure to be the basis for disseminating knowledge of routes and interchanges to the affected motor carriers or other interested parties. Finding someone who really does know the status of a local route is a search that often is compromised. The willingness of the SACOG and SJCOG to try to create such a map or list is meritorious but results in highlighting the complications and inaccuracies.

When a driver or trucking company official or an official of a support service company realizes that there are maps of routes available on the internet, they encounter a somewhat cumbersome and usually inadequate process. Namely, for most routes, they have to access one map for each of the jurisdictions that a route under consideration might travel. That can be as many as three, four, or five maps. While all of the STAA routes are linked to the Caltrans’ website pages covering STAA routes, such a search requires time (more than a truck driver has), excludes city and county truck routes (for non-STAA trucks), and engenders a number of questions about alternate, undesignated and city truck routes that might be possible.

At best, the process is time- consuming. It might induce the person to contact someone at Caltrans, CHP or the city involved. At worst, some interviewees that represent trucking companies report that their personnel become confused and/or frustrated (including after talking with Caltrans or local personnel). If and when the inquiry is met with the need to file an application for route designation approval, it is not necessarily likely that the person making the inquiry will actually follow through with an application even though the act of applying is very simple. More likely human nature will prevail and the person involved, while now better informed, is not motivated to apply.

Most municipalities and many counties have designated truck routes. However, they do not allow STAA-sized vehicles to operate on those routes unless and until approved as STAA routes by the process outlined earlier. This is very confusing to someone not familiar with the need for a separate approval process for STAA-sized vehicles. Further, many municipalities do not have an easily accessible map or description of city “Truck Routes” much less STAA routes. The City of Stockton is a notable exception and sets a standard. To a degree this is attributable to the attention brought to the topic through the Goods Movement Task Force of the San Joaquin Council of Governments and the willing participation on the Task Force by city and county public works officials.

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In contrast to Caltrans, neither Sacramento nor San Joaquin Counties has compiled data on all county roadways and the eligibility of each for approval as an STAA route. At the municipal level, evaluating routes is a bit more manageable due to the greater concentration of roadways. At the county and municipal level for the two corridors, knowledge is less and the process may be less effective when compared to the state level when it comes to considerations involving Truck Routes generally and STAA routes specifically.

STAA Terminal Routes

One of the deliverables for this project is a geographic map of the routes on which STAA-sized trucks have been approved. The summary map is shown below as Exhibit 7. Routes in green are the routes in the study area that are part of the National Network (SR-99 is shown along with the National Network as it was formerly a US Highway). Routes in blue are state, county and local routes that have been approved by the specific jurisdiction involved. Data sets for these routes were obtained from the relevant cities and counties plus SACOG and SJCOG, which had created data sets consolidating some of the approved routes from some of the parties. These parties represented that the routes are current as of March 2012.

It is apparent from Exhibit 7 that existing STAA routes cover only a small part of the road network. The Terminal routes shown in blue are localized, and do not appear to form a complete network system. The underlying databases used for mapping contained no Service Access (“S”) routes, thus Service routes are not included in the map.

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Exhibit 7: Study Area STAA Terminal Access routes (June 2012)

Exhibit 8 through Exhibit 11 provide four enlarged sectional maps. The colors used for the routes are consistent with those used on the fold-up map provided by Caltrans entitled “Truck Networks on California State Highways” dated August 2007.

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Exhibit 8 shows that STAA routes are concentrated in West Sacramento, Woodland, and the area north of I-80. Many developing commercial and industrial areas lack STAA terminal routes.

Exhibit 8: STAA Terminal Access Routes – Sacramento County North (April 2011)

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In South Sacramento County (Exhibit 9), the available routes are concentrated in the Fruitridge/Florin area.

Exhibit 9: STAA Terminal Access Routes – Sacramento County South (June 2012)

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In the far southern part of Sacramento County and northern part of San Joaquin County, STAA routes are available around Galt and Lodi (Exhibit 10).

Exhibit 10: STAA Terminal Access Routes – San Joaquin County North (June 2012)

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STAA routes are fairly extensive around Stockton (Exhibit 11), but have not kept pace with all of the distribution center development in the area.

Exhibit 11: STAA Terminal Access Routes – San Joaquin County South (June 2012)

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Interchange Issues

Despite being a part of the National Network, not all interchanges between the National Network and the intersecting routes are able to accommodate vehicles meeting STAA specifications. In the case of the I-5 and SR 99 corridors, the majority of interchanges are not approved either due to physical constraints or lack of application for access. Having some interchanges signed as permissible and others not signed because they are not approved can be an impediment to commerce because many interchanges cannot be used by the passing truck driver, even when they may be physically sufficient, because they lack signage.

The Caltrans’ District offices, the counties or the major cities involved in this study could not readily produce a list of the interchanges on the National Network that have been approved, disapproved, not been applied for, or are not up to STAA design standards. Instead, the agencies often rely on their personnel to physically inspect the interchange to determine if the proper signage is in place. There are other photographic tools that enable someone to remotely view these interchanges such as the Caltrans Photolog or Google maps; however, those provide only snapshots in time and may not reflect the current status of the interchange in question. Signage may be missing, obscured, not easily located, or temporarily removed due to a construction project in process. It is notable that at the time of this study, Caltrans was progressing on an orderly set of improvements on SR 99 that are designed to upgrade deficient interchanges to STAA design standards.

Mapping Issues

There appear to be gaps in some of the STAA and “truck” routes within these maps. Jurisdictions provided the data and published the printed maps used to create the maps that follow; however there were inconsistencies between the data and the printed maps, and there are routes in the data not shown on the maps because the GIS data provided did not include a route type category.

There are a number of causes for these discrepancies. While not intended to cover all the causes, the following have been isolated or raised:

 To the extent that maps of approved STAA routes exist, they are under the jurisdiction of the individual counties and cities, or Caltrans.

 There is no uniformity in mapping protocol, or as to how current a given map or GIS coding may be. It may be necessary to go to each and every jurisdiction involved to determine the status of a given route.

 The jurisdictions do not all use the same format, wording, or GIS coding system, e.g., not all jurisdictions include the on-off ramps to and from the National Network or any approved route that has split-level interchanges.

 The wording used to describe the nature of the route is not consistent across multiple data sets, e.g. some Terminal Access routes were worded as “TA” and others as STAA-Terminal.

 No Service Access routes were so labeled in the data sets.

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 Many more route segments were provided than just those that are Terminal Access or National Network routes. In particular, city truck routes were provided and only labeled as such a fraction of the time.

 Local staff who know that an STAA route has been approved in their jurisdiction have not necessarily forwarded the necessary information to their GIS staff to allow it to be encoded and, therefore, to appear in the data set or on their printed maps.

 No one single party is responsible for the integrity of the GIS coding, either within a jurisdiction and/or across jurisdictions.

 Not all of the local routes have been provided to the relevant Caltrans District office, nor would they be likely to be included in the STAA map(s) that Caltrans maintains online, because those maps do not include information on routes outside of the National Network and State Highways/Routes.

 Not all interchanges on the National Network are up to STAA specifications, but there is no readily available list of approved, disapproved or not yet approved on- and off-ramps. There also does not appear to be any source that is guaranteed to be current allowing someone to find this information.

 Local STAA routes are approved by one jurisdiction without the involvement of other adjoining jurisdictions or Caltrans.

 Some of the “approved” routes in the data and on the printed jurisdictional maps are based on the recollection of a person not necessarily personally involved in approval of the route.

 Some of the time personnel in a jurisdiction cannot produce the documentation granting the approval if what is reflected in the data and/or map provided. The two COGs likely each need to take account of these observations when they consider what to do in the near and long term. Centralizing the separate data sets was done for this study, and could potentially be used as the start of a centralized database of STAA approved routes. However, the difficulties encountered in compiling maps should be carefully considered by the COGs if they elect to try to improve the process for capturing and disseminating this data and STAA route maps.

Current STAA Routes and Access Needs

There is a perception that approved routes do not match up with current or planned land uses. This was observed previously in the “SACOG Regional Goods Movement Study” which investigated this topic in Sacramento County. For this project, the topic was revisited for both Sacramento and San Joaquin Counties.

The thesis is that areas zoned for certain uses likely should have more approved STAA routes and a better developed network of routes within the territory so zoned. These truck-related zones are summarized in Exhibit 12 for each community along the study corridors.

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Exhibit 12: County or City Truck-related Zoning

This zoning analysis resulted in the maps in Exhibit 13 through Exhibit 20.

The Woodland STAA network (Exhibit 13) is fairly congruent with the pattern of industrial land use on the east side of the city, although growth has extended beyond the routes shown.

Exhibit 13: STAA routes in Woodland

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The North Sacramento area (Exhibit 14) shows a clear mismatch between the extent of truck- related development and the available STAA routes. The Richards Blvd. area is not served, and major tracts of current and potential development north of I-80 have minimal access.

Exhibit 14: STAA Routes in North Sacramento

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West Sacramento routes are better developed, although not complete (Exhibit 15).

Exhibit 15: STAA Routes in West Sacramento

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The South Sacramento and surrounding areas (Exhibit 16) shows large-scale current and developing truck-related land uses below Rancho Cordova and Mather Airport, with a partial STAA network.

Exhibit 16: STAA Routes in South Sacramento & Surrounding areas

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The Galt area has a partial STAA network (Exhibit 17).

Exhibit 17: STAA Routes in Galt

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Portions of the Stockton area (Exhibit 18) are well-served, but other portions are not. The Port of Stockton has control over the roads within the East and West Complexes, and can allow STAA vehicles there, but there are no designated STAA routes to or from the port.

Exhibit 18: STAA Routes in Stockton and Central San Joaquin County

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STAA route development in the Lathrop/Manteca area (Exhibit 19) appears to have lagged the rapid expansion of distribution facilities there.

Exhibit 19: STAA Routes in Lathrop and Manteca

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Likewise, the Tracy area (Exhibit 20) does not appear to have sufficient STAA access for the influx of new distribution centers.

Exhibit 20: STAA Routes in Tracy

As a generalization, many critical parts of the region have only a few existing STAA routes but, with exceptions, do not seem to attract a greater number of applications for routes.

Future Needs

Exhibit 21, Exhibit 22, Exhibit 23, and Exhibit 24 depict locations where STAA routes would logically be needed in the future. Exhibit 21 shows the clustering of trucking companies around Woodland, West Sacramento, and South Sacramento. Many of the locations will be staging areas and operating bases for fleets of 53-foot trailers allowable under the STAA. Exhibit 22 shows the clustering of warehouse facilities in many of the same areas. These shippers and receivers will be served with 53-foot trailers. Exhibit 23 shows large retail complexes in a more dispersed pattern. Many of these retail establishments will routinely receive goods in STAA vehicles. Research team members have observed even small convenience stores being served with such trucks.

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Exhibit 21: Sacramento and Yolo County Trucking Locations

Exhibit 22: Study Area Warehouse Locations (100,000+ square feet)

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Exhibit 23: Study Area Retail Complex Locations (100,000+ square feet)

Exhibit 24 displays the rapid recent and expected growth of business parks and related complexes in the Stockton/Lathrop/Manteca area. While the pace of development slowed during the recent recession and has yet to regain full momentum, the tendency of the industry to expand past the boundaries of existing STAA routes is clear.

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Exhibit 24: Existing and Proposed San Joaquin County Industrial and Office Developments

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The obvious observation is that there are many more locations that are or will be used by STAA- sized vehicle combinations than there are T and S routes applied for or approved. Also, many of the locations are on older, legacy roadways and off of arterials. For the “last mile” to/from a major roadway and/or the National Network, the most prevalent present practice of motor carriers is to let the driver find his way and for the owner/tenant of the motor carrier operating site not to get involved in requesting approval of a route(s) to the site. On the other hand, there are a number of motor carriers (not landlords) that do make an effort to obtain approval of routes to/from their specific site.

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Exhibit 25 from Woodland is a model for what might be done to create a more comprehensive list of truck-involved facilities in each area, if and when such an effort can be justified and resources appropriated.

Exhibit 25: Woodland Distribution Centers

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At least one municipality, Tracy, has done a great job of planning for both city truck routes and desired STAA routes. Caltrans has done so for connecting state routes also. But, those exemplary examples contrast with situations where there has been little or no planning or willingness to match routes with zoning. Most jurisdictions are in the middle.

Only one planning document reviewed spoke directly to the need to preplan routes for increased truck traffic and to have improvements to routes contemplate use by STAA-sized trucks. Also, on many occasions when such improvements are in place, it has not resulted in an increase in applications for STAA designation. However, most jurisdictions, led by Caltrans Districts 3 and 10, do have in place the necessity for future improvements to be up to STAA specifications, even though on rare occasions that requirement has been bypassed.

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IV. STAA Vehicle Operations

Overview

This report section covers the operation of STAA vehicles within the I-5 and SR-99 corridors and within the study area in general. Fifty-three feet is now the dominant length for new highway trailers and for domestic containers used in rail/truck intermodal service. In this respect and others, operations within the study area are consistent with nationwide practices and conditions.

Customer and Trucker Preferences for STAA Trailers

Customers with freight shipments that “cube out” before they “gross out” prefer longer trailers with greater cubic capacity. Cubing out is the ability to fill a trailer with goods (such as empty cans or fluffy plastic toys) before the gross weight of the equipment plus lading exceeds the permissible maximum, generally 80,000 pounds in California. One of the basic reasons the 53- foot trailer was adopted was to better accommodate pallets of a certain, common size than were accommodated in either the early 45- or 48-foot versions of semi-trailers. Customers with more dense freight (e.g. wine, canned goods) that reaches the maximum of 80,000 pounds may also prefer the inside length of the floor in such 48- and 53-foot long trailers. This is because they can create a full load without having to double-deck the lading. The added length allows easier, cheaper loading down the entire length of the trailer. As is most critical to the customer (whether it be a “customer” of a company’s own trucking operation or of a for-hire motor carrier) the cost per unit transported is reduced.

Because customers prefer them, truckers want to provide 48- and 53-foot trailers. Not every load in a 48- or 53-foot trailer utilizes the full cube or floor length, but it is better to have every trailer be of that length than to try to operate a mixed fleet and hope to be able to have the optimal- sized trailer available. That strategy results in more missed opportunities and a higher percentage of empty (non-revenue) miles than a uniform fleet of 53 foot trailers. A uniform fleet is more responsive and therefore competitive.

The marketplace does not yet appear saturated with 53-foot trailers. According to industry sources interviewed, demand exceeds supply, and motor carriers operating 53-foot trailers are adding them to their fleet, and across the industry there are more 53-foot trailers each subsequent year. The most common newly-built trailer is a 53-footer, while units being disposed of are shorter than 48 feet. The end of this trend is not in sight. In the near future there may be more 53-foot operations in absolute numbers and as a percentage of total operations.

Reverting to equipment of a prior size and characteristic is not an option because customers appear want and need the more efficient STAA sized equipment. This is because the cost per shipment unit handled is less with this equipment than with equipment of a smaller size. Because such equipment is not always available, the population of such equipment is expanding and is expected to continue to expand for the indefinite future.

The commercial trucking industry, whether private carriage or for-hire, can be segmented into hundreds of sub-sectors. The segment here is operation of trailing equipment 48-53 feet in length. While this is a prevalent characteristic of much of the commercial trucking industry, it

Tioga Page 48 has never before been an important sub-sector that provides data about its operation. The basic characteristic of this sub-sector is that it operates tractor semi-trailer combinations where the distance between the kingpin of the semi-trailer and the center of the rear-most axle is not to exceed 40 feet. This distance, known as KPRA (kingpin to rear axle) can exceed 40 feet when either: a) a trailer with an overall length of 48 feet or less has the kingpin set in a position such that the KPRA is greater than 40 feet; and/or b) when the rear axle of the trailer is positioned greater than 40 feet from the kingpin. The most common occurrence is when the trailer is equipped with a so-called “sliding tandem” or “slider” that allows the rear tandem axles to be slid forward and back on the sub-frame of the trailer. The possible complication that is controlled by this KPRA requirement is the so-called “off track” distance or “sweep” distance by which the rear of the trailer, when making a turn, follows a track that is shorter than and therefore inside the track of the tire/wheel on the front axle of the tractor that is pulling the semi- trailer.

Dry van, refrigerated van, insulated van, household goods van, and flatbed trailers are more likely to be 48 or 53 feet in length. Liquid tank, dry hopper, and dump trailers are less likely to be that long. Motor carriers that specialize in lighter density products (e.g., paper products, appliances, furniture, packaged consumer goods) are more likely to operate 48- or 53-foot trailers than those that specialize in heavy or bulk commodities. A motor carrier operating so- called “STAA-sized” trailers, meaning 48- or 53-foot trailers, may operate semi-trailers of other lengths as well.

In 1982 when the STAA first authorized the use of minimum 48-foot trailers, there were virtually no such units in existence. Such units are now the most common type being manufactured, and are increasing their penetration of the trucking industry.

There are no consolidated data on the number of 48- and 53- foot trailers in existence, how the entire fleet is deployed, or how many are where at a given moment. Such units flow freely across the U.S., Canada, and Mexico. Such units are commonly available, sometimes with a reservation and pre-planning due to fluctuating demand and supply. By observation, there are many operating in the study project territory, Sacramento and San Joaquin Counties of California. Similarly, there are many that are “based” (that is, allocated) to locations in the two counties where such motor carriers have physical locations for temporarily housing/stationing such trailers. More generally, the greater the number of distribution centers and warehouses in a given community, the greater the availability of 48- and 53-foot semi-trailers. Both counties have a significant number of such distribution centers and warehouses, although far fewer than in Southern California.

There is an important difference between where this size equipment is housed/stationed and where it tends to operate. Where it is housed is determined by the size of the market served; in this case the two counties. More total units tend to operate in and through the two counties than serve origin/destination sites. The National Network has three routes that traverse the two counties: I-80 east-west, and I-5 and SR 99 running north-south. It is also caused by the fact that there is far more population beyond the two counties than within the two counties. Also, there is far more of certain types of commercial activities beyond the two counties than within the two counties. Of all the industry sectors served by commercial trucks, likely only the agricultural, food processing, and possibly the military sub-sectors of industry are more dominant within the two counties than in the surrounding counties.

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Contrasts with other types of trucking operations and equipment

In contrast with 48- and 53-foot trailers, trailers used for route deliveries tend to be 20- to 45-feet long. Route deliveries are trucking operations based most commonly at only one location, and where the truck with its trailer tends to operate in a daily loop from where the driver and truck are based. The trip departs and returns to the same location usually within about a maximum 14 hours of on-duty time for a given driver in a given tour of duty in a given 24 hour period. Management of such operations based in the two counties usually knows to operate equipment that is either “California legal” or less than STAA length.

In one sense, these operations are not sensitive to STAA regulations because they are set up to avoid encountering them. On the other hand, they do encounter STAA rules and equipment in two ways. First, there may be some loops or peddle runs that are better accommodated by using STAA-sized equipment. For example, Wal-Mart’s fleets domiciled in Tehama and Porterville, CA and Sparks, NV use 53’ trailers on loop (aka peddle or return-to-barn) operations, or often they are used by for-hire carriers operating under contract to Wal-Mart. Second, there likely are carriers delivering to and picking up from the same distribution centers as private fleets with STAA-sized equipment. The trucking management at that site must know and utilize the STAA rules and regulations for routes for arriving/departing for-hire carriers that are not a part of that company’s private fleet. How this is managed is particular to each operation. However, it is noticeable that some managers seem to ignore the need to have the for-hire fleets serving their installation qualified and operating on approved STAA routes. In direct contrast, there are some managers that require for-hire motor carriers to strictly comply with the STAA requirements.

Brokers

In 1982 there were very few brokers arranging for freight transportation by truck. According to interviews with truck brokers, the count of loads managed by truck brokers has increased many- fold. Brokers are also labeled third parties or logistics providers, often abbreviated as “3PL”. They arrange for freight to be transported, acting as intermediaries between a shipper looking for a truck and a motor carrier looking for a load. Usually they use a proprietary or a public “load board” to assist in making the match.

Today, due to the evolution of the management of supply chains, the number of truck shipments arranged by brokers has exploded. These brokers simply order a truck for a load, specifying that the type of trailer required is a van, a reefer, a flatbed, etc. They may also specify the length for reasons of the cubic capacity required. Usually they deal only with the city of origin and destination. They rarely know the street addresses involved. They do not even know to ask if the point of origin or the point of delivery is on an approved STAA route. Few interviewed were even aware of the requirement. Those that are aware tend to take the position that such is the responsibility of the motor carrier to determine. But at the same time, they will not tell a motor carrier with whom they are negotiating a price/rate the name and phone number of the shipper, for fear of having the trucker talker to the shipper directly and negotiate directly if the trucker is allowed to talk to the shipper, even if only to ask about the existence of an appropriate/necessary STAA route. As is particularly applicable to the study corridors, such brokered loads tend to be more prevalent in the agricultural and food products industries – industries very active in Sacramento and San Joaquin Counties.

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STAA Vehicle Registration

R.L. Polk can mine the data on vehicle registrations based on an equipment owner’s act of registering a trailer or chassis in any state. Polk indicated that one of the digits in the vehicle identification number (VIN) that each manufacturer must put onto a “manufacturer’s plate” on each piece of equipment does indicate the length of the unit. However, exactly how that length is reported by each state was not fully known. It is likely that some would include lengths other than those studied here. Also, Polk stated that there is no such VIN on domestic containers, although there is on the chassis that holds the container. Polk provided a quote for obtaining registration data for two calendar years. However, it was decided not to proceed based on both the cost and the substantial likelihood of incomplete records.

Locations of the STAA fleet

The motor carrier and/or its drivers operating the STAA-sized vehicles may or may not have a company-authorized location in either or both counties. There are two cases: a) the carrier has a specified location, or b) the driver must find a location. On rare occasions the company- specified location can be a specific address for a terminal, shed, or drop lot for that company, possibly shared with others. More commonly, the driver must find the shipping/receiving locations, and if the driver arrives early, the driver is on his own to find a suitable parking place at which to wait. That place may be a site such as a truck stop that services such drivers or it may be on the public roadway or on private property. When it is private property, it is desirable, but rare, for the site to be the shipping/receiving location.

The best, but by no means comprehensive or totally accurate, database for locations where trucking companies have equipment domiciled (and maybe drivers) is the CHP’s Management Information System for Terminals (MISTER) database. Basically this is a historical listing of street address where, in the past, CHP has located trucks and tractors (with or without trailers). MISTER therefore lists some locations where trucks and tractors may no longer be based. In that sense it lists more sites than may be active. Similarly, more than one motor carrier may have equipment based in a given location. In that sense it lists more companies than locations.

Exhibit 26, Exhibit 27, and Exhibit 28 map these sites. There are many locations in each county: Sacramento County has 714 locations, San Joaquin County has 987 locations, and the four ZIP codes covering Woodland and West Sacramento in Yolo County have 227. A key difficulty with the MISTER database for purposes of this project is that it covers more motor carrier equipment than just STAA trailers based at a given address.

From the data, it is apparent that many locations are not on approved STAA routes. Eventually virtually every location that is utilized for commercial trucking purposes to pick up, deliver, and transship freight will need to be on an STAA-approved route.

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Exhibit 26: Sacramento County Trucking Locations

Source: CHP MISTER Database

Exhibit 27: San Joaquin County Trucking Locations

Source: CHP MISTER Database

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Exhibit 28: Selected Yolo County Trucking Locations

Source: CHP MISTER Database

Driver Route Choice

A critical consideration is how the driver makes a decision about the roadways to be used to access a pick-up/delivery point. Often this is called “the last mile” of operation. The Aberdeen Group, a research house, has reported that 86% of truck drivers have a mobile device, with 44% being smart phones. Also, some tractors are equipped with laptop computers that can access truck routing software directly or via a dispatcher assigned to the driver. For operations using STAA trailers, the percentages are higher than the average and the occasions for use of truck routing software are significant. Also, often the driver or the dispatcher has access to the “Motor Carriers’ Road Atlas” published by Rand McNally. Similarly, often the driver or the dispatcher has access to the Caltrans website, the phone number for the Size and Weight office at Caltrans, and/or the phone number for the shipper/receiver.

However, drivers of STAA equipment cannot be expected to know all the last mile routes that are approved for STAA-sized trailers. The first reason is human nature: drivers are inclined to try to get there on their own, particularly if they think they might know the way. The second is that they will tend to ask another truck driver and/or the shipper/receiver. The third is that they will “look it up” (in whatever way that means to the driver) using whatever resources they have, but without knowing which is best. The situation is even more sensitive because it requires the driver, their dispatcher or the shipper/receiver to know that in California, including the two counties involved, there are special regulations. Truck drivers from out of state will rarely know that something special is applicable much less what it is, and their resources also may not know that the driver is operating with an STAA-sized trailer or the county in which the driver is located. Worse yet, there is no known routing software that takes into account the county- and city- approved routes for STAA-sized equipment. It is true that some of the maps and routing aids do account for STAA routes when using federal or state highways, but none are known to

Tioga Page 53 have programmed either the county/municipal approved routes or the length of the specific trailer involved.

Even when the driver or dispatcher involved knows of the existence of special, local-only rules and enforcement, they rarely know or take the time to learn how to find such approved routes. Additionally, the complexities of looking through many pages of websites and trying to piece together an approved route from multiple pages on a website are daunting when confronted with time and location pressures. There is the added complication that usually neither the driver nor dispatcher know much, if anything, about STAA routes in California, much less in the two specific counties, the borders of which are not easily recognized relative to the name of the city, which usually is known.

A significant consideration is that many drivers use the GPS feature on their cell phone, and none of those are known to indicate STAA route considerations. Most such phones simply provide the shortest physical route without regard to the type of vehicle operated. This is also true of many software applications accessible on laptops or other computers. These aids do not account for truck- specific situations such as clearances or grades.

There are some drivers, dispatchers, and motor carriers that are quite organized, and provide to drivers in advance a specific route to be traveled. That still raises whether or not the driver will follow the specific route; if the specific route even recognizes the equipment type (very rarely) and unique California STAA rules and procedures (usually not, and in one instance where it is known to do so, it recognizes only the state highway system, not the county, municipality, or last mile); and if the shipper/receiver or freight broker, if one is involved, knows of the existence of a specific approved route to reach its facility (probably). On top of all that, if the approved route is somewhat obscure or circuitous and/or the driver misses the approved exit off the freeway, this may cause the operator not to be able to adhere to the advance routing.

STAA Truck Operating Data

All of the considerations described above contribute to the operating patterns of STAA trucks.

The US DOT Freight Performance Measurement program (FPM) includes vehicle location data from the American Transportation Research Institute (ATRI). The ATRI data come from participating motor carriers that regularly “ping” their onboard GPS systems for vehicle location information.

Tioga obtained two maps of tractor/semi-trailer vehicle locations for the three-month period of April, May, and June 2011. One map covered portions of Sacramento and Yolo Counties; the second covered San Joaquin County. The number of vehicles reported in the three-month time period was 1,000,000 for San Joaquin County, 530,000 for Sacramento County, and 73,000 for Yolo County. All of the reported locations were on public roads rather than private property.

The two maps are Exhibit 29 and Exhibit 30. While the roadways are not labeled with route names or numbers, persons with sufficient familiarity with the geographical area involved had no difficulty identifying the street/roadway name and locations mapped due to familiarity with the roadway system.

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ATRI estimates that 85+% of the reporting vehicles are combinations with 48- or 53-foot trailers, and considers the maps to be representative of actual operating patterns. A given STAA vehicle could be pinged more than once in the area, so the records should be considered indications of vehicle operations rather than counts of unique vehicles. Not all motor carriers that operate 48- and 53-foot trailers are reporting to ATRI, and some STAA vehicles could traverse the area between pings and not be recorded. The counts are therefore likely to be underestimates.

Because the points plotted on the maps are in color, some sense of the congestion encountered is revealed. That is because the color of the dot represents the speed of travel between any two pings (but only the second ping is plotted) as follows: red dots denote speeds between 1-15 mph, orange is 16-35 mph, yellow is 36-45 mph, and green is 46-55+ mph.

This database is new and unique. This is the second known application of it in the three counties. The first time it was used involved only two intersections, both in Sacramento County, both involving I-80. The link to this use is at: http://atri-online.org/2011/10/01/fpm-congestion- monitoring-at-250-freight-significant-highway-locations/. Click on 116 and 141, but note that 141 is mislabeled as “I-80 at I-99” when it is at Business I-80.

The Project Team and the Goods Movement Task Force of the San Joaquin COG used this data to assist its review of candidates for specific evaluation of potential STAA routes. The key consideration was Criteria 1, non-STAA facility with STAA trucks present. The data supporting this criterion helped assure that this evaluation concentrated on candidate locations that would yield the greatest impact.

The most important implication of these data and the maps on which they are displayed is the pervasive use of STAA trucks on freeways, secondary highways, and arterials. A comparison between the near complete coverage of Exhibit 29 and Exhibit 30 and the partial coverage shown for STAA routes in previous chapters clearly indicates routine operation of STAA vehicles on non-STAA routes in both regions.

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Exhibit 29: Sacramento County STAA Vehicle Locations

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Exhibit 30: San Joaquin County STAA Vehicle Locations

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Exhibit 31 and Exhibit 32 are extracts of Exhibit 29 and Exhibit 30 showing operations in the central Sacramento and Stockton areas. In the Sacramento map is apparent that STAA vehicles routinely use “downtown” streets and arterials that are not STAA routes. The Stockton map shows the same result.

Exhibit 31: Central Sacramento Area STAA Vehicle Locations

W. EL CAMINO

RICHARDS BLVD. SR-160

I-5

BUS 80

I-80

SR-84

US 50

SR-160

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Exhibit 32: Central Stockton Area STAA Vehicle Locations

MARCH LANE

I-5

WATERLOO RD

SR-99

SR-4

NAVY DR

SR-4 CHARTER WAY

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V. STAA Enforcement

The Enforcement Challenge

Enforcement of STAA regulations is inherently problematic and subject to almost inevitable inconsistency. Neither drivers nor trucking company managers are commonly knowledgeable about STAA requirements. STAA violations are not a high priority for either CHP officers or local police. Local enforcement may depend both on the individuals involved and their knowledge, and on the presence or absence of community complaints regarding truck operations.

Enforcement Practices

Enforcement of the STAA laws is the responsibility of the California Highway Patrol (CHP). All CHP officers receive basic instruction in commercial enforcement. However, only a subset of CHP officers go through specialized commercial training school to specifically enforce the many laws that govern surface freight transportation, including STAA requirements.

Given the signage shortfalls, increased enforcement, and the lack of other easily accessible information, drivers and dispatchers are left using their own judgment regarding the safety and navigability of possible routes. Under current conditions, a driver on an apparently safe route that in fact meets STAA standards may be fined if the route has not been designated a T or S route by Caltrans or a local jurisdiction.

When an STAA truck is cited for operating on a non-STAA roadway, enforcement typically entails a fine (a violation typically costs $250). Although most customers pay for trucker violations, some do not. For-hire motor carriers have been known not to work for customer companies that do not cover the cost of violations. Many customers choose simply to absorb the cost of such fines as a business expense rather than pay the high cost of physically retrofitting roadway facilities to meet STAA criteria. It is not atypical that interest in or receipt of STAA applications within a local jurisdiction is influenced by enforcement activity by the CHP or by local police.

The California Department of Motor Vehicles publishes a 150+ page Manual for those applying for a California Commercial Truck Driver License (CDL). On page 16 there is a short explanation of signage for STAA routes. When a police officer stops a truck driver, the first action is to ask for the driver to produce a CDL. When the officer realizes that the driver has violated the requirement for an approved STAA route, the officer will cite this Manual. Not surprisingly, police officers report that the driver pleads ignorance of the requirement and the content. Often the driver is left frustrated by the imposition of the fine for what the driver considers a remote, little known requirement that he has never before encountered, similar to the ignorance many private vehicle drivers have of less often enforced portions of the California Vehicle Code. Based on interviews with motor carriers, the trucking company that the driver is working for may learn of the situation from its driver, and might even pay the fine the driver has incurred, but apparently this circumstance is rarely sufficient to cause the motor carrier to pursue an application for an STAA route designation.

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Enforcement Options

Law enforcement officials face a dilemma:

 Strict enforcement of STAA rules is impractical and would seriously hamper economic activity in the region.

 Lack of enforcement or a non-enforcement policy would likely lead to over-use of non-STAA routes, adverse impacts on local communities, and reactionary responses from elected officials.

More consistent and effective enforcement will only be possible with approved STAA networks that are more congruent with existing practices and emerging transportation needs.

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VI. Stakeholders and Perspectives

Interviews

Over 75 interviews for this study were conducted in person or by phone by personnel from Tioga, Dowling Associates, and by Jock O’Connell. A list of the organizational affiliations of the parties contacted is in Appendix B. The names of the persons interviewed and their individual comments are consolidated in this report because the participants were promised that their remarks would not be directly attributed to them.

Everyone contacted was presumed to know or need to know something about STAA vehicles and routes. About 90 percent of the jurisdictions, agencies, and trade associations contacted did have that knowledge, and about 90 percent of those agreed to an interview. Of the truckers contacted, about one-half did not know of the STAA requirements (when asked without any aid). Of the one-half that did not know, when aided, one-half of them still did not know anything about the topic. In large part this was because they believe the regulations are not applicable to their vehicles and/or locations and/or customers. Of the customers of the truckers, the lack of awareness (unaided) was nearly universal, and then when aided, less than five percent had any awareness.

Less than 25 percent of those interviewed, were aware of the existence of and/or the purpose of STAA routes and the application and approval process. Over 50 percent had no awareness even when aided. Awareness amongst motor carrier representatives was higher, about 40-50 percent, but in large part that was due to Tioga staff selecting motor carrier representatives that they knew were operating such equipment. Those that were aware expressed displeasure with the STAA requirements and the process. Primarily this was due to having received citations for violations that involved operating STAA-sized equipment on routes that were not approved. A very few motor carriers are very conversant with the process and use it from time to time. Trade associations had much less familiarity with it, unless they were involved with motor carriers and/or the development of industrial sites. Those with that orientation and familiarity expressed frustration and displeasure. Also they tended to have examples, also promised confidentiality, of substantial difficulties.

Trucking Companies

Interviews were conducted with over 50 owners and managers of trucking companies operating in California. Less than 25 percent responded in the affirmative when asked if they knew what an STAA route was. When prompted, most had not heard of STAA, knew very little about it or believed it was not applicable to their operation. Ten of the 50 had had some experience with either applying for approval or having been cited for violation. Only two had had substantial experience with the application and decision process, and they expressed some frustration with their ability to understand the process or the reason for the STAA requirements. Of a group of 22 Sacramento-based trucking executives and managers of trucking support services, only nine knew of STAA and only one had experience with obtaining approval of a route. Five knew (by hearsay) of others that had experience with the topic.

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More lengthy interviews were conducted with three major carriers, two for-hire and one private, each of which are very active in the study area and each of which had substantial experience with the STAA process. All three expressed some frustration with the need for applications and approvals considering the extensiveness of the operation of 48- and 53-foot trailers by their companies (and others). Each had at least one anecdote about circumstances surrounding at least one application wherein some local accommodation was involved.

Trucking company executives who have a sense of the STAA "T" route process are skeptical of the necessity for it. To them, it is noticeable that many 48- and 53-foot trailers operate in the study area every day on roadways that are not "T" routes but on which there is a history of truck travel. If there are geometric or safety issues with such operations, they are generally not known and not appreciated, particularly when certain segments of the trucking industry are exempted. Most of these executives, while reluctant to say so, ask "why does this even exist?" They are hesitant but some have stated that it is easier to risk violations, pay some fines, work out local accommodations, and avoid the application process.

Trucking executives aware of the STAA requirements and processes are quick to identify a number of things about trucking operations:

 53-foot trailers have, over the last 30 years, become prevalent, and the trend is expected to continue.

 Many 53-foot trailers are based at trucking company locations and positioned at customer locations in the two counties, including at the two major rail intermodal yards south of Stockton on the Union Pacific and BNSF Railway railroads.

 Many 53-foot trailers traverse the two counties without stopping.

 The section of I-5 between I-205 and SR 120 has the largest percentage of trucks, of any size, among all the vehicles traveling I-5 or SR-99 in the study corridors.

 It is very desirable for trucking companies to be located in close proximity to freeways although some still remain in older industrial areas due to land cost considerations elsewhere.

 The economics of trucking is very sensitive to excess miles and time.

 Good safety practices are mandatory. That includes using the shortest practical route to get to and from a location and not increasing exposure to incidents by driving other than the most direct route.

 The judgment of the driver has to be relied upon to pick a safe route rather than to regulate every section of every roadway that may be used by trucks of various configurations.

Due to the number of motor carriers interviewed, the reactions are very varied. They have ranged from "I do not know anything about it, and now that you have explained it, I do not care" to "yes, I know something about it, and I have a local accommodation that lets me run those trailers." There have been predictable cynical comments such as "another example of why California is not friendly to business" to "give it time, as more and more 48 and 53 footers get in

Tioga Page 63 operation, the regulation will die of its own weight." A couple of interesting comments were "prove to me that a safety issue exists; it doesn't because my drivers won't operate if it is unsafe" to "why must I pay for specific improvements that help everyone; that is what I pay taxes for – to improve the roadways."

More constructive comments were obtained when a knowledgeable trucker was present along with one lacking awareness, and the informed trucker told the other: "you're illegal and do not know it." Or, "they have just started creating ”T” routes in Riverside County." The most insightful comments were to the effect that applying for a route can be ignored because the trucker has more pressing concerns. Or, "that's why my drivers have learned how to bypass enforcement points."

The bottom line is that the truckers respect enforcement but the process of applying for approval is viewed as obsolete and burdensome by trucking company owners and administrators.

Support Service Providers

These are the businesses eligible for “S” routes to their sites because they provide support services for truckers. It is noticeable that in the study area, there are very few "S" routes applied for or approved. The services are limited by statute to food, fuel, lodging, and repairs although many additional services are also provided such as parking, security, communications, and recreation rooms.

While only two were interviewed, it appears that this type of business may or may not care if it is on or off an “S” route because the motor carriers come to it wherever it is most convenient for the motor carrier or its driver. Similarly, it was pointed out that if the business is located on a “T” route, there should not be a requirement to apply for an “S” route. To this end, some local agencies prefer to use only “T” routes to avoid analysis of all routes within the one road-mile of the “S” route off-ramp concept in the “S” route designation and the possible discontinuance of the operation of the service business. While the Interstate Highway System has drawn some to open locations at freeway interchanges, they have tended not to close original, city center locations because “the business is still there, too” and business comes to that site whether or not it is on a "S" route. In other words, the discretion about the route to be taken to get to the site and the safety/geometric considerations are left to the driver and the motor carrier, not to the support service provider.

The nature of these businesses tends to segregate into two categories as is applicable here. The first is businesses that traditionally were located off the National Network and have continued operations at such sites. Businesses in this sub-sector have remained at the original location because there was sufficient activity at the site to perpetuate the business. These should be interested in having "S" routes to their locations given that "S" routes are applicable within one road-mile of an interchange on the National Network, but it is common for businesses so located to believe they do not need to apply. As their customers operate 48- and 53-foot trailers, they may instead need to apply for a "T" route to allow customers to get to the historical site. However, the definition of a "T"" route requires the location to be a terminal. “Terminals” in the sense used in this process mean an end point on a roadway, not a particular type of facility or site. Some of these service sites may well receive and/or ship goods in 48- and 53-foot trailers, but many do not apply. Also, some of these historical sites are located in older, developed areas

Tioga Page 64 where the chance of approval is very limited due to the inability to expand the roadway cross- section and a reluctance to convert to one-way streets.

The second category is support service businesses that have locations within a road-mile of an intersection on the National Network that is designated as an exit to an approved "S" route. Many of these sites are of recent construction, and more are appearing. Two characteristics are that: 1) the new site at the intersection rarely results in closure of the original facility, catering instead to a different set of customers, and, 2) even though an application for an "S" route is required, sites are committed before obtaining "S" route approval. It has been the experience of those involved that sometimes local agencies do not support designation of S routes.

Many of these support service businesses do receive inbound shipments (and sometimes make outbound shipments) in STAA-sized trailers. Technically they need to have a "T" route to their "terminal" (another occasion for misunderstanding). But they believe they can only have a "S" route under conditions that can be quite constrictive because the needed route is not eligible.

To "S" route applicants, the need for an "S" route at a freeway interchange seems superfluous for an obviously desired service, and may well inhibit applications from being filed. Additionally some such service vendors believe that because they are already located on a "T" route, they need not apply for an "S" route. The justification for the existence of "S" routes seems unnecessary and not compelling..

Trucking Industry Associations

The American Trucking Associations (ATA) is the umbrella association for various types of trucking associations. It represents the industry at the national level. The most critical individual at the ATA, its Director of Highway Policy, is fully aware of this topic and of this project. This person’s observation is that the issues identified in this study exist only in central California; he hears nothing about them from any other location or the FHWA. To that same end, when 10 managers of non-California state trucking associations were asked, only one even knew of the topic and has had no issues with it in his state. It is clear that nationally, with the sole exception of California, and even though the federal rules are applicable to every state, county, and municipality, there is no activity in applying for approval of "S" and "T" STAA routes.

The California Trucking Association (CTA) is the state trucking association for California. The topic of STAA routes is well known to its Vice President of Highway Policy. He reports that he regularly hears about it from individual carriers and industry representatives. He has a document that explains the STAA process that he provides to members when they inquire. In times past, he has considered trying to muster an effort to be proactive about getting industrial developers and jurisdictions to incorporate into designs for new and revitalized industry parks roadways with the necessary requirements to meet engineering and safety standards and a successful application for a "T" route. The goal was to start proactive, long term progress on enhancing the roadway system and the characteristics of specific development projects. It was learned that new state legislation would be necessary, so this approach was abandoned, resulting in no measurable improvement in the design of facilities to meet legal requirements. This representative's opinion was that the carriers do not know about STAA and those that do know, do not care, and as has been proven with the passage of time, do not need to care except when drivers are ticketed by enforcement officials.

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The Truck Trailer Manufacturers Association (TTMA) is the national trade association for manufacturers of highway trailers. In conversations with two of its representatives, it was learned that TTMA does not keep data on trailer/container lengths, nor does it have either last year’s production figures or a profile of the present fleet of trailers in operation. Its representatives did not know of the STAA requirement, and they saw no need for or value in having such data. They did refer to “Trailer Body Builders” magazine (Penton) as a source of annual vehicle registration data. Each March edition of the magazine publishes data on the number and type (but not length) of production by a limited number manufacturers that cooperate with the magazine in providing such data. They were not aware of the STAA route requirements that might benefit from such length data. They were also not aware of any person at any specific trailer manufacturer who tries to compile market-share data based on trailer/container length.

Three other private organizations that provide consulting services were also contacted. One of these does create an annual forecast of new trailer production. Like others, they were not aware of the STAA requirements or how to obtain such data.

Shippers and Receivers

Shippers and receivers who are either customers of for-hire truckers or operators of their own fleet of private trucks find the word "terminal" not descriptive of their sites, unless their own private fleet is domiciled at that "terminal" point. Also, as private truckers tend to run predominately repetitive trips that return to domicile after each tour of duty, they are more aware of having their equipment conform to California Legal criteria and use shorter trailers to conform even if it does lessen the payload on occasion.

It is difficult to locate such parties; rather most comments are second-hand through those that assert that they have seen “customers” have difficulties and concerns. In these cases, the “testimonials” usually involved some economic disadvantage suffered or the need to make “local arrangements” (meaning political) to avoid penalty and inconvenience. One current applicant explained that the private trucking company supplying goods to his business would no longer be able to operate 53’ trailers to his site, and the receiver is thus disadvantaged by no longer receiving goods from that supplier. As a result, the business is considering relocating from its historic (1930s) city center site. However, there were also a number of examples provided by those in agencies that ruled on requests of “success stories” where routes were approved.

At a meeting of Central Valley agricultural shippers attended by 60 people, the question was asked: “How many of you know what an STAA truck route is?” Only a staff member from the sponsoring shipper trade association and a few of the truckers in attendance responded in the affirmative. Even after some explanation, only one of the shipper personnel recognized the topic as something she had heard of. When asked how many were aware of the blue “S” and “T” signs, only one (a different person) recalled seeing such signs.

Also, almost uniformly, neither customers nor motor carriers or their drivers indicated they would tolerate the delay, exposure, and added cost to transfer lading to shorter, California legal equipment to avoid running STAA-sized trailers to a destination. This issue creates a stalemate between customers/carriers and approval/enforcement agencies.

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Departments of Transportation and Motor Vehicles

Contacts at these agencies typically made two observations. First, they cannot vary from the law. Second, even if they have ideas for improvements in the processes or laws, they do not feel free to discuss them and a few even asked that recommendations and ideas in this report not be attributed to them until after they had the opportunity to make their own assessment of the study findings. This is understandable, but it also raised the issue of how an interest in improvement or the internal steps necessary to gain concurrence in changes might occur. The current result is inertia or reversion to the status quo, with agency staff making it clear that the laws, regulations, processes and rules exist, and it is their duty to execute them as they currently exist. This is compelling because it is true, but it inhibits initiative to cope with the present complications in a 30-year old law and processes that some judge to have a number of shortcomings.

Trade and Business Organizations

These organizations fall into two categories: organizations active in the two counties in the study area, and national organizations. The dominant conclusion from reaching out to 12-15 of these organizations with offices in the two study counties is that most do not know anything about STAA truck routes.

There were two exceptions amongst local organizations. One told of its awareness and its accommodations made with local officials to assure access to a specific facility. The other organization, which has a much greater scope and experience, told of specific cases where the need for such routes was not well received so one constituent decided not to locate in the area. Both were aware of the need/desire for new development sites to be pre-approved prior to construction on raw land or redevelopment sites, but each told of the resistance of developers to agree to required design criteria and an unwillingness to make application for STAA routes.

Municipalities

Discussions with staff of about 12 municipalities reveal a wide range of levels of knowledge about STAA routes. Some communities have little awareness and make little effort. Most have a basic awareness and suggestions for routes that might be approved. All indicate a lack of available funding for necessary improvements.

Confusion on criteria is magnified at the local level, with some local ideas invalid but politically attractive. They are a manifestation of the STAA process and the practical way that issues of STAA trucks are accommodated, if not truly resolved. Most often these incidents do not come to the attention of Caltrans personnel until after the fact. When they do, Caltrans employees know the correct thing to do, but usually the situation has progressed beyond what they can, as a practical matter, influence in the given case. They may counsel the local officials as to what is the preferred process and correct application of the rules, but for the particular case, it is too late.

Sacramento County Local Agencies

Although not all Sacramento County local agencies were interviewed, the general findings of those that were interviewed was that local agency staff is not as familiar with the STAA process/requirements as their counterparts in San Joaquin County. This appears primarily due to

Tioga Page 67 lack of staff retention and resulting loss of institutional knowledge that occurs with staff turnover. This lack of experience is reflected by local agencies admitting they were more familiar with the STAA requirements than with the STAA process itself.

STAA route needs generally come to the attention of staff when reviewing development-based site access needs (ingress-egress). Staff noted that STAA requirements do not cause any hindrance to economic development. Local agency staff acknowledged that Caltrans District 3 has been generally helpful is assisting them with the STAA requirements.

San Joaquin County Local Agencies

Interviews were performed with each local agency in San Joaquin County (seven cities and the county). Typically, the responsibility of administering the STAA application process is given to one, perhaps two, employees on a local agency staff. Most of these staff assumed the role by default. However, most have had this responsibility for five plus years and have worked closely with Caltrans District 10 and the CHP on the STAA process. As such, local public agency knowledge of the STAA process is quite extensive in San Joaquin County.

Based on the interviews, all jurisdictions expressed a sound understanding of the STAA requirements, process, and purpose. Most cited safety as the key motivation and support for implementing the program locally. All jurisdictions retain files of applications. Most indicated that STAA requirement issues and application submittals are typically driven by CHP enforcement activity, i.e., enforcement drives the application process.

Although generally all jurisdictions favor approving applications submitted by businesses, approval rates vary by jurisdiction. Factors affecting approval include: 1) age of the road network (i.e., newer cities have built roads to standards); 2) whether or not the local facility in question interfaces with the state system (if so then Caltrans becomes the approving agency); 3) whether the cost is significant to upgrade/retrofit existing facilities to meet STAA criteria. Most application denials are due to physical constraints that require retrofitting. Costs are too prohibitive for the businesses or locality to absorb so the jurisdiction is left with no choice but to deny. The jurisdictions recognize that application denials are especially hard on the truckers who put themselves at risk of enforcement.

Given the lack of public funds to address STAA issues, only a couple of agencies have proactively identified STAA “hotspots” and retain a prioritized list of these locations for future planning/programming. This being the case, almost all of the agencies are proactive in informing applicants for new development permits of the STAA criteria. This includes those applicants who either do not know what size of trucks will be used, or claim that smaller trucks will be used by tenants. Agency staff typically informs businesses that even if they do not use STAA-sized trucks now for business, likely they will need to use them in the future given the trend in the trucking industry to manufacture predominantly STAA-dimension trucks. Only one agency indicated that it does not presume that STAA-sized trucks will be the dominant sized truck for a new business seeking a permit. One agency indicated that if a major arterial meets STAA criteria, the agency assumes that businesses will use it for that purpose whether or not it is designated as a “T” route. As another example of how an agency can be proactive, one jurisdiction has placed “Ghost Buster” signs (truck with a circled cross through it) in locations that trucks have been seen to use non-STAA facilities.

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Some jurisdictions cited that most requests from companies pertain to access to and from a business location, i.e., ingress/egress from the site. For new developments, most agencies place the responsibility on the developer to ensure ingress/egress meets STAA criteria.

Most jurisdictions use AutoTurnTM to analyze truck turn radius. However, it is not uncommon for the local jurisdiction to apply it differently than Caltrans District 10 applies it. How it is used depends on who owns the right of way (ROW). Local agencies defer to Caltrans District 10 if state ROW is involved. Some jurisdictions perform empirical verifications using an STAA- sized truck belonging to an applicant or a combination of empirical field tests with AutoTurnTM. Agencies have found that empirical tests are very helpful in conveying the problem to the applicant and verifying that the roadway geometrics would not suffice. However, such a process requires significant time or resources for both the staff and the applicant.

All agencies were in agreement that there is a need for better education, particularly to the private sector. Most are active (on a case-by-case basis) in trying to educate businesses. One agency felt equal responsibility should be placed on the businesses, shippers and trucking companies for educating all affected employees. Others indicated that learning what Caltrans expects when state right-of-way is involved has been critical to facilitating the STAA process. Several characterized the STAA process as a loosely defined or undefined process. Better clarification of the process is still desired. Several cited that training sessions to address what Caltrans recommends for local STAA route decisions would be most helpful to local agencies dealing with the STAA process and STAA analysis requirements (i.e., application of AutoTurnTM software).

One agency noted that the apparent lack of STAA requirement implementation in other counties around the state puts San Joaquin County and its jurisdictions at a disadvantage for economic development. This agency cited an example of not being able to bring in businesses that have an interest in locating in the County due to enforcement and costs of meeting STAA criteria. However, the majority of jurisdictions when questioned about the implications to economic development disagreed, citing the economic downturn as the key contributor to difficulty in attracting new businesses.

Some agency staff conversed with colleagues in other cities/counties around the state and generally concur that no one is aware of the STAA process; it seems it is only being enforced in San Joaquin and Sacramento Counties.

Industrial Real Estate Developers

A particular group of businesses that might be involved are the developers of new, greenfield sites and the redevelopers of old, repurposed, brownfield sites. When the prospective use of the site is industrial, office, logistics/distribution, or retail, developers might apply for STAA routes to serve these new sites. As such sites have to be “entitled” by local authorities, which may provide an opportunity for assuring proper truck routes of any type are in place to access a site. As a practical matter, this should be done prior to breaking ground because soon afterwards trucks will be arriving at the site to deliver goods and equipment necessary for either construction or as materials that go into improvements.

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One of the local business organizations speaks of its particular familiarity with this. It has attempted to get both the developer and/or its prospective tenant to make such an application for approval of an STAA route to/from the site. This organization indicates that it has even placed onto its “check list” the need for such an application. Nonetheless, the response by developers and tenants/operators has been very limited. This organization continues to try, but reportedly has generated only minor interest in planning for such highway trailers in advance of selecting a site. Once a site has been selected, the organization has tried to encourage developers and prospective tenants to work with their design firm to be sure that the private facilities can accommodate 48- and 53-foot highway trailers and tractor semi-trailer combinations up to 75 feet in length as part of the original design, but such efforts have met with little interest.

Truck Routing Software Providers

There are two categories of commercial software products relevant to truck routing. The first is whatever GPS capabilities might be used by a truck driver. Typically these are as simple as whatever is available from the cellular phone company to which the driver subscribes. The second is provided by various software providers. These software products purport to provide proper highway routes for trucks between points, to the level of street addresses. There are an unknown number of such providers. Just how suitable each product is to that objective is in the eye of the user, be it a trucking company’s dispatcher or the truck driver. In addition, there are companies that provide, either to the cell phone companies and/or to the routing software companies, the underlying locational attributes of the roadway system. These can be loaded into a given software application that includes a routing module, whether accessed by cell phone, in- cab GPS device, or in-cab electronic on-board recorder (EOBR) device.

One such provider of routing software is Rand McNally through its TND 760 Fleet Edition module. Based on a test of that software as performed by a representative of Rand McNally for this study, it appears that its software does account for STAA routes in the study area but only those on the National Network and state highway routes, not those involving either county or municipal routes. Rand McNally suggested a contact with the representatives of the NavteqTM Transport product line provided by NavteqTM, now a division of Nokia Corporation.

NavteqTM representatives have limited familiarity with the STAA route designation and approval process. They indicated that they believe that county and municipal routes in the two counties in California that are the subject of this project (Sacramento and San Joaquin) are not accounted for in their routing attributes data, and even if they are, just how they are accounted for and used by the software developer, as published, and trucking personnel is not known to NavteqTM.

A representative of ProMilesTM, another software development company, explained that there are only four firms that attempt to do the field work necessary to assure accuracy in geocoding of routes in routing software, and that ProMilesTM is one of them. Experience has told ProMilesTM that the diligence necessary to track down STAA Terminal Access routes is well known to ProMilesTM, and it tries to do it well. However, it runs into difficulties in two regards. One is that it is not sure that the person in a jurisdiction with whom it speaks even understands the topic or can provide the geo coordinates of such routes. The other is that the “packager” of various applications into hardware devices installed in tractors and available to drivers, dispatchers, and motor carrier management do not understand the need for routing systems accommodating

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STAA Terminal Access routes, because their trucking company customers are not asking for that level of detail for routing instructions.

This is particularly critical for a number of reasons. First, when the process for approval of STAA routes was decided and implemented between 1982 and 1991, such routing software did not exist. Secondly, GPS via cell phone (or any other mobile device) was not available. Third, no EOBRs (with or without GPS capability) existed. In contrast, in today’s world, use of GPS to create routes for drivers dominates the motor carrier industry and, likely, is the most used method to obtain routing guidance – maybe second only to driver memory, either first-hand or second-hand.

Other Constituencies

No other individuals, companies, or groups were identified as having any interest in being an applicant for approval of STAA truck routes. Metropolitan Planning Organizations (MPOs) are eligible to be applicants but do not have approval authority for any application. MPOs tend to be the best source for identifying shortcomings of the present roadway system and processes to consider for approval of possible STAA Terminal Access routes.

VRPA’s Companion Project

As a companion project, Caltrans retained VRPA Technologies, Inc. to conduct interviews and investigations of appropriate public stakeholder communities that might be affected by STAA- sized vehicles. VRPA’s report was separately submitted to Caltrans. The Project Team for this project was briefed by VRPA on its report’s contents and conclusions. It is noticeable that results from the VRPA effort were very similar to those obtained by Tioga from its interviews, despite being very different constituencies.

 About two-thirds of the parties contacted did not respond.

 Of the agencies and individuals that were surveyed, all of whom were aided with descriptive materials, only about one-half of them knew anything about STAA vehicles and routes.

Despite these differences, it is clear that lack of awareness (aided or unaided) by all audiences is the norm.

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VII. Potential Improvement Projects

Background

One of the tasks in this project was to select a sample of routes not presently approved as STAA routes that seem to be meritorious and illustrative of the need for more approved routes. This section of the study explains the processes used to isolate and analyze these candidates. The process demonstrated some of the nuances and complications of the existing protocol for applications and the approval, contingent approval, or denial of such applications. It also revealed some of the considerations and complications that are present and affect how various participants view the STAA process. This section also includes an analysis of 10 possible projects as case studies of particularly topical possibilities.

Selection of Candidate Projects

Inputs to the selection included complications, tales, and stories with examples, reports, local planning considerations and accommodations, lack of a current and uniform map of routes, unapproved interchanges, lack of network approach, and more.

Inputs

Virtually everyone interviewed who had an understanding of STAA routes and the approval processes and was involved had suggestions for specific roadways as candidates for approval, and had observations about complications and obstacles to approval. The most insightful observations tended to come from the people most intimately involved in specific past applications and/or coping with complications that cause applications to be denied or deferred.

A long list of candidate routes was created (Appendix D). There is no pretense that this list is comprehensive. In fact additions to the list arise each week. These candidates ranged from very short pieces of a given roadway, as short as only a few hundred feet, to a comprehensive example that created a whole network of routes because of the belief that a network approach was missing from the current application procedures. Excellent examples of the network approach were: a) the lack of connectivity of existing routes and major arterials in the Elk Grove area near S. Stockton Blvd, Elsie and Mack Roads, or b) a need to connect South Airport from French Camp to SR 120 and west to I-5 at Roth, Lathrop, Louise, and Yosemite. An excellent example of a short piece candidate was in West Sacramento particularly on West Capitol, Jefferson, and Sacramento.

Cooperating CHP officers had the longest lists, primarily of short roadway segments presently being used by STAA-sized vehicles. Two cities, Tracy and Woodland, had very well developed plans for both city truck routes and STAA routes predicated on the planning principal that it is important to their towns to redirect through-trucks off of existing legacy routes and onto planned new expressways and arterials.

A master but by no means comprehensive list of potential routes and a simple list of weighted criteria to be used to screen potential routes was formulated from the various suggestions and

Tioga Page 72 experiences of those close to the topic. Similarly, selected broad categories of candidates were formulated. These are described in more detail below.

Selection Criteria

The screening criteria selected were: 1. Non-STAA facility with presence of STAA trucks per ATRI data and personal observation by those doing the screening. 2. Non-STAA facility that is a gap in a potential STAA network. 3. Non-STAA facility where CHP has an interest in having the route approved for STAA vehicles. 4. Non-STAA facility serving the older business and industrial districts (primarily within cities and towns). 5. Non-STAA facility expected to serve existing or future development sites. 6. Non-STAA facility serving as a parallel arterial or frontage road to the National Network. 7. Other observations unique to a specific route or location that are potential generalized observations because they repeat.

These criteria were circulated and discussed with both the Project Team members and some of the members of the San Joaquin COG’s Goods Movement Task Force. A list of 32 possibilities was created for intensive discussion by both of these groups as well as the consulting team from Tioga and Dowling. The criteria were accepted and applied by those involved in final selection of candidates for more intensive study.

Project Selection

The 32 initial route possibilities included 12 in Sacramento County: SC1: Business I-80 – Jefferson Blvd./SR-275 SC2: East-West Stockton Blvd. frontage roadways along SR-99 Grant Line to Mack/Bruceville SC3: Franklin Blvd. as a parallel arterial/frontage roadway along SR-99 to Fruitridge SC4: Mack Road - SR-99 to Stockton Blvd., aka Mack/Elsie interchange (I/C) SC5: Twin Cities Rd. (E13/SR-140) between I-5 and SR-99 SC6: City of Sacramento – The Railyards development area (Q, J, I, 5th, 6th, 7th, Richards Blvd, Garden Highway) SC7: Richards Blvd - I-5 to SR-160. (I-5/Richards I/C was recently upgraded to STAA standards.)

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SC8: Del Paso Blvd. - I-5 to Rio Linda Blvd. SC9: El Camino - I-80 to I-5. SC10: Seamus/Fruitridge - I-5 to Power Inn SC11: Florin Road - I-5 to Power Inn SC12: Hood Franklin Road - I-5 to Power Inn

There were 20 initial routes in San Joaquin County: SJ1: Liberty Road - SR-99 to SR-88 SJ2: Peltier Road - I-5 to SR-99 SJ3: Victor Road -SR-99 to SR-88 SJ4: Harney Lane - Lower Sacramento Road to SR-88 SJ5: Cherokee Road – west of SR-99 SJ6: SR-99 Frontage Road - north of Airport/Arch to Mariposa SJ7: SR-99 Austin/Moffatt Road (Spreckles access) SJ8: East Grant Line Road- North MacArthur Drive to I-5 SJ9: Lathrop Road - I-5 to SR-99 SJ10: Airport Way - French Camp Road to SR-120 SJ11: Roth Road - UPRR Driveway to Airport Way SJ12: Yosemite - Airport Way to SR-120/Guthmiller Road SJ13: French Camp Road - I-5 to SR-120 SJ14: March Lane - I-5 to Holman Road SJ15: Harlan Road Frontage - SR-120 to French Camp Road SJ16: Benjamin Holt Drive - I-5 to El Dorado Street SJ17: Turner Road - I-5 to SR-99 SJ18: K-5/Kasson Road SJ19: I-580/SR 132/Crisman Road SJ 20: Hammer Lane between I-5 and SR-99

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Many more possible projects could have been listed except that many of them tend to fall into five broad and important categories. These more generalized categories were made apparent in the discussions of the 32 possibilities, as many of them also fall into one of these five:

 Parallel arterial or frontage roads to National Network routes.

 Where both a T and an S sign are, or could be, placed at a given interchange on the National Network.

 Older business and industrial districts in towns and cities where legacy roadways are not sized appropriately for easy modification to accommodate STAA-sized trucks.

 Routes serving solely agricultural growing acreage

 City truck routes.

These categories are discussed as problem areas in the findings section.

Selected Projects

This is a description of the 10 projects selected through the discussions and use of the criteria described above. There are five each in the two counties, detailed below from north to south through the study area.

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Project SC8: Del Paso Road between I-5 and Norwood and/or Rio Linda. Selected based on Criteria 1, 2, 3, and 5 plus a recognition of the lack of an STAA route connecting I-5 with the industrial areas north of Sacramento. (Exhibit 33 and Exhibit 34)

Exhibit 33: Del Paso Road Project Area

Exhibit 34: Del Paso Road Project Area Truck Activity

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Project SC7: Richards Blvd between I-5 and SR-160, plus the new 5th Street arterial between Richards Blvd and J and I Streets and west to I-5. Also may involve Q, 6th, 7th, and 8th Streets and Garden Highway. Selected based on Criteria 1, 5, and 7 plus a recognition that the I-5 interchange with SR-160 has just been upgraded to STAA standards, and these routes will be the major access routes to the Railyard redevelopment. Because of the current planning for the Railyard development, these routes were combined to evaluate the scope and logic for an integrated, network approach. (Exhibit 35 and Exhibit 36)

Exhibit 35: Richards Blvd. Project Area

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Exhibit 36: Richards Blvd. Project Area Truck Activity

Project SC1: A selection of routes in West Sacramento that could become a more coherent network. Selected based on Criteria 1, 2, 3, 4, and 7. Routes include Enterprise, West Capitol between the interchange with I-80 and Harbor Blvd, West Capitol between Harbor and Jefferson, the interchange of Jefferson with SR-275, Jefferson between SR-275 and Sacramento, Sacramento between Jefferson and its interchange of I-80, Harbor Blvd between Sacramento and West Capitol, West Capitol between Harbor and Jefferson, the overlap/combination of Harbor Blvd as a T route at Business I-80/US 50 and as an S route at the same interchange, and West Capitol west of Harbor to its junction with I-80 and Enterprise Blvd. (Exhibit 37 and Exhibit 38)

Exhibit 37: West Sacramento Project Area

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Exhibit 38: West Sacramento Project Area Truck Activity

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Project SC4: Mack, Elsie, Stockton Blvd. at SR-99. Selected based on Criteria 1, 2, and 7. Routes include those above plus the Bruceville/Mack exit off Southbound SR-99, plus an incomplete network east to Watt Avenue and north to 47th Street/Elder Creek Blvd. (Exhibit 39 and Exhibit 40)

Exhibit 39: Mack/Elsie/Stockton Blvd. Project Area

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Exhibit 40: Mack/Elsie/Stockton Blvd. Project Area Truck Activity

Project SC5: Twin Cities Road between I-5 and SR-99. Selected based on Criteria 1, 3, and 7. Also, this route has been used by CHP as an authorized detour including STAA-sized vehicles when there is an incident blocking either I-5 or SR-99. To do so has involved posting a CHP warning and officer on the route, but when the detour is taken down, STAA-sized trucks are prohibited once again. This appears to be a dual standard. Also, the interchange at SR-99 and Twin Cities Road is about to be improved to STAA standards, and this route is used by STAA vehicles east of SR-99 to the Rancho Seco natural gas facility. (Exhibit 41 and Exhibit 42)

Exhibit 41: Twin Cities Road Project Area

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Exhibit 42: Twin Cities Road Project Area Truck Activity

Project SJ1: Liberty Road SR-99 to SR-88. Selected based on Criteria 1 and 3. This is one of about eight possible east-west routes north of SR-4 in Stockton that have the same pattern. However, it has the added feature that there are many STAA truck drivers who do not understand that it does not connect westerly to I-5. (Exhibit 43 and Exhibit 44)

Exhibit 43: Liberty Road Project Area

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Exhibit 44: Liberty Road Project Area Truck Activity

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Project SJ17: Turner Road between I-5 and SR-99 in Lodi. Selected based on Criteria 1, 3, 4, and 7. This is a county route that has impediments to being used as a through-route. In particular trucks with more than two axles are prohibited from Lower Sacramento Road (north) to SR 99 southbound. Circuitous miles are involved to access some points not presently accessible directly on Lower Sacramento Road north. Periodically, the CHP and Caltrans use it for a detour route, thereby allowing STAA-sized vehicles. On the west end at I-5, the area next to the off ramps is used by over-dimensional loads to hold and wait for clearance. There are issues of compatibility with STAA design standards at both interchanges at I-5 and SR-99. (Exhibit 45 and Exhibit 46)

Exhibit 45: Turner Road Project Area

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Exhibit 46: Turner Road Project Area Truck Activity

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Project SJ10: Airport Way between French Camp and SR-120, plus Roth Road from the existing “end” at 1000 Roth to Airport, Lathrop from I-5 to SR-99, Louise from South Holland to Airport, Yosemite between Spreckels and Guthmiller, Guthmiller between Yosemite and SR- 120, D’Arcy between South Holland and Yosemite, and French Camp from the eastern “end” to Jack Tone Road. Selected based on Criteria 1, 2, 3, 5, and 7. Involves completing an incomplete network to serve pending site developments and known truck trips. This includes a legacy design on Yosemite in the town center of Manteca. (Exhibit 47 and Exhibit 48)

Exhibit 47: Airport Way Project Area

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Exhibit 48: Airport Way Project Area Truck Activity

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Project SJ7: Austin/Moffitt Road between Spreckels access and SR-99. Selected based on Criteria 1, 2, and 7, including the need to more efficiently connect to existing STAA routes when a new design for this area is created. Current STAA routes direct traffic to a congested route. The rebuilding of the interchange at SR-99 and Moffatt is programmed. (Exhibit 49 and Exhibit 50)

Exhibit 49: Austin/Moffitt/Spreckels Project Area

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Exhibit 50: Austin/Moffitt/Spreckels Project Area Truck Activity

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Project SJ8: East Grant Line Road between the interchange with I-5 and MacArthur Drive, including Paradise Road and Pescadero Road. Selected based on Criteria 1, 2, 3, 5, and 7, plus to complete the loop around recent and pending new development. (Exhibit 51 and Exhibit 52)

Exhibit 51: East Grant Line Project Area

Exhibit 52: East Grant Line Project Area Truck Activity

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VIII. Route and Operational Findings

Overview

This section summarizes the findings from the research team’s information-gathering, interviews, and analysis. In general, the study confirmed that regional public and private stakeholders face a number of issues in attempting to develop, designate, and use STAA routes, in particular the interchanges and intersection roadways on the I-5 and SR-99 corridors.

Many trucks simply pass through the two counties on the designated Interstate and State Routes that are freeways. Some will exit only to access driver or vehicle services such as fueling. Many of these are tractor-semi-trailer or truck-pull trailer combinations utilizing 48- and 53 foot semi- trailers. There are no known passing counts based on the length of the trailer. However, the count is substantial and may approach the count of vehicles that get on and off the designated system to provide local pick-up and/or delivery services or to operate via a company facility. To allow vehicles and their drivers to pass through, there is a necessity to use only STAA approved interchanges when operating 48- and 53-foot trailers. However, it is recognized that such drivers likely do not understand that they are governed by the blue S and T signs.

For this sub-sector of the commercial trucking industry that is only passing through the area, the issues with these two corridors are the more traditional considerations of congestion, pavement conditions, line of sight, accident prevention, construction zones, etc.

STAA Route Designation Issues

Applications for approval of STAA routes should be expanding in type and number. Compared to 1982 when the STAA was first adopted, the numbers of trucking companies truck drivers appear to be significantly greater. The number of 48- and 53-foot trailers operating on unapproved routes on a daily basis has also grown to the point that it may compromise the willingness of a driver and/or a motor carrier to honor the application process. Instead, “take a chance, and pay the fine if you must” is the true approach to the requirement.

Caltrans personnel involved with STAA routes are exceptionally knowledgeable, helpful, and concerned. They are well regarded by outside personnel that know and work with them. Interviewees that have talked with Caltrans personnel acknowledged that Caltrans personnel are advocates and educators within Caltrans. Their concern stems not from Caltrans and local jurisdictional staff’s sincere efforts but from the pace of application approvals being so slow and a realization that many routes are incomplete.

Additionally, as organizations experience staff turnover, often there is a significant loss of institutional knowledge that results in learning curves that may cause frustration and inaccurate approaches to the STAA route application and approval processes (at least temporarily).

Need versus Applications. The initial 1982 presumption in the STAA statute was that all roads other than the National Network were incapable of accommodating STAA-sized vehicles until proven otherwise – called the negative presumption. The current application process is largely a process of separate applications for each route. It lacks a provision for a master plan to create a

Tioga Page 91 network of STAA truck routes or to overcome existing obstacles or gaps in routes. The rules and regulations presume that for-hire and private motor carriers, shippers/receivers, and support service vendors will apply for approval of such routes. The thought that they might not apply apparently was not contemplated.

Delay. Generally, a decision on approval or disapproval occurs within the statutory 90-day requirement. However, in some cases STAA route installation has been delayed after being recommended for approval. The delay typically results from a wait for approval by higher- ranking public officials, having signage erected, creating local accommodations and/or signage peculiarities in some municipalities.

Additional Conditions. At the local level, there are reports of additional processes and approvals, over and above those in the federal and state laws and regulations. These occasionally add complexities and timing difficulties. An example would be an applied-for STAA route that passes by a school, a playground, a park, or the entrance to a gated community, and/or where the route has one jurisdiction on one side of the roadway and another on the opposite side of the roadway, with the two jurisdictions split on the approval/denial of the applications. Many arterials that would be suitable as an STAA route pass schools, parks, churches, community centers, etc. where people congregate. The thinking of some is that such routes should not be approved for STAA trucks, even though shorter vehicle combinations, exempted vehicles, and vehicles with a special trip permit are allowed to do so. However, in prohibiting such a route and encouraging a more circuitous route may result in greater risk of exposure to citizens and property than would otherwise be involved.

Local Accommodations. Very often the current status or “resolution” is a temporary local accommodation based on agreements between the affected parties closest to the specific situation. Often these accommodations involve localized political considerations that lift the specific route out of the sphere of influence of the engineers, safety experts, and even Caltrans experts.

Lack of Notice or Signage. Except to the applicant, often there is no official notice of additional approved routes beyond the minimal “decision point” signage at ramps or intersections. Other users have to wait for signs to be posted between these “decision points,” and they are not known to anyone but drivers unless local municipal “truck route” maps are updated on a regular basis. Often there is a delay in getting additional signs posted, and some communities fail to do so for budgetary reasons.

Emerging Street Design Practices. As city planners embrace concepts such as traffic separation and livable cities, the roadways and lanes on a given roadway tend to impose additional, new obstacles to using the complete roadway and right-of-way for the purpose of maneuverability of larger vehicles. For instance, in the “complete streets” concept, the existence of pedestrian “bulb outs” and islands that channel traffic into narrow, single lanes are in direct conflict with STAA needs.

Crossing Double Yellow Lines. Caltrans guidance is to deny a route for safety reasons if it requires the tractor semi-trailer to cross a double yellow line into a traffic lane for on-coming vehicles. This is also a violation of the California Vehicle Code. Nonetheless, drivers often do make such a maneuver because either: a) while it is unnecessary physically, it is expedient; or b)

Tioga Page 92 the driver believes he has sufficient space to complete the turn before on-coming traffic competes for the same space on the roadway.

Truck Turnarounds. It is required in the CA MUTCD (Traffic Operations Policy Directive 12- 05) that at the end of an approved route there must be a space available at which an STAA truck can turn around to exit the area. A turnaround location can be on private property provided that the owner agrees to keep the turnaround area open 24 hours per day, 7 days per week. It cannot be on private property if there is a gate and the gate is locked after working hours, even though making the turnaround during working hours is practical. There have been some rather creative routes designated for this purpose, such as through a shopping center parking lot or alley or constructing circular turning areas solely for this purpose. On the other hand, there are multiple examples of not making provision for trucks to turn around. Some of these are at a dead end cul- de-sac. Some, however, are at a point where the truck could continue forward to an arterial that is within sight.

Circuity. Local truck route designations may force circuitous trips, adding to cost and emissions. Forcing the truck to operate via a longer route than is necessary is both confusing to the driver and increases the potential for violations, property damage, or personal injury. Circuity also adversely affects those living, working or traveling along the longer route.

Transfer of Freight. It is common for some parties to suggest to both truckers and customers that the proper way to comply with the lack of an STAA approved route is to modify the trucking operation. The usual suggestion is that when the customer is located at a site to/from which an STAA route is not possible, then the proper thing to do is one of three things, namely, tell the trucker to: a) use shorter trailers; b) be California legal; or c) stop at a warehouse or freight shed on the edge of town and transfer the lading from the “illegal” STAA trailer to a compliant truck to shuttle it the rest of the way to the receiver (or vice-versa). These suggestions are rarely followed, because the direct and indirect costs of such extra handling and arrangements are not optimal. What is optimal is to find a motor carrier that will continue to serve the site with 53-foot equipment via an unapproved route despite the risk of complications, and/or make local accommodations to arrange for continuing operation of STAA-sized trailers.

Designation Records. There is no sure, comprehensive, permanent recording of approved STAA routes at the jurisdiction or local level. This is attributable to decentralization, without auditing to see that it is done or done uniformly. Once a local route is approved (or denied) there is no assurance that it is documented in a local city or county’s GIS system, or that it is done in the same way in each GIS system across all jurisdictions. Caltrans District staff is involved in approvals provided that the local road in question connects to a State Highway or the National Network; but not every other local STAA route approval is forwarded to the applicable Caltrans District office. When a citation is at question, the only way to verify the accuracy of the approved route is an informal communication between the arresting officer and someone deemed to know the routes in the local jurisdiction. No one party knows all routes within the local jurisdictions or a Caltrans District, with the exception of those local roads that connect directly with a State Highway or the National Network, and there is no one listing of local jurisdiction personnel available who can confirm a citation’s validity at the time of writing. Turnover in personnel, particularly in the GIS function is another complication, as is the lack of a standardized method for coding GIS data for approved routing.

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Problem Cases

The study team identified at least five categories of problem cases where STAA rules and procedures are difficult to apply.

“S” and “T” Routes

When conceived, California Vehicle Code Section 35401.5 “Combination Vehicles Additional Exceptions” set up two types of STAA approved routes: “T” (Terminal) and “S” (Service). Each had its own purpose, and it appears they were intended to be mutually exclusive. However, in practice, they are not mutually exclusive, create signage complications, involve safety and roadway design considerations beyond what might have been contemplated originally, and can cause confusion among motor carrier personnel.

Basically, the S route appears not to be necessary or useful, for three reasons. First, any “service” business catering to trucks and/or truck drivers also requires truck deliveries (or pick- up) of goods used/sold at the service facility. Such deliveries may utilize STAA-sized vehicles. Service facilities need to be on routes designated as T routes. As a result, there are many locations signed as T routes that are roadways that serve service facilities so the requirement for the S signage is ignored. An example is the interchange of Cherokee and SR 99 (in northeast Stockton) where many truck service facilities exist, and Cherokee is approved and signed as a T route. Second, the definition of an “S” route is any identified approved STAA route within one road-mile of an interchange on the National Network or an approved State Route. Third, local jurisdictions have been known to use logic that is somewhat convoluted to T routes with S routes so as to “stretch” the geographical coverage of either or both types of routes. An example is the S designation at the interchange of Business I-80/US 50 and Harbor Boulevard in West Sacramento reaching to connect to the existing T designation on W. Capitol west of Harbor (unsigned) and/or to the S designation on Enterprise/West Capitol.

Parallel Arterials and Frontage Roads

There are many frontage roads and arterials that parallel freeways and major highways. Besides carrying local truck traffic, these routes serve as alternate routes when I-5 and/or SR-99 are congested. These sections of roadways are often designated as “local truck routes” by the local jurisdictions. However, that designation does not make them legal STAA routes.

Legacy Roadways

Legacy roadways can be prohibitively costly or impossible to upgrade to STAA standards, particularly in and near town centers. Yet local businesses located on such routes are likely to use or receive STAA tractor and trailer combinations. An application for approval of such a route raises numerous issues, including:

 The cost to modify the existing roadway – such as the network of one-way couplet streets in downtown Sacramento – and the source (if any) of funding.

 The cost of transferring the load or relying solely on compliant vehicles.

 The potential loss of business volume, or relocation of the affected businesses themselves if STAA vehicles are not allowed use of the route.

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 Possible local accommodations that put STAA vehicles on sub-standard routes.

 The likelihood of ongoing violations by STAA vehicles, even with the threat of fines, if the route is not approved.

 The potential deterioration of the business community and important employers if STAA truck activity is limited or prohibited. This includes creating abandoned business sites and urban blight.

Farm-to-Market Roads

Agriculture and related industries are prominent in the study area. Many farms, orchards, ranches, packing houses, and processing plants are not on STAA routes, despite the need to accommodate STAA vehicles (particularly during harvest season). Many such vehicles are using rural roads that do not meet STAA standards. To not be able to do so is economically unacceptable to the buyer/broker/grower/farmer.

Additionally, use of private roadways is often involved in the final access between the public road and the field. This topic is sufficiently complex to be a candidate for a separate analysis, beyond the scope of this project. It is being reviewed as part of the ongoing SACOG Rural Urban Connections Strategy (RUCS) project.

City Truck Routes

Most local jurisdictions designated local municipal truck routes long before STAA vehicles were authorized. Many of these city truck routes are legacy routes. Many communities are diligent in maintaining these routes both physically and conceptually; however, some communities are trying to relocate truck routes to newer roadways that encircle the town and no longer use the original, older routes that defined the original downtown area. Tracy and Woodland are examples of cities attempting to modify city truck routes. One option is to update city truck routes to STAA standards, thereby eliminating confusion with city truck routes that are not STAA routes. However, Sacramento, for example, has not elected to extend its system of city truck routes to all of its city center streets, and it has not re-labeled any of them as STAA routes even though some are likely to meet STAA standards.

Status and Signage at Freeway Interchanges

One of the most serious shortcomings in the current system is that many freeway interchanges do not meet STAA requirements. The law, per the CA MUTCD, is that if the interchange is not marked with the proper blue T or S sign, it is not authorized. However, the issue becomes ambiguous or unknown to truck drivers when:

 Some, but not all, of the on/off ramps at a given interchange are authorized.

 There is construction on the freeway or the crossing roadway and the signs have been removed during construction.

 The sign has been damaged or removed.

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 The sign is either not in the logical line of sight or placed only after starting down the exit ramp or in the median rather than the curbside berm.

 There is no additional signage at the bottom of the ramp indicating the direction to turn to continue on the approved route.

Neither the driver nor his motor carrier know how to find out easily if a given interchange is approved, short of physically looking to see if a sign exists. When motor carrier personnel know to look on the Caltrans website, they learn that to use the website to identify a route that traverses multiple jurisdictions can be complex and time-consuming. Also, they note that very few of the jurisdictions have such maps on the website, and for those that do, the maps are not uniform in character, making the information more difficult to understand.

Terminal and Service Designations

There is a presumption that the route designation “Terminal” or “Service” would be meaningful. In fact, the word “terminal,” which is defined in the federal regulations to include customer sites, is inconsistent with the general meaning of the word as a motor carrier facility or base of operations. The separate designation of “Service” has also developed to be ambiguous in at least two ways. First, if the route is a “Terminal” route, by definition it honors locations that provide support services for truckers (one of which is the trucker’s terminal). Second to limit the designation “Service” to a one road-mile distance from an approved interchange is to make obsolete all of the truck service vendors located “off the Interstate” – an impractical outcome as they will not necessarily close up shop at their present locations to move to within one mile of the Interstate.

Exceptions

There are many exceptions to the federal requirements. The merits of these exceptions may no longer be applicable or are not always obvious. Two exceptions that are applicable but provoke adverse comparisons to the requirements for 48-foot STAA trucks are:

Household Goods

There is an exception in Section 35401.5 regarding household goods carriage. The exception allows all equipment operated by household goods carriers to operate as is “direct and safe.” Originally, the purpose of this exception was to allow moving vans access to residences, and that is still the case. However, in some neighborhoods, such access is physically challenging, even impossible. Also, in today’s unregulated motor carrier world, household goods carriers are often transporting freight that is not household goods. Rather, they move new furniture, machinery, fixtures, cabinets, etc., to/from commercial establishments, in addition to pre-owned household goods. The trade associations to which movers belong and some of the individual moving companies report no difference in accident rates of STAA-sized moving vans compared with any other vehicles. In part this is due to special training and instructions that exist in the trucking industry. From the point of view of motor carriers, “if the household goods guys can do it, so should we be able to.”

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Grandfathering

Longer 53-foot trailers have been “grandfathered” for legal operation in some states. California also allows “California Legal” 57-foot trailers. In the study corridors there are a few trucking companies that operate 57-foot trailers in combination with short-coupled cab over tractors. With such tractors, 57-foot trailers are within the 65-foot overall length combination limits and may operate on highways and local roadways that are not yet approved as STAA routes. When the kingpin setting and tandem positioning on a 57-foot trailer is the same distance from the nose of the trailer as on a 53-foot trailer, there is an added four feet of length of overhang at the rear of the 57’ trailer compared with the overhang on a 53’ trailer. This additional overhang at the rear of a 57-foot trailer could potentially create maneuvering and safety challenges, even though these trailers can operate without the requirement to have prior route approval because the combination is “California Legal.”

Cost of Improvements

A major factor that inhibits the designation of approved routes is the cost to make necessary improvements. Often a route can be approved if a physical improvement is made. However, the governmental departments involved rarely have the funds to do so, and Caltrans cannot necessarily provide funding for improvements that help only one business. Various agencies including Caltrans, the counties, and municipalities have asked for the ability to request the applicant to pay for the improvements necessary for a specific route to be upgraded to the standards necessary for STAA route approval. Sometimes applicants have provided such funds. More often, the applicant refuses to do so on the grounds that the applicant and its trucker already pay fuel, property, sales and employment taxes that are supposed to fund such physical improvements. Additionally there is the consequence that the other businesses along the route gain the benefit but without the expenditure incurred by the applicant. This creates an obstacle and negative impression of the STAA process.

Commercial Considerations

Most representatives of agencies understand commercial considerations but are not allowed by law and regulation to take them into account when reviewing STAA route applications. It appears that more than anything else, it is commercial considerations that drive an applicant to make an application. Enforcement may be a motivating factor, but in the few instances where interviews have revealed a candidate’s motivation, commercial considerations dominate. Examples of commercial considerations include: the need for acquiring a facility into which to expand; a new tenant coming to town to look for a location; avoiding the need to transfer lading (shipments) from a 48- or 53-foot trailer to a smaller truck in order to access a site; household goods movers being fully exempted from having to comply with STAA route rules but not the applicant; a general lack of awareness of any actual personal injury (but not property damage) accidents having been caused by safety considerations; expansion of the criteria for denial on safety consideration to factors far beyond the operation of the truck such as neighborhood objections, etc.

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Specifying the “Last Mile”

The STAA was enacted in 1982, just after the motor carrier industry was deregulated in 1980 by an act of Congress. One of the key tenets of deregulation was to remove from the trucking industry the burden that had existing since 1935 that each and every motor carrier had to apply for each and every “route” that it intended to serve. Each state had similar laws and regulations, which were finally prohibited by the U.S. Congress in 1998 after most states had voluntarily followed the federal guidance and dropped their own requirements for route applications. A notable exception to the application for routes process prior to 1980 was for private trucking, that is, trucking operated by a business that was confined to transporting its own property. Private trucking thus had an unfair advantage over for-hire trucking.

Even during the period of heavy regulation, the routes granted by the federal and state governments were not specific highways or roadways within a given city, town or radius based on the population of the given community. Instead, for safety reasons, specific roadways that were within a community were designated by that community as “truck routes.” Also, each community understood that it did not need to specify each and every mile of street by name to each and every address where a truck might load, unload, trans-load or be domiciled. Instead, the practice, and in many cases the regulation, stated that the “last mile” was at the discretion of the driver, subject to being safe and using the most direct roadway between the designated truck route and the specific site where the truck was loaded, unloaded, trans-loaded or parked.

In contrast, the current practice in Sacramento and San Joaquin counties is to try to specify each roadway to the specific address involved in order to approve a T route. This is also the law and regulation in other California counties, although far more rarely invoked in the rest of the state. To the knowledge of those interviewed, no other state or county in the U.S. has the specificity that is being imposed in Sacramento and San Joaquin counties, or to a lesser degree in other California counties. Given this history and the observations about practices elsewhere, it is possible that many truck drivers, motor carriers, customers, and state highway officials view the existence of Section 35401.5 and the processes attendant to it as unusual and unnecessarily burdensome.

Service Routes and Interchange Status

It would be a great industry aid if there was a list of the status of each interchange on the National Network and of all STAA approved State Routes. Such a list could indicate if the interchange is an S route or not. Even more useful would be a list in geographical order of the status of all interchanges on all National Network routes and of all State Routes that are limited access freeways and approved by Caltrans. Note that such routes are not designated T routes because, as limited access routes, no service or terminal locations exist. Appendix C provides notes on the status of interchanges. Among the issues with creating such a list are:

 Not all names are consistent with the signage when approaching the interchange.

 Not all interchanges are yet numbered.

 Not all on and off ramps are designated as approved.

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 Not all off ramps in one direction are matched with an approved on ramp in the opposite direction.

 Not all on ramps in one direction are matched with an approved off ramp in the same direction.

 Not all interchanges are marked as T routes, even though theycould accommodate STAA size vehicle combinations.

 Not all interchanges are marked as S routes, even though they could accommodate STAA size vehicle combinations.

 Not all T routes go both directions on the intersecting routes.

 None of the connecting ramps between National Network roadways and/or between approved State Routes are marked as T routes even though every one of them is an STAA route.

A complete and correct list of the status of interchanges, once finished, could be added to the Caltrans website with links between them. How best to publicize the existence of the list, and how to keep it up to date are open questions. Such a publicity effort might be combined with a renewed effort to raise awareness among truck drivers and motor carrier managers of the existing STAA process and procedures.

Signage Issues

The topic of signage raised a number of issues during the study. The premise that the signs were the only, or at least the primary, method for conveying awareness of T and S routes was continuously called into question.

Signage standards are provided by Caltrans in Chapter 2D Guide Signs – conventional roads in its California Manual on Uniform Traffic Control Devices (MUTCD) manual. However, signage is not definitive or uniform because of local variations and failures. Signage:

 Often becomes more distorted the closer one gets to a specific municipality or a specific route within a county or municipality.

 Is not always provided in the reverse direction “to escape.”

 Is not always intuitive.

 Does not allow routing to the closest or next arterial that connects to the freeway.

The signs are not uniform:

 Locations are not standard.

 Use of “End” signs is confusing.

 Signs are removed during some types of road work and construction.

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The STAA signs are too easily confused with city “truck route” signage, whose purpose is different because it is applicable to far more trucks and may not designate a route that can accommodate STAA-sized trucks.

Local variations become confusing when Caltrans is not involved and its rules are not followed:

 Re-wording is excessive and confusing to drivers looking for specifics and consistency.

 Signage variations perpetuate “one off” characteristics and lack of network considerations. In one case where a network exists, the cost of the signage is too great for the municipality so it wants to use fewer signs, e.g. “just on the perimeter, not on the routes.”

 Height off the ground is not always in the driver’s line of eye sight.

 Local signage often misleads drivers for lack of uniformity in message, location, etc.

The “T” and “S” system and the blue signage are unique to California, and not consistently understood in the industry.

 Blue signs are unique to California. Blue is supposed to be informational, not for mandatory routes. Yellow advisory route signs accomplish the same thing and seem more appropriate as they are “warning” signs.

 Immediately before a connector to another T route, there is no signage indicating that the route is a connector and/or that it connects to a T route.

 After exiting on an exit ramp, there is not always a sign at the bottom of the ramp as to which direction is a T route.

 After exiting an exit ramp onto an arterial, there are supposed to be signs indicating that a T route either turns or intersects “at key decision points.” These are not always there and/or do not appear sufficiently often for each truck driver to know that he is still on the T route. Often when a sign does appear, it is at the intersection involved and does not provide sufficient notice to allow a truck driver to properly position his tractor-trailer to accomplish the turn, particularly from turning pockets.

 After exiting an exit ramp onto an arterial, there are other blue signs without the white T but that otherwise look identical to T route signs (the purpose of which is not obvious).

 Periodically there are “End” signs where a local approved T route ends because it is connecting to a National Network or a State Route which continues on as an STAA route. This gives the driver the impression that he cannot proceed because the route has “ended” when in fact the State or National portion of the STAA route is beginning.

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IX. Conclusions

Overall Conclusions

Dissatisfaction with the status, use, and planning of STAA routes was the impetus for this study, particularly in these corridors in these counties. The research team verified many of the perceived problems with STAA routes in the SACOG and SJCOG regions:

 Local STAA routes in the study region are incomplete, disconnected, poorly documented, and inadequate to support the region’s transportation needs.

 STAA vehicles are frequently and widely operated on non-STAA routes, knowingly or unknowingly.

 Most stakeholders (truckers, customers, planners, etc.) are unaware of STAA route issues, consider them peripheral to their interests, or ignore them.

 The need for widespread STAA access cannot be met by a process that requires hundreds of route-by-route and “last mile” applications and designations.

 Terminal (“T”) and Service (“S”) Route signage is no longer a practical approach to route designation or communication with truck drivers.

 Enforcement of STAA vehicle restrictions is reportedly inconsistent and uncommon, and is perceived by the industry as ineffective.

 Restricted STAA access and perceived difficulties with the application processes and enforcement may place the study region at a disadvantage for economic development.

Corridor STAA Route Status

The need for approved truck routes is growing, and it is growing faster than the rate of improvements in road quality necessary to accommodate the recent and forecast growth in the number of trucks on the roads. Various estimates at the federal level are for up to 40 percent more vehicles and 25 percent more shipments or trips in the next 10 to 20 years. Caltrans planning has forecasted traffic volumes but not for specific sub-sectors of the commercial trucking industry such as vehicles by any size or type.

Many sections of municipal roadways and State Routes cannot be upgraded to STAA standards in the short term. It will require major reconstruction of many interchanges on the National Network to bring roadways to STAA design standards. Today there is a major effort to do this on SR 99 in both counties. Four new interchanges in Elk Grove are examples, as is SR 12 at its northerly interchange with SR 99. Three new interchanges are scheduled to commence construction on SR 99 between Lathrop Road and SR 4 in San Joaquin County. A number of additional projects have been planned and are awaiting funding.

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In some cases, it may not be feasible to upgrade all county or municipal roadways, much less every State Route. For county and local roads, there is no known inventory of all of the necessary route improvements, although two communities are known to have conceptual plans if not yet designs.

Corridor STAA Vehicle Operations

The trucking industry’s practices for routing its trucks have completely changed since the time when existing STAA route information communications practices were established. Hence, the existing multi-level considerations published on the Caltrans website and implemented in various ways by local jurisdictions are an obstacle to voluntary compliance with the existing STAA application processes.

It has been 30 years since STAA vehicles were first introduced. Today, and for the foreseeable future, they will dominate commercial trucking. Hence, the processes to support them need to change. Today’s processes are not as applicant-friendly as they could be and may lead to local accommodations rather than utilization of the existing application, review, funding, and signage processes. Also, many out-of-state truckers and even truckers from other parts of California, expect to operate STAA vehicles on any route where they are not expressly prohibited by posted signs.

Frequently it appears that outes that might be STAA and/or need to be STAA approved often are not yet up to STAA standards but, nonetheless, operation of STAA sized trucks is occurring on these routes. In many cases, the operation is allowed to continue pending improvements that might be made some time in the future.

Designation Process

While valid and functional when followed, the current processes for designating STAA routes are not meeting the transportation needs of the SACOG and SJCOG regions. Specifically, reliance on the application process and signage to designate and mark routes is not tenable in an age where STAA access must become the norm for commercial, agricultural, and industrial sites.

The Caltrans process for STAA route designation, used by most jurisdictions, is well organized and well documented. Caltrans offers technical and procedural guidance to local and regional applicants. The process is well understood by the Caltrans and local personnel involved, but it is not widely known or followed by other stakeholders, resulting in a serious mismatch between designated routes and long-term needs.

The existing process is based on the negative presumption that no route is capable of safely and operationally accommodating STAA vehicles; hence, a one-at-a-time application process is in place.

Municipalities and regional planners seldom take a proactive stance to have routes in their jurisdiction designated.

More approved STAA routes are needed. However, the current process does not encourage applications, and often the most practical option is to risk a citation for a violation.

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The ability to create “local accommodations” to circumvent applications for approval of local routes also serves to question the credibility of the current regulations and processes.

Potential applicants are not motivated to apply and may also be discouraged. Avoidance of making an application has become a viable alternative when learning of the requirement. The law is clear that anyone can apply for an STAA route although among all the jurisdictions interviewed, none of those have ever taken the initiative to “apply.”

The STAA route designation process is at great variance with what has become common in the industry, particularly interregional and interstate trucking. Drivers and dispatchers obtain routes from GIS systems not paper maps or websites. They use cell phone applications and specific routing software to tell them the “practical” truck route for each address in the U.S. To be effective, any California requirement for specific STAA-designated routes and city truck routes will have to be accessible by these electronic information systems.

Unfortunately the currently designated county and municipal STAA routes are not found on any such routing systems. It does exist in some applications for State Routes so designated. It would behoove Caltrans and the counties and cities involved to assure that such systems are informed and actively using the STAA route information and data. That will require a material change in Caltrans and local jurisdiction processes, and substantial time and involvement with the providers of such software and GIS hardware. It will require a secure and timely system to catalogue every piece of such routes in a manner that is satisfactory to vendors and their motor carrier clients. To date, no one has been able to verify that any such software systems do more than account for the National Network and the approved portions of California State Route highways.

Stakeholder Perspectives

Shippers, receivers, and real estate developers are typically unaware of route designation requirements or do not consider STAA access issues their responsibility. Applicants that do seek STAA designation for specific routes are often frustrated by what they perceive as slow or arbitrary actions, and may seek intervention from local elected or non-transportation officials.

Most of the parties who should be responsible for knowing about STAA route requirements and filing applications for approval are not aware, interested, or willing. It is far easier just to operate STAA-sized tractor-trailer combinations and hope to avoid enforcement, complications on the roadways and administrative controversy.

Reverting to equipment of prior size and characteristics is not an option because customers want and need STAA-sized equipment. This is because the cost per unit handled is less with this equipment than with equipment of a smaller size. Because such equipment is not always available in the locations where it is desired, the population of such equipment is expanding and is expected to continue to expand for the foreseeable future.

The existence of the exemption for household goods carriers is, to truckers and others, counter- intuitive as there is no meaningful safety or engineering difference between moving vans and other goods carrying trailers. This serves to diminish the credibility of the regulations.

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Signage

All of the signage issues described above create consternation and an inclination to ignore the signage. Ultimately the need for signage should be minimized. The current program, were it to be more successful in designating STAA routes, would materially increase the complications with signage.

It is most likely that there would be reductions in time, confusion, frustration, and excess driving mileage if the approved route always entered/exited the nearest interchange on the National Network, was routed via the intersecting arterial to the point closest to the point of pick-up or delivery of the shipment, and then via a direct, local road to the pick-up/delivery site.

However, until all interchanges are STAA approved and all arterials that intersect the National Network are approved for their entire length, the signage considerations are likely to become more complex and confusing. The probable result is that when all interchanges and arterials are signed, the logical option would be to remove all the blue signage and replace it with the existing yellow advisory signage only for those short sections of roadways where there remains a legitimate engineering or safety reason not to approve that short section.

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X. Alternatives and Recommendation

Need for Alternatives

Since 1982, the use of STAA vehicles has changed from being the exception to becoming the norm for large portions of the trucking industry and the SACOG/SJCOG study area. While valid and functional when followed, the current processes for designating STAA routes is not meeting the transportation needs of the SACOG and SJCOG regions. In specific, reliance on the application processes and signage to designate and mark routes is not tenable in an age where STAA access must become the norm for commercial, agricultural, and industrial sites.

Shippers, receivers, and real estate developers are typically unaware of route designation requirements or do not consider STAA access issues their responsibility. Frequently out-of-state truckers expect to operate STAA vehicles on any route where they are not expressly prohibited by posted signs. Municipalities and regional planners seldom take a proactive stance to have routes in their jurisdiction designated. Applicants that do seek STAA designation for specific routes are often frustrated by what they perceive as slow or arbitrary actions, and may seek intervention from local elected or non-transportation officials. In too many cases, routine use of non-designated routes by STAA vehicles has become the most practical alternative.

The Caltrans process for STAA route designation is well organized and well documented. Caltrans offers technical and procedural guidance to local and regional applicants. The processes are well understood by the Caltrans and local personnel involved, but it is not widely known or followed by other stakeholders, resulting in a serious mismatch between designated routes and long-term needs.

The Study region appears to be an exception to national STAA practice, which in other states and counties appears far more permissive. The shortfall in STAA access and the twin problems of perceived application challenges and inconsistent traffic enforcement levels are potentially hurting the region’s prospects for economic development.

The study identified two alternatives to the current system which might achieve the desired changes and results.

Strengthening the Current Processes

If the region chooses to rely on the existing bottom-up application and designation processes for STAA routes, the processes could be strengthened in several ways:

 Additional resources on the local and regional to facilitate the process and reduce delays.

 More education and outreach to shippers, receivers, real estate developers, truckers, private fleet operators, municipal planners, and other stakeholders regarding STAA rules and designation processes.

 Expanded and improved signage to clearly designate STAA routes.

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 Development and maintenance of more comprehensive STAA route maps with easy on-line access that works well across various platforms and devices, and which can be embedded in trucking industry routing software.

 Clarification and uniform interpretation at all jurisdictional levels of STAA route engineering and safety requirements and of standard criteria for designation of Terminal Access and Service Access routes.

Specific steps could include:

 Enhancing the resources and effectiveness of the Caltrans District Truck Supervisors, and responsible local municipal staff with an education and awareness program.

 More attention to communications practices including: - Adequate and complete signage. - More concise, understandable and easy-to-navigate communications on the Caltrans website, particularly as to status of interchange ramps on the National Network and State Highway Routes. - More assistance with applications for approved routes and training/support for District and local officials. - A single source for one map covering all STAA approved routes in the state. - Prioritizing communication of newly approved routes and routing changes/detours to the current providers of routing software and routing advisory services, particularly those most commonly used by drivers and trucking company dispatchers.

It is not clear, however, whether these efforts would result in significant improvement. There are thousands of shippers, receivers, service locations, and truckers who could be involved in STAA routing but no simple or effective way to locate or reach them. There is also still no guarantee that encouraging or facilitating bottom-up initiatives will yield an adequate system of STAA routes. The need to identify “last miles” and encourage applications for appropriate designation would require substantially more resources than have typically been available or have been deemed necessary elsewhere in the country.

Proactive Planning

The potential value of a regional truck route planning and designation approach was discussed in the SACOG Phase III Goods Movement Study and is a logical alternative to the status quo. A proactive planning approach would require cooperation between local authorities, regional planning agencies, and Caltrans to:

 Identify current and expected needs for STAA truck access.

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 Determine which through-arterial routes can currently support STAA operations, and which require upgrades. Locally-designated Truck Routes must be included in this determination. Other local streets and roads would remain a local issue, except that STAA vehicles would be allowed last-mile access to trucking and customer sites (local service only signage). If there was a specific reason not to allow STAA vehicles, including those currently exempted, that impediment would have to be signed.

 Designate the eligible current segments as STAA routes, and sign and map them as required.

 Develop and implement plans to upgrade sub-standard segments to complete a coherent STAA route network and system.

A regional route planning process would require substantial time and resources. This approach would create a top-down planning process while still allowing the bottom-up application process for additions or exceptions. Steps within a proactive planning effort could include:

 Discontinuing “S” (services) routes, and incorporating them into existing T (terminal access) routes. This would include communications clarifying that “terminal” includes customer sites as well as carrier facilities.

 Separating out as a distinct category any potential “T” routes in legacy city center and intercity industrial areas, and “T” routes on parallel frontage roads and arterials.

 Continuing to allow local accommodations that meet safety standards as an interim step until necessary improvements can be funded.

 Creating projects and programs covering National Network interchanges in the state that need to be upgraded to STAA design standards.

 Incorporating improvements necessary to raise state and local routes to STAA standards in regional transportation plans, and eventually MTIPs, RTIPs and the State Transportation Improvement Program (STIP).

 Planning to close gaps in existing local “T” routes to make viable networks out of otherwise detached route segments.

 Mandating applications and approval of STAA routes as part of permitting for new industrial, office, or retail buildings, regardless of intended tenants.

 Funding improvements in “packages” of logically-networked routes presently being used by STAA trucks, without a need for individual local applications.

A particular challenge to a regional planning approach – in common with all regional planning efforts – would be reconciling the divergent and conflicting concerns of cities, counties, and other agencies and stakeholders within Caltrans eligibility rules. Jurisdictions and residents are concerned about legitimizing access for what they perceive as “large trucks” even when those

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Common Policy Issues

There are a number of issues that these alternatives all face, and which will require considerable attention in choosing a final course of action and planning for implementation.

Time and Resources. The combined SACOG and SJCOG region is a large area, with about the same acreage as the State of Massachusetts and roughly the population of Connecticut. Identifying the need for STAA routes, locating and documenting exceptions, resolving local conflicts, and signing and mapping the resulting network will require substantial time and resources under any alternative. Public agency resources are scarce under current economic conditions, and the near-term outlook is no better. SACOG and SJCOG may have to either prioritize truck route development over other needs or accept a long implementation timeframe.

Enforcement. Managing the nature and level of CHP and other enforcement activity is a key consideration. Keeping enforcement policy and practice in sync with STAA route policy and network development will be a challenge regardless of what alternative is pursued. Enforcement practices may be partially critical in any transition period between existing, restricted STAA access and possible broader access for STAA-sized vehicles in the long term.

Local Accommodations. Accommodations to local preferences and conditions are a fact of life and will remain so. Currently, local accommodations help bridge the gap between needs and available routes. In the long term, they should be less necessary, and could be revisited as needed.

Funding for Improvements. Funding for road improvements to meet STAA standards are likewise scarce under present and expected near-term conditions. Currently, depending on the repairs or reconstruction necessary for a given application to be approved, the agency will ask the applicant to pay for the cost of the necessary physical changes. This is not satisfactory for a number of reasons, the most important of which is that the applicant rarely is willing. The practice only aggravates the situation and perpetuates continued violations.

Consolidated Data and Mapping. Developing a comprehensive STAA network or documenting exceptions will require coordinating and consolidating the mapping, listing, and dissemination of route information, more standardized practices for route information, and more proactive, coordinated planning for improvements.

Signage Management. While completely consistent and comprehensive signage may be an unattainable goal, any STAA route improvement program or policy choice will require attention and resources to coordinate and maintain signage. Variations in local signage practices are confusing, especially where STAA routes do not completely coincide with local “truck routes.” Though consistent signage at STAA route “decision points” is required, local jurisdictions frequently don’t make clear that T routes continue on through intersections. During the course of this project team members and agency staff found numerous instances of missing, confusing, or inconsistent signage. A drive for more signage, however, will run up against desires for local autonomy and local resource shortfalls.

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Recommendation

It is clear from the study conclusions that the SACOG and SJCOG regions should make STAA access the norm where consistent with engineering and safety criteria, and use signage, on-line maps, and other means to identify STAA and non-STAA routes.

Now that STAA vehicles have become the norm throughout much of the trucking industry and the region, it is no longer effective to treat STAA routes as the exceptions. The status quo application, designation, and signage processes are not meeting the region’s transportation needs, and they are increasingly unlikely to do so in the future. Strengthening these processes will help, perhaps as an interim measure, but will not resolve the issues identified in the study.

Broadening STAA access and identifying exceptions can be achieved through Proactive Planning outlined above. A Proactive Planning approach may be more attainable in the near future, and is within the general purview of SACOG and SJCOG. Here, too, it would be critical to solicit the thoughts and ideas of each of the constituencies involved. The major impediments to this step may be the knowledge of stakeholders and their willingness to participate, and the risk of perpetuating “local accommodations” that are beyond the existing regulations and best practices.

A final choice between approaches will likely entail legal, technical, and policy analysis that was beyond the scope of this project, and evaluation of the related staff time and resources required. Resources to conduct these assessments and for creation of detailed action plans would have to be found. Funding is a major obstacle given current state, local, and federal budgets. To the extent that current processes could be streamlined, the resources now used in those processes could be freed up. That option, however, is not available until alternative approaches are in place.

At this point it is worthwhile reemphasizing three key findings:

 The existing processes are based on the negative presumption that a route is not capable of safely and operationally accommodating STAA vehicles, so a one-at-a- time application processes are in place for approval.

 The trucking industry’s routing practices have completely changed since the time that existing communications practices were set up. The existing multi-level considerations published on the Caltrans website, and used by Caltrans and most local jurisdictions, make voluntary compliance with the existing application processes a challenge.

 It has been 30 years since STAA vehicles were first introduced. Today, and for the foreseeable future, they will be dominant in the freight industry. The processes to support them need to change because today’s processes are perceived as not applicant-friendly and may invite local accommodations rather than utilization of the existing application, review, funding, and signage processes.

Therefore, it may be time for a change in the core presumption on which the existing STAA process is based. That change needs to support current commercial realities and practices. The

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Appendix A: Glossary

California Legal Trucks: A California Legal truck has an overall maximum length of 65 feet, and a maximum KPRA of 40 feet.

Domicile. A location at which either truck drivers and/or a piece of motor carrier equipment is assigned/based as a home base. May or may not be a terminal, as defined below.

Jurisdiction. Any of a state, a county or a municipality.

Load Board. A listing of available loads looking for a match to an available tractor, trailer and driver that can be viewed on a specific vendor’s internet site and/or monitor placed at a truck stop so that available drivers can look for possible loads to haul and/or available loads can “look for” possible drivers to haul the load that is posted.

Local Accommodation. A politically or economically justified accommodation made at the local level (city or county) to allow STAA sized vehicles outside of an official STAA route applications process. Municipality. Any legal form for an incorporated area.

National Network (aka NN). Per Section 658.5 Definitions of the Code of Federal Regulations (CFR), “The composite of the individual network of highways from each State on which vehicles authorized by the provisions of the STAA are allowed to operate. The network in each State includes the Interstate System, exclusive of those portions excepted under Section 658.11(f) or deleted under Section 658.11(d), and those portions of the Federal-aid Primary System in existence on June 1, 1991 as set out by the Federal Highway Administration (FHWA) in Appendix A to this part of the Code of Federal Regulations (CFR).”

Service Access (Route). A section of highway designated by the applicable jurisdiction as suitable for operation by vehicles of the size specified by the STAA and used to access locations that provide support to motor truck vehicles and drivers, specifically the services of food, fuel, lodging and repairs.

STAA (truck). Either of a) Surface Transportation Assistance Act of 1982 or b) A STAA truck is a truck with a 48-foot semitrailer, an unlimited overall length, and an unlimited kingpin-to- rear-axle (KPRA) distance. STAA trucks were made legal on the National Network by the 1982 federal Surface Transportation Assistance Act (STAA).

State Highway (aka SR). Roadways labeled as State Routes by the California Department of Transportation (Caltrans) that are under its jurisdiction for physical control.

Terminal. “The term terminal as used in this [federal] regulation means, at a minimum, any location where: Freight either originates, terminates, or is handled in the transportation process; or commercial motor carriers maintain operating facilities.”

Terminal Access (Route). A section of roadway designated by the applicable agency or jurisdiction as suitable for operation by vehicles of the size specified by the STAA and used to access terminals. There are both State Terminal Access (TA) routes, as well as local TA routes.

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Appendix B: Parties Interviewed

Public Agencies Caltrans District 10 Caltrans District 3 Caltrans, Traffic Data Branch CHP, Sacramento Commercial CHP, Stockton Commercial City of Elk Grove City of Escalon City of Galt City of Lathrop City of Lodi City of Manteca City of Ripon City of Sacramento City of Stockton City of Tracy City of West Sacramento City of Woodland Federal Highway Administration, CA Division Port of Stockton Port of West Sacramento SACOG SACOG Goods Movement Task Force Sacramento County Airport System Sacramento County Sheriff Sacramento County Public Works Department San Joaquin County Public Works Department San Joaquin Valley Air Pollution Control District SJCOG SJCOG, Goods Movement Task Force Stockton Metropolitan Airport

Trade Associations Agricultural Transportation Coalition Sacramento Chamber of Commerce Greater Stockton Chamber of Commerce

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Sacramento Area Commerce and Trade Organization Sacramento Metro Chamber of Commerce San Joaquin Farm Bureau San Joaquin Partnership Valley Vision

Motor Carrier Trade Associations American Trucking Associations Arizona Trucking Association Arkansas Trucking Association California Trucking Association Illinois Trucking Association Maryland Trucking Association Montana Trucking Association Nevada Trucking Association North Carolina Trucking Association South Carolina Trucking Association Tennessee Trucking Association Washington Trucking Association Wyoming Trucking Association

Commercial Motor Carriers, California-Based Ability Tri-Modal AC Trucking Alto Systems Apex Logistics Britton Trucking C.D. Matthes C.R. England Certified Freight Logistics Charles Diaz Trucking C-Line CPS Express CTP Transport FedEx Corporation FedEx Freight Knight Transportation Mountain Valley Express Quikway Trucking Roadstar Trucking

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Rocha Transportation Swift Transportation System Transport Ted's Food Service UPS Freight UPS Ground, West Wallace Cascade Wal-Mart Yandell Trucking

Suppliers and Others BNSF Railway Delta Truck Center Navteq ProMiles Qualcomm Rand McNally TeleTrac Union Pacific Railroad

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Appendix C: Status of Ramps and Intersecting Roadways at Interchanges

This document depicts the status of interchanges on the highways in the I-5 and SR 99 corridors that are in Sacramento and San Joaquin Counties that are on approved STAA routes. All of these routes are limited access freeways. STAA-sized vehicles are approved on these routes in their entirety because they are either National Network routes or State Highway routes on which STAA sized vehicles have been approved for operation on the main line but not all ramps serving as connectors to the intersection and paralleling roadways. Routes are listed with east- west routes following I-5 and SR 99. Routes are directional and data is as of June 1, 2012 as approved by Caltrans Districts 3 (for Sacramento and Yolo Counties) and District 10 for San Joaquin County.

The purpose of this list is to provide something “driver friendly” as the truck driver approaches an exit or entrance.

For this list to be kept up to date requires the cooperation of the two Caltrans Districts. It could be made even more accurate by recording the status of each ramp (off or on) at each interchange and by adding the interchange number (mileage marker).

If an interchange was under construction at the time of this inventory, and some were, the status indicated here is deemed accurate but might not have been physically verified due to the “T” and/or “S” signs having been removed because of the construction.

“No” means that the ramp(s) is/are not authorized even if the cross street at the end of the ramp is signed, hence authorized. Also, ramps from one STAA freeway to another STAA freeway are usually not signed but are authorized and some have signage. The status information is oriented to exiting from the STAA expressway route, but it is also necessary to insert the data about on ramps entering onto the route, if and when the status is different from the corresponding off ramp. Data about the directionality (if any) of an already authorized route at the end of each off ramp is intentionally not included herein. Instead, this is intended to be an inventory of interchanges that are up to STAA standards so that they can be presumed to be qualified when an application is received for approval of a new STAA route that connects to the National Network at each such intersection. If an interchange or ramp is not yet up to STAA design standards, it is necessary for an applicant for approval and the jurisdiction handling the approval request to involve the applicable Caltrans District Office.

East-West Routes

Eastbound I-205 from I-580: Authorized Ramp (S, T, No)

Contra Costs/San Joaquin county line

1. Mountain House T 2. West 11th Street No 3. Grant Line Road No 4. Tracy Blvd No

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5. MacArthur Drive T 6. I-5 Northbound T

Westbound I-205 from I-5 SB: Authorized Ramp (S, T, No)

1. MacArthur T 2. Tracy Blvd. No 3. Grant Line Road No 4. Mountain House T

San Joaquin/Contra Costa county line

Eastbound SR 120 from I-5: Authorized Ramp (S, T, No)

1. Guthmiller/Yosemite No 2. Airport Way No 3. Union Road No 4. Main Street T 5. SR 99 – northbound/southbound T

Westbound SR 120 from SR 99: Authorized Ramp( S, T, No)

1. Main Street T 2. Union Road No 3. Airport Way No 4. Guthmiller/Yosemite No 5. Southbound I-5 T

Eastbound SR 4 Fresno to SR 99: Authorized Ramp (S, T, No)

1. Fresno St on ramp No 2. I-5 southbound T 3. I-5 northbound T 4. Lincoln No 5. El Dorado/Center No 6. Stanislaus (66) No 7. Wilson Way (67) No 8. Filbert Street No 9. SR 99 – southbound T 10. SR 99 – northbound T

Westbound SR 4 SR 99 to Fresno: Authorized Ramp (S, T, No)

1. Filbert No 2. Wilson No 3. Stanislaus No 4. El Dorado/Center No 5. I-5 northbound T 6. I-5 southbound T 7. Fresno Street No

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Eastbound I-80 thence Business I-80 (aka SR99, in part) thence USH 50 Yolo Causeway to Sunrise:

Authorized Ramp (S, T, No)

1. West Capitol/Enterprise T and S 2. I-80 Eastbound T 3. Harbor Blvd. T and S 4. Jefferson Blvd./275 No 5. I-5 Southbound T 6. I-5 Northbound T 7. X Street (only from I-5 SB) No 8. Broadway (only from I-5 SB) No 9. 15th Street No 10. USH 99 northbound T 11. USH 99 southbound T 12. 34th Street No 13. 59th Street No 14. Howe/Power Inn T 15. Watt No 16. Bradshaw No 17. Mather T 18. Zinfandel No 19. Sunrise T

Westbound USH 50, thence Business I-80 (aka SR99, in part), thence I-80 between Sunrise and Yolo Causeway:

Authorized Ramp(S, T, No)

1. Zinfandel No 2. Mather T 3. Bradshaw No 4. Power Inn/Watt No 5. Howe T 6. 65th Street No 7. 59th Street No 8. Stockton Blvd. No 9. 34th Street No 10. 26th Street No 11. I-80 Business northbound T 12. SR 99 southbound T 13. 16th Street No 14. 10th Street (exit only) No 15. I-5 northbound T 16. Q Street No 17. I-5 southbound T 18. River Road/Jefferson No 19. Harbor Blvd. T and S 20. I-80 eastbound T

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21. I-80 westbound T 22. West Capitol/Enterprise T and S

North-South Routes

SR 99 Northbound: Authorized Ramp (S, T, No)

San Joaquin/Stanislaus county line

1. 2nd Street/Main Street No 2. Milgeo Road T and S 3. Jack Tone/Colony Road T 4. Austin Road No 5. SR 120 west T 6. Yosemite (SR 120 east) T 7. Lathrop Road No 8. French Camp Road No 9. Frontage Exit No 10. Arch Road T 11. Clark No 12. Mariposa Road T 13. Farmington Road T 14. MLK/Main Street No 15. SR 4 T 16. Fremont, first exit (SR26) T 17. Fremont, second exit (SR26) T 18. (SR88) T 19. Cherokee Road T 20. Hammer Lane No 21. Morada No 22. 8 Mile Road No 23. Armstrong No 24. Harney No 25. Cherokee Lane No 26. Kettleman (SR 12 West) T 27. Victor (SR 12 East) No 28. Turner Road No 29. Acampo Road No 30. Woodbridge T 31. Acampo No 32. Peltier No 33. Jahant T 34. Collier No 35. Liberty No

Sacramento/San Joaquin county line

36. Crystal Way No

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37. Boessow No 38. Simmerhorn No 39. Ayers Lane No 40. Walnut No 41. Twin Cities (E13/SR 104) No 42. Mingo No 43. Arno No 44. Dillard No 45. Grant Line/Kammerer (E2) No 46. Elk Grove Blvd. No 47. Laguna/Bond No 48. Sheldon No 49. Consumes River/Calvine No 50. Stockton/Mack (NB exit) T 51. Florin T 52. 47th Street T 53. MLK/Fruitridge No 54. 12th Street/Sutterville No 55. Broadway No 56. Business I-80 eastbound T 57. USH 50 eastbound T 58. Business I-80 westbound T

See Business I-80 EB and I-5 NB

59. Elkhorn No 60. Elverta No

Sacramento/Sutter county line

SR 99 Southbound: Authorized Ramp (S, T, No)

Sacramento/Sutter county line

1. Elverta No 2. Elkhorn No

See I-5 southbound See Business I-80 eastbound

3. SR 99 southbound T 4. 12th Street No 5. Fruitridge No 6. 47th Street No 7. Florin No 8. Mack/Bruceville T 9. Consumes River/Calvine No 10. Sheldon No 11. Laguna/Bond No

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12. Elk Grove Blvd No 13. Grant Line/Kemmerer (E2) No 14. Eschinger No 15. Dillard No 16. Arno No 17. West Stockton Blvd. No 18. Twin Cities (E13/SR 140) T 19. Walnut No 20. Simmerhorn/Pringle No 21. Bosseo/Crystal Way No

Sacramento/San Joaquin county line

22. Liberty No 23. Collier No 24. Jahant T 25. Peltier No 26. Frontage Road No 27. Woodbridge T 28. Turner Road T 29. Victor (SR 12 East) T 30. Kettleman (SR 12 West) T 31. Harney No 32. Armstrong No 33. 8 Mile Road No 34. Morada No 35. Hammer Lane No 36. North Wilson Way (SB only) T 37. Cherokee Road T 38. Waterloo Road T 39. Fremont (SR 26) T 40. SR 4 westbound T 41. MLK (SR 26) T 42. Farmington Road (SR 4) No 43. Mariposa Road No 44. Arch Road T 45. Exit to Frontage Road No 46. French Camp Road No 47. Lathrop Road No 48. Main Street No 49. Yosemite (SR 120 east) T 50. SR 120 westbound T 51. Austin/Moffatt Road No 52. Jack Tone Road T 53. 2nd Street No

San Joaquin/Stanislaus county line

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I-5 Northbound

San Joaquin/Stanislaus county line

1. I-580 NB No 2. SR 132 T 3. Lehman/Ahern SR 33 No 4. Kasson No 5. Mossdale Road (460) No 6. SR 120 eastbound (461) T 7. Louise (462) T 8. Lathrop Road (463) T 9. Roth Road (465) T 10. El Dorado (467A) No 11. Matthews (467B) No 12. French Camp Road (468) No 13. Downing (469) No 14. 8th Street (470) No 15. Charter Way/MLK Blvd. (471) T 16. SR 4 – eastbound (472 NM) T 17. SR 4 – westbound (NM) T 18. Pershing No 19. Monte/Diablo No 20. Country Club Blvd/Alpine No 21. March Lane No 22. Benjamin Holt Drive No 23. Hammer Lane No 24. 8 Mile Road T and S 25. SR 12 T 26. Turner Road No 27. Peltier Road (J12) No 28. Walnut Grove T 29. Twin Cities Road No

Sacramento/San Joaquin county line

30. Hood-Franklin No 31. Elk Grove Blvd. No 32. Laguna T 33. Meadowview (SR 160) No 34. Florin Road No 35. Seamus/Fruitridge No 36. Sutterville Road No 37. USH 50 eastbound No 38. USH 50 westbound No 39. Q Street (exit only) No 40. J Street (exit only) No 41. Richards Blvd. No

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42. Garden Highway No 43. El Camino No 44. I-80 eastbound T 45. I-80 westbound T 46. Arena No 47. Del Paso No 48. SR 99 northbound T 49. Power Line Road No 50. Sacramento Intl. Airport No

Sacramento/Yolo county line

51. CR 18/22/Old River Road No 52. CR 102 T 53. Main Street No 54. 55. East Street T and S 56. West Street, Woodland No

I-5 Southbound: Authorized Ramp(S, T, No)

1. West Street, Woodland No 2. East Street T and S 3. SR 113 No 4. 5. CR 102 T 6. CR 18/22/Old River Road No

Yolo/Sacramento county line

7. Sacramento Intl Airport No 8. Power Line Road No 9. SR 99 northbound T 10. Del Paso No 11. Arena No 12. I-80 westbound T 13. I-80 eastbound T 14. Garden Highway No 15. Richards Blvd. No 16. J Street No 17. Business I-80 westbound T 18. Business I-80 eastbound T 19. Sutterville Road No 20. Seamus/Fruitridge No 21. Riverside/43th No 22. Florin No 23. Meadowview/Pocket No 24. Laguna T

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25. Elk Grove Blvd. No 26. Hood Franklin No 27. Twin Cities Road (E13) No

Sacramento/San Joaquin county line

28. Walnut Grove Road (J11/8) T 29. Peltier Road (J12) No 30. Turner Road No 31. SR 12 T and S 32. 8 Mile Road T 33. Hammer Lane No 34. Benjamin Holt Drive No 35. March Lane No 36. Alpine Avenue No 37. Country Club Blvd. No 38. Monte/Diablo No 39. Pershing No 40. Charter Way T 41. 8th Street No 42. Downing No 43. French Camp (J9) No 44. Mathews Road No 45. Roth T 46. Lathrop No 47. Louise T Note #5 48. SR 120 eastbound T Note #1 49. Manthey Road No 50. I-205 westbound T 51. West 1st Street No 52. Kasson Road No 53. Lehman/Ahern Road (SR 33) No 54. Vernalis/Ohm Road (SR132) T

San Joaquin/Stanislaus county line

I-580 North and Southbound:

The section of this highway from the San Joaquin-Stanislaus county line just south of the junction of I-580 and I-5 (Exit 446) to the San Joaquin-Contra Costa county line just south of the junction of I-580 and I-205 (Exit 60) is in the study area but while it is in the I-5 corridor and in San Joaquin County, it is excluded from the study report because the nature of the STAA truck traffic on this section of roadway is not materially related to the topic of this study.

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Appendix D: Suggested STAA Routes

Over the course of gathering data, many parties suggested routes that either have known issues that need to be clarified or are routes where 53-foot trailers are observed frequently. Below is a list of such issues and suggestions. It is organized by Caltrans District, which is consistent with the two counties. Ideas and suggestions involving District 3 (Sacramento and Yolo Counties) are in the first section, regardless of the affiliation of the parties making the suggestion. In the second section are the ideas and suggestions involving District 10 (San Joaquin County), again regardless of the affiliation of the parties making the suggestions. Likely there are additional suggestions, or they will be forthcoming. This list if perpetuated by each county and each Council of Governments can become a master “check list” of ideas, possibilities and existing complications. All of this is by geography, not topic, status or cause.

District 3 (Sacramento/Yolo Counties)

1. Lack of adequate turning radii and/or turnarounds in:

a. Northeast Sacramento on existing T routes

b. West Sacramento on E and F Streets

2. Lack of T routes in areas where new development is occurring.

3. Lack of T routes where they have been requested but denied:

a. SR 160 from north via Freeport Road continuing as River Road, near Clarksburg; this may be a physical impossibility.

4. Lack of T routes as compared to where STAA trucks are appearing, e.g.:

a. Surrounding, east and south of McClellan Airport (which is out of scope due to distance from SR 99).

b. Same at Mather Field, but that is out of scope due to distance to SR-99.

c. Central southern Sacramento County.

d. In and out of Sacramento International Airport.

e. Around Richards Blvd and 12th Street just north of downtown; including new Rail Yard development project.

f. SR 160 including connecting to I-5 via Richards Blvd. and to city center one way streets.

g. Truck routes in Woodland city center.

5. Lack of T route access

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a. To/from I-5 at:

i. Roads north of I-80; Elkhorn Road, Del Paso, Arena Blvd.

ii. Twin Cities Road; see note re US 99; good spot for permit loads and parking, but there is nothing available.

iii. Hood Franklin; major issues; CHP expressed frustration here.

iv. Laguna with its unique variation on “T” signs but no “T” sign southbound on I-5 Meadowview/Pocket: need review due to “big box” store nearby.

v. Richards; being rebuilt to STAA standard; open as of June 2012.

vi. Del Paso; needs an evaluation, and has network considerations.

b. To/from SR 99 at:

i. Stockton Blvd/ Mack Road/ Elsie

ii. Cosumnes; new big box stores here

iii. Sheldon Laguna/Bond; should be

iv. Elk Grove has new interchange ramps at Calvine (which really is in the County), Sheldon, Elk Grove Blvd., and Grant Line.

v. Twin Cities as preferred detour route; needs improvements; traffic circle is being planned; does that meet STAA design standards

vi. Elverta; possible; new interchange planned

vii. Elkhorn; possible, but in Sutter County; hence out of study corridor

c. All of Franklin Blvd. as an alternate to I-99 plus local commerce including along the UP right-of-way west of Franklin. Includes several possible lateral arterials to/from I-99

d. In West Sacramento

i. To/from Business I-80 at first exit west of Sacramento River (Jefferson Blvd., Park Blvd, South River Road, and Riske Lane to Delta Lane and Capitol Ave.)

ii. West Capitol between Enterprise and Harbor Blvd.

iii. Reed off of I-80

iv. No access to SR 275 from Jefferson

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6. Confusion over ever-changing city limits of Sacramento, Sacramento County, and Elk Grove

District 10 (San Joaquin County)

1. In Tracy where City wants them; has 10 as possibilities:

a. at top of list is Pescadero and Paradise, connecting to MacArthur and I-205 to north and to Grant Line to east to I-5

b. and, in the same vicinity, to/from I-205:

i. Eastbound at MacArthur

ii. Northbound at MacArthur

iii. Both directions at Grant Line

iv. Eastbound at 11th Street

2. In and surrounding Stockton/Lathrop:

a. Pending projects at:

i. SR 99 at MLK, Farmington; a complete re-routing and new interchange

ii. SR 99 at French Camp and Lathrop to rebuild interchange

b. Connecting French Camp to Sperry/Arch with an overpass over UPRR

c. Connection SR 4 to Fresno, Washington, and Navy Drive

d. Frontage Roads along I-5:

i. Manthey on the west side of I-5 between I-5 and French Camp

ii. Harlan on the east side along I-5 between SR 120 and French Camp; particularly as the route is already both a T and S route for a portion of the route

3. Many gaps and discontinuities between routes authorized by separate jurisdictions; Airport Road south of French Camp is prime example

4. Counter-intuitive circuitry:

i. Exit from United Grocers off of Waterloo Road (SR 88)

ii. Access to Spreckels via Yosemite and not Moffett

iii. UPRR Lathrop ramp to/from points north of Roth and east of Airport

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iv. Stockton Airport access

v. Lack of access to city center and industrial area east thereof from SR 4

5. Places where 53’ trailers are sighted often in Stockton and south county but are not T routes:

a. Liberty Road: Between SR-99 and SR-88 b. Peltier Road: Between I-5 and SR-99 c. Turner Road: Between I-5 and May Road d. Thornton Road: Between Walnut Grove Road and Kyle Road e. Thornton Road: Between Peltier Road and Kyle Road f. Thornton Road: Between Turner Road and Flying J g. SR-99 on/off ramps: At Victor Road (SR-12) h. Kettleman Road: Between SR-99 and SR-88 i. Harney Lane: W/ and E/ of SR-99 j. SR-99 Frontage Roads: S/ of Eight Mile Road k. Fine Road: Between Flood Road and Copperopolis Road l. Mariposa Road: Between Carpenter Road and Escalon Bellotta Road m. Escalon Bellotta Road: Between SR-26 and SR-120 n. McHenry Road: Between SR-120 and S/ of East River Road o. French Camp Road: E/ of SR-99 and SR-120 p. Airport Way: Between French Camp Road and SR-120 q. McKinley Road: Between French Camp Road and El Dorado Road r. El Dorado Road: Between I-5 and McKinley Road s. Moffat Blvd: Between Spreckels Ave and SR-99 t. Linne Road: Bird Rd to Corral Hollow u. Macarthur Blvd: from Linne Rd N to 11th St v. Bird Road: From Linne N to Grant Line Rd w. Chrisman: from 132 N to 11th St. x. Tracy Blvd: from Linne Rd to 205 y. Tracy Blvd: from 205 N to Sugar Rd z. Corral Hollow: from Linne to N of Valpico Rd aa. Valpico Road: Corral Hollow W to Lammers Rd bb. Schulte Road: W to Lammers Rd. cc. Schulte Road: from Lammers Rd to W of Hansen Rd (Safeway Entrance) dd. Byron Rd North: from Lammers Rd to Alameda County Line ee. Mountain House Pkwy: from 205 E to Byron Rd. ff. SR-4: from Discovery Bay to Port of Stockton Expressway gg. Pescadero: E of Macarthur Blvd. hh. Grant Line Road: from Byron Rd East to 11th St. ii. Paradise: north and south of Grant Line Rd. jj. 11th St: from I-5 to Tracy city limits kk. Valpico: east of Corral Hollow to Chrisman Rd

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