Public transit buses are operated on the Interstate System in all major markets. The amount of service on the Interstate varies from jurisdiction to jurisdiction based on service area, route structure and other operating considerations. In many jurisdictions, the buses operated on the Interstate System are express buses and do not, in fact, have standees.

As mentioned above, the inclusion of additional mandatory equipment to comply with various Federal statutes has significantly added to the weight and the costs of the standard public transit bus.

It is estimated that a front door lift (complying with the Americans with Disabilities Act (ADA) requirements), complete with motors and controls, weighs 1,200 pounds and adds approximately $20,000 to the cost of a transit bus. Ninety percent of the weight of the front door lift is carried on the front axle. Approximately 300 pounds additional weight is represented by the inclusion of wheelchair securement systems, flip-seat assemblies, and seat-belt/tie-downs and storage compartment for such equipment. It is also expected that other ADA requirements such as larger diameter handrails, larger destination signs, and public address and annunciator systems will add several hundred pounds.

To comply with Clean Air Act requirements, it is estimated that a particulate trap weighs 200-300 pounds and is carried by the rear axle of the bus. The cost is approximately $10,000 per bus for the trap and the electronic controls. Alternative fuel vehicles are still in the developmental stage, but it is estimated that an additional 3,000 pounds in weight could be added, for example, if compressed natural gas were used as the fuel (including tanks, piping, etc.).

Designing public transit buses to meet the current 20,000 pound single axle weight limit would reduce the transit riding capacity of vehicles. Additional vehicles would then be required to handle such passenger loads. In theory this could increase wear and tear on highways because of the increase in the number of public transit buses using the highways.

The additional buses would not be necessary for increased ridership, but because of design limitations to meet the Federal requirements. Operating and replacement costs of existing vehicles would correspondingly increase in order to meet just current capacity, not recognizing expected demands for increased ridership. The overall costs of new vehicles would be substantially more than current vehicles, although it is too early to predict how expensive. There is currently a transition in technology. Light-weight vehicles are not yet achievable or available. Many manufacturers have taken the position that "there will be an evolution in technology and not a revolution."

It would not be feasible to design two types of public transit buses, one to meet the axle weight limit on the Interstate System, and the other designed for use off of that system. The principle reason that it would not be feasible is the minimum amount of time that public transit buses are operated exclusively on the Interstate System. Because of the complexity of the service profile of major transit systems, segregation of vehicle types would be

impractical, increase costs, and adversely impact operations.

All practical efforts have been made to reduce weight. All efforts, to date, still have not brought current public transit buses to the Interstate System single axle limit. The cost of building a light-weight bus that meets axle weight limits, and that includes necessary equipment and equipment mandated by federal laws or regulation, would be impractical in the current budget environment. As it is, we do not have sufficient resources, from all sources, to meet the capital needs of the transit industry.

It is estimated that vehicle design, prototype vehicle development, normal testing, Altoona facility testing, modifications to existing plants or the building of new plants so current business could go on unaffected in the interim, would take between five to eight years at an investment cost of approximately 60 to 80 million dollars in order to bring a bus to the market place that would meet current Federal and State axle weight laws. A Federal guarantee of volume business that would allow for reasonable profit margins would have to be in some way put in place to make such major investments feasible by the private manufacturing sector.

The Advance Technology Transit Bus project currently being sponsored by the Federal Transit Administration is a five-year, $30 million program which will produce six prototype buses for field testing prior to full scale production.

The estimated production cost of a public transit bus that would meet the Interstate single axle weight limit, as well as all other applicable Federal, State, and local requirements, would be substantially in excess of today's costs.

While we anticipate an eventual decline in the weight of public transit vehicles, at a reasonable cost, we believe that national goals and the public interest are best served by an exemption for public transit vehicles from current axle weight limitations. We appreciate your consideration of our views on this subject and we would be happy to respond to any additional questions you might have on the subject.

STATEMENT OF ANDREW H. CARD, JR.

PRESIDENT AND CHIEF EXECUTIVE OFFICER

BEFORE THE

U.S. HOUSE OF REPRESENTATIVES

COMMITTEE

ON

PUBLIC WORKS AND TRANSPORTATION

SUBCOMMITTEE

ON

SURFACE TRANSPORTATION

H.R. 4496

SAFE HIGHWAYS AND INFRASTRUCTURE PRESERVATION ACT OF 1994

COMMENTS

SUBMITTED ON BEHALF

OF

AMERICAN AUTOMOBILE MANUFACTURERS ASSOCIATION

JUNE 14, 1994

The American Automobile Manufacturers Association (AAMA) respectfully submits these comments in opposition to provisions in H.R. 4496, Safe Highways and Infrastructure Preservation Act of 1994, which would freeze and/or rollback truck size and weight limits on the Interstate Highway System and other roads designated as part of the National Highway System. AAMA and its members support the safe, competitive, efficient and economical flow of commerce over the National Highway System. However, the provisions of this legislation related to truck size and weight will eliminate substantial improvements made in the safe, competitive, efficient and economical flow of commerce.

IDENTITY

OF

AMERICAN AUTOMOBILE MANUFACTURERS ASSOCIATION

AAMA is a not-for-profit trade association whose members are Chrysler Corporation, Ford Motor Company and General Motors Corporation. Members of the Association ship, in interstate and intrastate commerce, component parts used in the manufacture, maintenance and repair of vehicles as well as finished vehicles which are subject to federal and state vehicle weight and length laws.

2

THE ISSUE

Specific provisions of H.R. 4496, Safe Highways and Infrastructure Preservation Act of 1994, would prohibit the operation of trailers, şemi-trailers, containers and other cargo units longer than 53 feet on the Interstate Highway System or other roads designated as part of the National Highway System. Other provisions would eliminate the ability of states to issue over-weight and overdimensional permits.

AAMA POSITION

Safe, efficient and economical flow of commerce over the nationwide transportation system is of concern to AAMA and its members. As shippers, AAMA members are customers of the for-hire motor carrier industry and are affected by federal and state regulations intended to ensure a safe, efficient and economical nationwide transportation system. In addition to using the services of for-hire motor carriers, AAMA members operate private truck fleets which are subject to applicable safety, weight and length regulations.