DOT feedback Re: weight, CDL, and registration

[OMSK]

Since theres always questions about registration/CDL/etc, I thought I would post the content of several e-mails between me and PennDots help center. I am purchasing a deckover equipment trailer and wanted to be sure I was as legal as possible, if nothing else I now have documentation from the state should there be a question on the road. A copy of this will be with me at all times [img]/ubbthreads/images/graemlins/rolleyes.gif[/img]

What is most interesting to me is the info regarding the CDL, especially after I made it clear that there would be some commercial use of this rig.



From: MelissaNGregg@Comcast.net [mailto:MelissaNGregg@Comcast.net]
Sent: Monday, February 06, 2006 12:38 AM
To: customerservice@dot.state.pa.us
Cc: MelissaNGregg@Comcast.net
Subject: Truck/Trailer Registration

Message: I have a 2001 Ford F350 Superduty (VIN entered above)currently registered at 11,500lbs. I intend to use this truck to tow a 14,000lb trailer, primarilly for moving a small backhoe and agricultural tractor. This equipment would be moved in the course of off-farm sublet business or to and from repair facilities, as well as possible transport to and from shows. The trailer may also be called into use to transport agricultural equipment purchased from out-of-county, or out-of-state.
I have spoken with several tag services, several State Police officers, and the Vehicle Inspection Officer at the Skippack State Police Barracks. I have yet to receive the same information from any two sources...
I need to know how to register the trailer and the truck. I have been told that even though the trailer will be registered at 14,000lbs gross weight that the truck must also be registered at high enough weight to cover the Combined Gross Weight of both the truck and trailer - in this case approx 22,000lbs. I have also been told that the truck will then require "combination" tags, and semi-annual inspection. Considering that the trailer will only be used a few times a year, and mostly locally, this seems a bit excessive (and unreasonably expensive). I have also been told that the trailer could be registered with "farm use" tags, and thereby side-step the expense issue. This doesn't make sense either as everything I can find related to "farm-use" doesn't apply to trailers, and restricts the
location and/or time of day for use.
Please outline the proper registrations, required forms, and any other
information needed to keep these vehicles legal. Also, I currently have a CDL, but there is some question wether or not a CDL is needed to operate this combination - if so please include that info so that I don't mistakenly allow a non-CDL driver to operate it. Several of our local police jurisdictions have taken to using truck enforcement issues to increase their income - while I applaud the efforts for safer roads I certainly don't want to become an unwitting contributor!
Thank you for your assistance in this matter.



From: "Penndot" <Penndot@acs-inc.com>
To: <MelissaNGregg@Comcast.net>
Sent: Thursday, February 09, 2006 11:19 AM
Subject: RE: Truck/Trailer Registration

Thank you for contacting Driver and Vehicle Services.

To register this truck with a combination weight, you would need to
calculate the total weight of the trailer combined with the GVW of the
truck. The total combination would then be listed as your GCWT. According to your email below it would total approximately 25,000 lbs. This would then place your truck in the Class 8 registration.
To add the combination weight to your vehicle, please complete form MV-41. This form may be downloaded from our website, or may be obtained from a notary messenger service, or automobile club in Pennsylvania (PA). Please refer to the form for additional instructions. From the time we receive your application, please allow 16 days for receipt of an updated registration card.
For further information on inspection requirements, please contact our
Safety Inspection Unit at 717-787-2895.

With regards to your CDL, the truck does not fall under a CDL classification.

Thank you for your inquiry,
Hilary Baxter
PA Department of Transportation
www.dmv.state.pa.us



From: Gregg Morrison [mailto:MelissaNGregg@comcast.net]
Sent: Monday, March 06, 2006 6:37 AM
To: Penndot
Subject: Re: Truck/Trailer Registration

Thank you for the information - but there are a few things I would like to clarify.

Some of the trailer manufacturers I have spoken with have recommended a trailer with a third axle, giving it a maximum GWR of 21,000lbs. Since I don't anticipate hauling quite that heavy, and to avoid a change in weight class above class 8, I have been told I can register the truck as a class 8 giving a maximum CGWR of 26,000lbs -essentially underrating the trailer but keeping me below CDL. My understanding is that so long as I don't scale over the registered weight this would be correct - true?

Looking at the registration charts, it appears the trailer could be
registered with a permanent tag - is this correct? (I'd love that - less to remember every year)

And last - your prior response indicated that this combination would NOT require a CDL (even though the trailer is over 10,001 lbs). Since we plan to letter the F350 for the farm (every little bit of advertising helps) I am concerned that some of the local police might consider it a commercial vehicle. Please also note that there is the possibility that some of the equipment moving would be for farm related work - field work on rented ground, or paid work such as mowing or excavation. Could you clarify this issue to keep me out of trouble - thanks.

Thank you very much for your time and assistance with this issue.

Gregg Morrison




Thank you for contacting us again.

Regarding the registration of the trailer, you are correct in stating that you are ok to register the trailer at a lower weight than the manufacture specifies it can carry. As long as you do not exceed the weight in which you register the trailer you would not be in trouble with the registration.

You may apply for permanent registration on this trailer since it is over 10,001 lbs.

With regards to the license, regardless of the weight of the trailer, as long as the vehicle towing the trailer does not exceed 26,001 lbs you will not need a Commercial Driver License.

Please feel free to contact us again if you have further questions or
concerns.

When responding, please include all previous e-mail.

Thank you for your inquiry,
Hilary Baxter
PA Department of Transportation
www.dmv.state.pa.us


I hope that this is more helpful than confusing.... [img]/ubbthreads/images/graemlins/biggrin.gif[/img]

Gregg

[BadInfluence]

[ QUOTE ]
With regards to the license, regardless of the weight of the trailer, as long as the vehicle towing the trailer does not exceed 26,001 lbs you will not need a Commercial Driver License.


[/ QUOTE ]

So long as the vehicle towing the trailer does not exceed 26,001 lbs . . . interesting. Not a GCWR, but a GVW is implied (not even GVWR, just actual weight).

ONly applicable in PA, of course, but very interesting none the less. Thanks for posting.

[Halfnut]

FWIW, I spent quite a bit of time chasing the answer to that question a few years ago, and I'm also in PA. I found it amazing how many different answers I got from 'knowlegeable people' in positions of authority. That woman may be right or wrong, but I know that if you get stopped by a motor carrier enforcement officer, and your truck and trailer GVWs add up to more than 26K, he will want to see your Class A CDL, and will take you out of service if you don't have it. Then it's up to you to fight the fine in court.

The registration people don't seem to know all about driver licensing regs. For the straight scoop get the phone number for the scale house in Avondale PA from your local state police and ask the officers there what they require when you go over their scale. I believe that's the only permanent scale near you, perhaps the only one in PA. Everything that officer there told me eventually turned out to be accurate under the scrutiny of time on the road.

[Dr.Evil]

I'm going to kindly disagree here. I think the DOT Gal is correct. DOT Cops, State Troopers, etc. could care less what Your truck or trailer is RATED by the manufacturer to carry and ONLY care about what it's licensed & registered to carry, AND what it actually scales out at. In My short 5-6 year driving carreer running 10, 14, & 18 wheelers in eight midwestern states I NEVER had a Cop look at the rating plates on ANY piece of road equip. But they ALL cared what the license was good for and what their scale said. You may find Local Cops who are clueless on these things and will hassle You to no end....That's just BAD luck and should be easily dismissed.

[mndorf]

Fascinating response from PA DOT. US DOT is the minimum stringent, and states cannot be less so. As far as US DOT, (I thought..) the truck GCVW and Trailer will be separate GVW but the combined will be the 26K barrier for our type of vehicles doing personal use. How they are calculating this in PA, talk about confusing. To say nothing of the "commercial not needing DOT".

I wonder if there is a second (ha ha) opinion in PA DOT. In the old days, for the trucking industry, a Class 8 truck were the big ones with a GVW of over 33K. A Ford 350 would be a Class 2 or so.

The manufacturer's designed GVW is what the regulations look for, from what I've seen and heard. I can imagine (but can't take the chance) that this would rarely be checked on an inspection unless they called in the title info.

Good luck and just how/why are the PA rules so mixed?

[OMSK]

Yes, there is quite a bit of confusion in PA, even more than other states it seems. Thats why I sent these e-mails - even if there is some room for disagreement over the stated information, at least I have documentation of my efforts to be compliant. As far as the CDL issue, I have a class A CDL so I'm not concerned about me, and it is unlikely that I would ever have a non-CDL driver in this rig, but I wanted to ask just to see what the response was.

I have considered running these same questions, or perhaps this whole exchange, past some of the other state/DOT information sources. Of course if I do that I may simply find myself back in the forest looking for trees [img]/ubbthreads/images/graemlins/rolleyes.gif[/img] [img]/ubbthreads/images/graemlins/confused.gif[/img]

For now I'll probably stick with what I have. This is all assuming I can get the required paperwork processed without having to rewrite the entire Motor Vehicle Code.

Gregg

[j_apetersen]

I think you had better read the site the clerk gave you in refferance to cdl. You stated that your primary reason was to haul backhoe and farm machinery. So I read it were it needs a CDL. when hauling Backhoes and farm machinery.

[psy999]

"With regards to the license, regardless of the weight of the trailer, as long as the vehicle towing the trailer does not exceed 26,001 lbs you will not need a Commercial Driver License. "

Sigh, I'm sure she just made an honest mistake but I'd hate to be the person driving a truck/trailer combination rated over 26,001 who has to explain to police why he doesn't need a CDL.

My personal experiences with DMV and DOT over registration and licensing are pretty similar.

[Diesel4E]

In NJ I got the same response from the DMV. My truck 11,400Lbs. GVW, trailer 12,000 Lbs. GVW so GCVW 23,400 Lbs. and I asked if I needed a cdl and their answer was the same as you got. As long as truck and trailer GCVW dont go over 26,000lbs. no cdl needed.

[CompuDoc]

[ QUOTE ]
In NJ I got the same response from the DMV. My truck 11,400Lbs. GVW, trailer 12,000 Lbs. GVW so GCVW 23,400 Lbs. and I asked if I needed a cdl and their answer was the same as you got. As long as truck and trailer GCVW dont go over 26,000lbs. no cdl needed.

[/ QUOTE ]

The way I am reading it the GCVWR is not even considered in NJ.

Here is where I am reading it.

The way I am reading this is I do not need a CDL to tow my trailer of 10,400GVWR with my truck that has an 11,000GVWR because the GVWR of the tow vehicle is not 26,001GVWR or higher.

I am also reading it as if I had my 10,400GVWR trailer hitched to a truck that had a GVWR of 26,001 or more pounds I would need a class A cdl and if the tow vehicle has a gvwr of 26,001 or more pounds and the trailer had a GVWR of 10,000 or less I would only need a class B CDL of which I have.

[j_apetersen]

[ QUOTE ]
[ QUOTE ]
In NJ I got the same response from the DMV. My truck 11,400Lbs. GVW, trailer 12,000 Lbs. GVW so GCVW 23,400 Lbs. and I asked if I needed a cdl and their answer was the same as you got. As long as truck and trailer GCVW dont go over 26,000lbs. no cdl needed.

[/ QUOTE ]

The way I am reading it the GCVWR is not even considered in NJ.

Here is where I am reading it.

The way I am reading this is I do not need a CDL to tow my trailer of 10,400GVWR with my truck that has an 11,000GVWR because the GVWR of the tow vehicle is not 26,001GVWR or higher.

I am also reading it as if I had my 10,400GVWR trailer hitched to a truck that had a GVWR of 26,001 or more pounds I would need a class A cdl and if the tow vehicle has a gvwr of 26,001 or more pounds and the trailer had a GVWR of 10,000 or less I would only need a class B CDL of which I have.

[/ QUOTE ]

I think someone better read their post and the dmv. If the trailer is under 10000 you need a class B if the trailer is over 10000 then you need a class A CDL. You stated my truck 11400, trailer 12000. so is 12000 greater than or less than 10000.Is 10400 greater than 10000 or less than. this mew math is killin me.

[Diesel4E]

I just double check my email to the DMV and what I said in my post is correct. As long as my gross combine vehicle weight is under 26,000 lbs. I don't need a cdl.

[CompuDoc]

[/ QUOTE ]I think someone better read their post and the dmv. If the trailer is under 10000 you need a class B if the trailer is over 10000 then you need a class A CDL. You stated my truck 11400, trailer 12000. so is 12000 greater than or less than 10000.Is 10400 greater than 10000 or less than. this mew math is killin me.

[/ QUOTE ]

If the trailer is over 10,000 you do need a class A CDL in that statement you are partially correct. The part you forgot though is the tow vehicle has to be rated for 26,001 pounds or more GVWR.

Therefore if I am driving a vehicle that has a GVWR of 26,000 pounds or less I do not need a CDL of any class even if I am towing a trailer that has a GVWR of 10,000 pounds or more.

As I stated earlier if I was to hitch my 10,400 GVWR trailer to my work truck then I would need a class A cdl because the work truck has a GVWR of 32,800. Being that my private truck has a GVWR of 11,000 I do not need a CDL even if my 10,400GVWR trailer is hitched to it.

So what are the laws in Texas?

[Leader]

Doc... I read this differant then you do.

"any truck and trailer with a gross combination weight rating (GCWR) of 26,001 or more pounds, provided the GVWR of the vehicle being towed is more than 10,000 pounds"

If the truck is 26000 GVW and trailer is 9999 GVW then no CDL but if truck is 8800 GVW & trailer is 17201 GVW then you do need a class A CDL.
Like most people here.. I could still be reading that wrong but... that's how I see it.

[j_apetersen]

[ QUOTE ]
I just double check my email to the DMV and what I said in my post is correct. As long as my gross combine vehicle weight is under 26,000 lbs. I don't need a cdl.

[/ QUOTE ]

As long as the trailer is not over 10000 [img]/ubbthreads/images/graemlins/shrug.gif[/img]