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How Should I Deal With USDOT Regulations For Servicing Lawn Care Clients Across The State Line?

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Discussion Starter · #1 ·
Hope the December lull is treating everyone well! Today I have what I believe to be a somewhat unique scenario regarding truck selection for my business that I'd like to run by the collective hive mind.

I'm situated on the outskirts of my hometown, which is located near the state line. While the bulk of my future residential accounts will (hopefully) be located in or near my hometown, I hope to expand into commercial work before long and have identified a relatively long list of potential clients located within short driving distance but across state lines.

For sake of context, I'm planning on launching a fledgling landscape maintenance company in 2020 which I will be operating solo for the foreseeable future. I'm considering a relatively light client threshold of about 30-40 accounts for at least the first year or two, and will be limiting service to basic landscape maintenance with no installs, hardscapes, irrigation repair, or fertilization / herbicide / pesticide applications.

I do plan on offering snow removal and salting services at some point, but I am somewhat on the fence regarding whether to do so in my first year in the interest of not making the learning curve too steep.

The USDOT Registration Requirement Problemhttps://www.lawnsite.com/threads/can-a-new-lco-land-commercial-accounts.491826/
Potential out-of-state clients present an interesting quandary and lots of implications regarding the selection of my towing vehicle - as well as compatible trailers and snow plows - due to USDOT registration requirements.

In essence, USDOT registration is required if conducting interstate commerce with a vehicle possessing a Gross Commercial Weight Rating (GCWR) of 10,001 lbs. or more. This differs from the individual requirements of both of the states in question, which only require DOT registration if GCWR exceeds 26,000 lbs.

I'm not at all excited about jumping through all of the hoops associated with USDOT registration - particularly the annual mechanic's inspection and pre-trip inspection log requirements. The penalties for non-compliance can be staggering, and I've read horror stories here on LawnSite regarding the general level of suck involved.

With this in mind, I started researching available trucks with a GCWR of 10,000 pounds or less. What I found is that just about every half-ton pickup manufactured in the last 20 years (forget about 3/4-tons and 1 tons) has a GCWR that exceeds 10,000 lb. and would make me subject to USDOT registration if I choose to service clients across state lines.

This would all be a non-issue for me if USDOT registration was required at 10,001 lb. of Gross Commercial Vehicle Weight (GCVW) instead of simply Gross Commercial Weight Rating (GCWR). In a worst-case future state scenario, my anticipated enclosed trailer setup would likely have a maximum loaded weight of between 4,000-4,600 lb., and when coupled with a typical half-ton pickup would be under 10,000 lb. of combined weight.

My Towing Requirements
My approach with my work truck vehicle search to date has been to first scope out a trailer and plow type / size so I can reverse-engineer my ideal truck from the associated GCWR, Payload, and FGAWR requirements. I'm hoping this approach will allow me to avoid purchasing a truck only to find later on that it's incompatible with the ancillary equipment I need.

Since trailer type and size will obviously have a bearing on the responses voiced in the comments, below are some quick-hitting details on my towing requirements:
  • I'll be using a 6x12 / 6x14 / 7x12 / 7x14 enclosed V-nose trailer with either a single 5,200-lb. axle (optional) or tandem 3,500-lb. axles.
  • Trailer contents to start will total approximately 1,750 lb. with the potential to increase to 2,500 lb. if/when I add a smaller stander for backyards.
  • A typical 6x14 single-axle enclosed trailer with a 3,500-lb. axle weighs about 1,300 pounds empty, leaving about 2,200 lbs. of available payload and resulting in a total max loaded weight of 3,500 lb.
    • This would be fine for my starting setup, but the 2,200 lb. max payload would make me unable to add a second mower. An optional 5,200 lb. single axle would bump up available payload capacity to 3,900 lb. while retaining the weight savings and maneuverability of a single axle trailer. Maximum loaded weight would then total approximately 5,200 lb.
  • A typical 6x14 tandem-axle enclosed trailer with dual 3,500-lb. axles weighs about 2,060 pounds empty, leaving about 4,940 lbs. of available payload and resulting in a total max loaded weight of 7,000 lb.
While my preferred truck is a half-ton (for several reasons), I would consider a 1/4-ton compact if I thought it would handle my towing / plowing needs. From what I've gathered after extensive online research, compact trucks max out at about 3,700 lb. of max towing capacity, and the plow offerings are limited to homeowner type models.

My Plowing Requirements
If and when I do decide to add snow removal and salting services, the primary motivation for doing so would be to pick up small commercial lots for the purposes of gaining those landscape maintenance contracts in summer. I'm sure I will mix in a healthy dose of residential accounts as well.

I've researched plow manufacturers and models extensively, including the full lineups of Blizzard, Boss, Fisher, Hiniker, SnowEx, SnowDogg, Sno-Way, and Western. Below are my main criteria in a plow:
  • I am excluding any plows with listed weights below 700 lbs. from consideration since I'm primarily interested in a 1/2-ton pickup.
  • The minimum plow width I am considering is 7'6" for the purposes of ensuring my plowed path will be wide enough to cover my tracks when windrowing at full angle. My ideal plow width is 8'0" to ensure that this is the case even when turning.
  • My preference is for a plow with controllable wings, followed by a V-plow. A straight blade would be my least preferred as it seems the least versatile.
  • Prefer direct (hydraulic) lift vs. chain lift in order to take advantage of down pressure options on the market for back-dragging purposes.
Given all of the above criteria, the Blizzard 760SW (Winged), Boss HTX (V), Fisher HT (Straight), Sno-Way 26R (Winged), and Western HTS (Straight) were the top contenders. Of those, the Sno-Way 26R was far and away my preferred choice due to the specific feature set of programmable wings, low overall weight, down pressure, 4-Sight lighting options, compatibility with a wide array of makes/models (including the Ford EcoBoost models), and a wireless controller w/integrated salt spreader controls and programmable macros.

The Sno-Way 26R requires a minimum Front Gross Axle Weight Rating (FGAWR) of 3,900 pounds, which my 1/2-ton pickup of choice - the 3rd-4th generations of Dodge's Ram 1500 - meets, per Sno-Way's compatibility checker.

This is post 1/2 due to character limitations. See post 2/2 below.
 

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Discussion Starter · #2 · (Edited)
(Post 2/2)

All-Purpose Towing / Plowing Trucks I've Considered
I considered the more modern Ford F-150's equipped with the 3.5L (2011-current) and 2.7L (2015-2019) V6 turbo-charged EcoBoost engines, primarily for their performance and fuel economy. The Sno-Way 26R is the only plow of its caliber compatible with Eco-Boost equipped trucks, so that checked out. The problem here is pricing - the Eco-Boosts are new enough that they are all way out of my price range.

I pretty much had my heart set on a 3rd-gen (2002-2008) Dodge Ram 1500 as my ideal work truck for both towing and hauling, as it can handle both my required trailer and the Sno-Way 26R in half-ton form. As an added bonus, many models within this range check in at just under the 10,000 GCWR threshold of USDOT registration. The problem lies in the details - per the Ram Body Builder charts, the only models checking in under 10,000 GCWR are regular cab, manual transmission, or 2WD only models. These are issues on my end as follows:
  • Regular Cab - I am married w/two kids, and the truck will need to occasionally serve as a family hauler.
  • Manual Transmission - I've driven a stick-shift daily since 2011, but my wife cannot for the life of her. Snow plowing with a manual seems less than ideal.
  • Drivetrain - If I'm plowing, I'm not messing around with 2WD.
After going back to the drawing board, I stumbled across the Dodge Ram 1500's little brother - the mid-sized Dodge Dakota. Bigger than most compacts, smaller than the half-tons, the Dakota seems to be somewhat in its own class. It's the only model smaller than a half-ton to offer a V8 engine (4.7L, 5.9L), comes in Regular, Club, or Quad Cab configurations, and has many of the same drivetrain components as the Dodge Ram 1500 (differential, axle, transmission, engine, et al.)

The Trailer Tow Group and Heavy Duty Service Group factory options include a Class IV receiver, 7-pin trailer light and electric brake hookups, upgraded battery, high-output alternator, transmission oil cooler, power steering fluid cooler, and an additional fan on the radiator.

The real kicker is that the 2001 Dodge Dakota Owner's Manual indicates the Club Cab 4x4 models with automatic transmissions powered by the 3.9L V6 (w/3:92 gears), 4.7L V8 (w/3:55 gears), and 5.9L V8 (w/3:55 gears) all have a GCWR of 9,200 lbs.!!

Not only would this enable me to tow while avoiding USDOT registration requirements, but it comes with an available payload of 1,450 lbs. and a max towing capacity of 4,800 lbs. Both of these would suffice for my towing needs as well. The only issue is that the FGAWR tops out at 3,600 pounds, 300 pounds shy of the 3,900 lb. minimum of the Sno-Way 26R, which the Dodge Ram 1500 just meets.

Which Equipment Combination Makes The Most Sense?

The way I see this, I have four options moving forward, which I've summarized via a poll attached to this thread:
  1. Purchase a Dodge Ram 1500 and equip it with a Sno-Way 26R plow and simply put up with the USDOT registration and compliance nightmare in order to gain access to the many potential landscape maintenance clients across the state line.
  2. Purchase a Dodge Ram 1500 and equip it with a Sno-Way 26R plow and limit my service area to in-state landscape maintenance clients to avoid USDOT registration requirements.
  3. Purchase a Dodge Dakota and equip it with a light-duty straight-bladed plow. This would enable me to service landscape maintenance clients across the state line without USDOT headaches, but restricts my snow plowing capabilities greatly.
  4. Purchase a Dodge Dakota for a tow vehicle and a dedicated Dodge Ram 1500 plow truck for snow plowing. Not crazy about this idea as I've not had good experiences with letting vehicles sit unused. We also live in an HOA, and even though we have an acre, storage space without becoming unsightly is a bit of an issue.
Questions For The Audience
To wrap-up this novel, what do you guys think is my best course of action from a business planning perspective?
  • Am I overthinking the hassle of USDOT registration and compliance?
  • Is obtaining the benefits of a plow with controlled wings like the Sno-Way 26R vs. a typical home-owner grade straight-blade worth either restricting my landscape maintenance service area or putting up with USDOT registration / compliance hassles?
  • Is there another half-ton pickup with a GCWR under 10,000 pounds and a FGAWR of 3,900+ lb. that can handle a Sno-Way 26R plow?
I welcome your thoughts. If you see a different option available to me that I haven't yet listed, I'm all ears!
 

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Id double check the requirements for you

Dot number for over 10000 gvw or gvwr new rule here even in state:dizzy:

Also for about 10 years a dot medical card is required for over 10k
 
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Discussion Starter · #4 ·
Thanks for the words of caution. I just double-checked - for intrastate commerce here in Michigan, USDOT numbers are only required if CMV's require a CDL to operate.

In turn, the requirements for a CDL per our Secretary of State are single vehicles with GVWR's of 26,001+ pounds or combination vehicles with GCWR's of 26,001+ pounds.

We do have Chauffer's License and Medical Examiner's Certificate licensing requirements in-state for GCWR's of 10,001+ pounds, however. I don't anticipate either of those two posing major challenges.
 
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This guy wrote a full blown essay, complete with citations and all. Lol.

Honestly you’re thinking too much into it. If there is enough business to go over state lines, get a DOT card. If not, then don’t. It’s not worth trying to find ways around the system, especially when you’re talking about plowing with a 20 year old half ton or a quarter ton.

You really need at least a 3/4 ton for plowing, and having a half ton or under will limit you in growing your landscape biz. You’ll have to upgrade at some point anyways.Those trucks you are considering aren’t made to be worked day in and day out, will wear them out faster and be limited.
 

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Discussion Starter · #6 ·
This guy wrote a full blown essay, complete with citations and all. Lol.

Honestly you're thinking too much into it. If there is enough business to go over state lines, get a DOT card. If not, then don't. It's not worth trying to find ways around the system, especially when you're talking about plowing with a 20 year old half ton or a quarter ton.

You really need at least a 3/4 ton for plowing, and having a half ton or under will limit you in growing your landscape biz. You'll have to upgrade at some point anyways.Those trucks you are considering aren't made to be worked day in and day out, will wear them out faster and be limited.
It certainly wouldn't be the first time I've been accused of overthinking something! I tend to be overly analytical when decision-making. Sometimes that pays dividends in spades, others... I simply get bogged down in analysis paralysis.

I'm a big believer in doing things correctly and by the book, so if I get a rig that ends up being subject to USDOT governance, it will really weigh on me. Just read the full book of requirements not long ago, and it's extremely far-reaching and onerous. No cell phone use while driving could be a problem as well.

Ultimately, my wife and I are trying to streamline our lives as far as possible with two kids under the age of three in the home. With what I've discovered to date, self-employment is complex enough without dumping all kinds of additional headaches and worries into the mix from USDOT.

I'm definitely cognizant of the limitations of half-ton use, and appreciate your words of warning. Everything I've read corroborates what you're saying. Then again, I have many reasons (which I won't get into here) for preferring a half-ton, and if I'm conscientious with use and application I think I can likely make it work.
 
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This guy wrote a full blown essay, complete with citations and all. Lol.

Honestly you're thinking too much into it. If there is enough business to go over state lines, get a DOT card. If not, then don't. It's not worth trying to find ways around the system, especially when you're talking about plowing with a 20 year old half ton or a quarter ton.

You really need at least a 3/4 ton for plowing, and having a half ton or under will limit you in growing your landscape biz. You'll have to upgrade at some point anyways.Those trucks you are considering aren't made to be worked day in and day out, will wear them out faster and be limited.
the issue is getting and keeping employees WITH Dot cards.... its hard enough to get them with a DL!
 

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If you are going to pull a trailer of any size you will need Dot numbers . The CGVW is the GVW of the truck and trailer added together . Its hard to stay under 10K CGVW with a trailer .
Only some states enforce like maryland...my question for the OP would be, what state are you traveling to? How do they enforce?..In Maryland, truck and trailer combined over 10k requires to have DOT numbers and medical card...if you are that concerned, be safe and just get the numbers. They are free, only thing that costs is the medical exam. You should already have a fire extinguisher and triangles in your truck I'd hope...the biggest pain is the flood of sales calls after obtaining the numbers.
 

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It's not that bad.... My company is located on the WV/VA line and we deal with DOT frequently. Honestly WV (home state) is harder to deal with than VA.

Here's your biggest situations (check your state)....
- Proper tags/title for truck+ trailer
- DOT inspection truck/trailer
- Proper insurance, make sure you have a MCS-90 (if required), hazmat statement on insurance for haul under XX gal of fuel but not actual hazmat endorsement.
- DOT medical card
- Flare kit, fire extinguisher, road side kit, etc....
- Proper straps for equipment.

Unless you are in CDL range most DOT guys (even the state police flunkys) will help educate you and get you compliant
 

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So crossing state lines puts you under the feds. I'm in the same boat crossing state lines. Follow federal guidelines unless the state has stricter laws.

A 07 GMC 1500 gvwr is under 7000 lbs. Add a trailer rated 3,000 gvwr you are under 10,001 lbs. When they pull you over you, can laugh at say they pulled you over illegally. I have one truck set like this for a higher mileage route that hits more patrolled areas. It works, in my opinion it doesn't solve your plowing issue. Plowing with a half ton commercially is foolish.

For what you want to accomplish long term (a vehicle purchase shouldn't be done for short term). A 3/4 truck for plowing and hauling is a much better choice. Front ends take the plow weight. Brakes are larger for hauling. Transmissions are made for the loads. You are in Michigan most likely have lake effect snow. You need a truck to be a work truck. I have 6 3/4 ton trucks plowing/towing and hold up well.

Keep the truck gvwr under 10k (yes some are over 10k, in theory they could pull you over without a trailer). Keep the trailer under 10k (or you will need a cdl). Fed rules. Buy a real plow, not homeowner. You will be much happier.

For the Dakota idea. Ask da lawns or whatever his name is. He thought he could get away with one. Told him 3/4 ton. Said he'd be fine. A year or two later I think he bought a half ton atleast. Doesn't plow snow to my knowledge though.

The dot hassle will be based on the patrols in the area. It's not really bad. Just more paperwork. Annual inspection costs.
 

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If it’s about the cost of the smaller trucks vs the 3/4 ton... just get a gasser. They are not much more than a comparable half ton
 

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Thanks for the words of caution. I just double-checked - for intrastate commerce here in Michigan, USDOT numbers are only required if CMV's require a CDL to operate.

In turn, the requirements for a CDL per our Secretary of State are single vehicles with GVWR's of 26,001+ pounds or combination vehicles with GCWR's of 26,001+ pounds.

We do have Chauffer's License and Medical Examiner's Certificate licensing requirements in-state for GCWR's of 10,001+ pounds, however. I don't anticipate either of those two posing major challenges.
#1 Its not "gross commercial vehicle weight rating" its gross combined vehicle weight rating.
#2 The vehicle inspection can be done by anyone.
 

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Around here if you are in a 1/2, 3/4 ton truck you could be pulling a D3 or 580 with a single axle trailer and the back end of your truck dragging the ground and not get pulled over.

I can't say it's fact but I believe that unless your are in a DRW truck OR you have a DOT # plastered on the side, the enforcement officers just don't pay attention like they should.
 

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I was going to comment earlier but that would just fuel the DOT debate which I don't want to argue here. So Just step up to the 3/4 or one ton haul truck, get the DOT numbers, medical card, DOT certifcations on trucks and trrailer if you are serious about this and going across state lines. This is all neccessary if you are going after commercial work as stated here and your other post. This is all part of overhead and gets passed on to the customer in your pricing. As stated earlier, you can do your own DOT certifications on the equipment. You may find out down the road that some of these things are not needed or enforced in your area but it's nice to have this in place when you start so you don't experience delays during the mowing season. Around here the first time you get pulled over by the DOT they will work with you and sometimes give warnings instead of tickets if you have a good attitude. All of these laws were written for a reason and keep the roads safe for every one. Sometime your insurance company may get involved and mandate everything stated above as well.
 
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