Dealing With The USDOT — Best Truck, Trailer, & Plow Combination For Me?

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

  • Mowing > Plowing — Dakota & light duty plow, service out-of-state lawn care accounts

    Votes: 0 0.0%
  • Other

    Votes: 0 0.0%

  • Total voters
    3
  • Poll closed .

Mac-s Lawn & Snow

LawnSite Bronze Member
Follow up:
Forget the 1/2 ton idea if you are going after commercial snowplowing. It is a bad idea. I think this was stated earlier that some places will require you to list equipment and if your primary truck is a 1/2 ton they will pass. I'd guess any where in Michigan see's more than the 60 to 80 inches we see here. Yeah people hang v-plows on f150's around here and I pull them out of snow banks when we get more than a foot of snow.
 

Andrew H

LawnSite Gold Member
Unless you are in CDL range most DOT guys (even the state police flunkys) will help educate you and get you compliant
That maybe true where you’re at, but that’s not everywhere, there’s many peace officers, msp included that don’t know the law, and often don’t enforce anything or wrongly enforce. The law changed in 2012, but not everyone got the memo.
I also think there’s so many terms that people get lost on what they mean.

for example, If you’ve got no Airbrakes on your CDL, that’s a restriction, but there’s a good chance someone would argue saying it’s an endorsement. If you have something like Hazmat, that’s an endorsement not a restriction, and then there’s groups.
Hopefully one day those enforcing the law, will know the law.
 
OP
T

The Swamp Fox

LawnSite Member
Location
Michigan
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 .

@Mdirrigation — I hear by and large what you're saying, and I agree as far as interstate travel goes — where the Federal USDOT registration requirement of 10,001+ pounds of GCWR would apply.

But if we're talking only intrastate travel within Michigan, residents don't need DOT numbers unless their GCWR exceeds 26,001 pounds — as @Andrew H points out below.

Only if he’s going interstate, if he stays within Michigan or exceeds 26,001 he doesn’t need one

This is my understanding as well, provided we amend your comment to read "or doesn't exceed 26,000".

...if he’s pulling a trailer and his GCWR is under 26,001 and he’s staying in the state of Michigan, he does not need a DOT number, or a cdl, or an air brake endorsement, or any restrictions.

Agreed on all counts — well said! The benefits you listed are just the tip of the proverbial iceberg when it comes to the pros of staying below the MDOT registration requirement threshold.

But if he goes over state lines he has to go by Federal rules

So don’t ?

Hence my dilemma of whether or not I want to take on accounts over the state line. Doing so with a typical 1/2 or 3/4-ton truck and a 6x12 or 7x14 tandem-axle trailer would likely put me over 10,001 pounds of GCWR and require me to join the DOT dance, whereas no such requirements would apply if I stay within Michigan since I'd be unlikely to hit the 26,001+ lb. GCWR MDOT threshold.

...The CGVW is the GVW of the truck and trailer added together . Its hard to stay under 10K CGVW with a trailer .

right but a 10k f350 and a 14k trailer is 24k and from what he says his state regs say over 26k so hes good.

I wanted to touch on the above two statements in red since I feel there's an important clarification to be made. From what I've gathered, avoiding the need for a Federal USDOT number if crossing state lines is actually far more difficult than simply trying to keep the combined Gross Vehicle Weights (GVW) of your truck and trailer under the 10,001 pound threshold.

Per the Federal Motor Carrier Safety Administration (FMCSA) website, a Federal USDOT number is required if the vehicle GVWR, GCWR, GVW, or GCW exceeds 10,000 pounds. The way I understand it, this means the 10,000 pound threshold applies to not just the actual physical weight of your truck and loaded trailer (GCW), but also to simply how much weight your truck is rated to haul (GVWR) and/or tow (GCWR) according to the manufacturer.

So even if you have a fairly light 1/2-ton truck and an empty, single-axle open trailer whose GVW's when combined total less than 10,000 pounds, you could still be subject to USDOT registration requirements if the GVWR or GCWR of your truck exceeds 10,000 pounds per the manufacturer.

Most 1/2-ton truck specs I've seen to date have GVWR's of 6,000-7,000 pounds or so — no problems there. GCWR is where the main problem lies, as most half-tons have GCWR's of 10,000-12,000 pounds.

My current understanding is that even a simple half-ton pickup with nothing in the bed, no trailer, no cargo in the cab, and no passengers other than the driver could still require USDOT numbers when crossing state lines for the purposes of commerce if the GCWR of the truck exceeds 10,000 pounds.
 
OP
T

The Swamp Fox

LawnSite Member
Location
Michigan
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.
Checking out the state-level DOT requirements for both the home and destination state is sage advice, and something I had done early on in my deliberations. In this case, I'd be looking at traveling to Indiana.

At first blush, the Indiana DOT registration requirements appear to match up with those of the USDOT, inasmuch that DOT numbers are required for any commercial motor vehicle traveling intrastate with a GVWR or GCWR of 10,001+ pounds.

But if you check out the fine print, you'll find that residents are excluded from this requirement if their vehicle weighs less than 10,000 pounds or if GCW is less than 26,001 pounds, so their requirements are similar to Michigan's for my particular scenario. The stickler in my case will be the Federal USDOT threshold of 10,001 pounds of GVWR / GCWR / GVW / GCW which governs interstate travel.

In terms of enforcement, I have no idea as I have no prior personal experience with DOT on any level. I tend to take a conservative approach to life in general so your recommendation of "playing it safe" and registering is appealing on the surface, but my concern is that by creating a DOT-required rig and applying for numbers I will actually be creating the potential for far MORE problems and hassles down the road, not less.
 
OP
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The Swamp Fox

LawnSite Member
Location
Michigan
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
I really appreciate you taking the time to share your experience, and will definitely look more closely at each of the above items you've referenced. DOT enforcement regulations and enforcement is all new to me, and I've been digesting quite a bit the last few months.

It sounds like the strictness of DOT enforcement can vary a lot based on the state or even the enforcement agent you're dealing with. My problem lies in not knowing what that looks like for my area. Could I merrily set up a 10,001+ pound truck / trailer, service lawns across the state line, never register with the DOT, and never be stopped? I'm guessing there's a strong chance.

It's also possible that I could be stopped and it would result in more of a warning and general education than a citation with tickets. Then again, I'm not really wanting to take that gamble. Guessing wrong could be expensive, cause mid-season delays in customer service if my rig is sidelined while working to become compliant, and result in an overall poor reflection of my company integrity and attention to detail.

If there is any way of entirely eliminating such a possibility, I think structuring my business accordingly and equipping my truck and trailer to take advantage of it will pay off in the long run.
 
OP
T

The Swamp Fox

LawnSite Member
Location
Michigan
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.
It's great to hear from someone with experience regarding this specific scenario and thought process. In my case, FMCSA USDOT requirements governing vehicles with a GVWR, GCWR, GVW, or GCW over 10,000 pounds will be stricter than the state-level DOT regulations for both of the states involved.

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.

The scenario you described above of having essentially outfoxed the DOT in the off-chance of a pullover is exactly the thought process and intent behind this thread. I'm hoping to create a rig capable of meeting my needs while avoiding the need to be subject to DOT enforcement entirely if I do my research and play my cards right.

Your example with the '07 GMC in red works great using the GVWR of a truck and trailer. But my research so far indicates that truck GCWR's are often much higher than are the related GVWR's. Most 1/2-ton truck specs I've seen to date have GVWR's of 6,000-7,000 pounds or so — no problems there. GCWR is where the main problem lies, as most half-tons have GCWR's of 10,000-12,000 pounds.

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.

Given the fact that the Federal Motor Carrier Safety Administration (FMCSA) website states that a USDOT number is required if a vehicle GVWR, GCWR, GVW, or GCW exceeds 10,000 pounds, I'm concerned that even a typical half-ton could technically be found in violation due to GCWR rather than GVWR, even if it's pulling / carrying no trailer, cargo, or passengers other than the driver.

Have you ever experienced / heard of anyone getting pulled over or cited for a truck without a trailer that was over the 10,000 pound limit? I'm reading the USDOT regs the same way you are and can see the potential, just not sure if it's common or not.

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.
There's no question that for plowing purposes a 3/4 ton is far more ideal than a half-ton. I don't disagree with that assertion in the slightest. I've been haunting the PlowSite forums for the better part of the last two months researching all things trucks, plows, suspension mods, and logistics, and everything I've read corroborates what you're saying regarding 3/4 tons being more capable out-of-the-box, as it were.

However, I have come across many examples of others successfully plowing residential and light commercial (my intended application) with half-ton trucks. In many cases, for 5–10 years or more. Consensus appears to be that if you take basic precautions like those below, you can plow with a half-ton successfully:
  • Select the right truck — not all half-tons are created equal.
  • Select the right plow — be cognizant of your trucks limitations, know your FGAWR, don't exceed it. Hydraulic lift vs. chain lift plows can limit plow movement during transport, reducing front end wear and tear.
  • Help out your suspension as needed in the form of Timbrens, Bilsteins, airbags, or lift kits to limit front end sag and ensure adequate plow clearance during transport.
  • Understand the differences between counterweight and ballast and configure each appropriately for your truck and plow.
  • Be diligent about removing the plow when not actively in use.
  • Plow "with the storm" during periods of heavy snowfall.
  • Use conservative attack angles and bites when windrowing in heavy snow.
A 3/4-ton makes a great plow truck. If all I was planning on doing was plowing, I'd definitely go that route. If I end up pursuing Poll Option #4 (Dedicated Plow Truck), it will definitely be a 3/4 ton. But since I need a one-size-fits-all truck to be a jack of all trades and hold down light hauling, family transport, plowing, and hunting duties, I would prefer a half-ton. I don't want to turn the entire thread into a 1/2-ton vs. 3/4-ton plow truck debate (saving that one for PlowSite!) :popcorn:, but a few of my reasons for preferring a half-ton, in no particular order:
  1. Shorter turn radius (parking, maneuverability, plowing)
  2. Less ground clearance (family transport, ease of access into the bed — wife and I are both under 5'10")
  3. Lighter vehicle weight (USDOT regulations, fuel economy)
  4. Softer, more supple ride (family transport)
  5. Smaller overall size (garage storage / HOA conformance)
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.
To my mind, the impact on my plowing capabilities is one of the biggest implications of the Dodge Ram 1500 vs. Dodge Dakota debate. I can put an 8'0" Sno-Way 26R scoop plow on the Ram 1500 and think it would be a great combination.

But if I elect to chase commercial lawn maintenance accounts across state lines and roll with the Dakota to avoid USDOT regulations, I'd have to go about 200 pounds lighter with a plow and would be stuck with a light straight blade, probably borderline home-owner duty.

The Dakota can easily haul what I'll be pulling (3,200–3,800 pounds max), so the plowing factor is probably the biggest sticking point for me. There seems to be quite a drop-off after the Sno-Way 26R in terms of the plow performance and feature sets available in lighter weight classes.

I probably haven't been around long enough to know who "DA Lawns" is, but if you can point me in the right direction I'd love to hear from current or former Dodge Dakota owners. I'm actually planning a separate thread to that effect to garner some targeted feedback.
 
OP
T

The Swamp Fox

LawnSite Member
Location
Michigan
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
If I DO go with a 3/4-ton, it will be gas-powered rather than diesel. Primarily because I've read that repeated short trips between ignition cycles is really hard on the (expensive!!) emission components.

In addition, I won't be hauling enough (3,200–3,800 lbs. max) to need the additional low-end torque, and wouldn't be planning on putting enough miles on to get the better fuel economy to pay off in terms of price differential between diesel and gas.
 
OP
T

The Swamp Fox

LawnSite Member
Location
Michigan
#1 Its not "gross commercial vehicle weight rating" its gross combined vehicle weight rating.
Thanks for pointing out my slip-up with the GCWR definition, Mark! How in the world did I DO that?! I knew the correct definition, but I managed to butcher that big time in my post... head must have been spinning from all the acronyms. :dizzy: I usually pride myself on my attention to detail, I'm sitting here kicking myself at the moment.

#2 The vehicle inspection can be done by anyone.
If true, this would be less of an issue. But this doesn't necessarily mesh with what I've read elsewhere.

For example, the criteria for qualifications of the inspectors responsible for performing the required annual USDOT inspections are outlined in Title 49, Section 396.19 of the Electronic Code of Federal Regulations (e-CFR) and are quite specific.

I could see how a loose translation of some of the stated criteria could potentially be achieved by a solo LCO, but the chances of it holding up under scrutiny seem tenuous, at best.
 

hal

LawnSite Fanatic
Location
Kansas
We have/had a DOT number and did yearly inspection in house. You can get all that info online. If you are going to do it, just do it right. Cover your arse and make your vehicle legal and safe. Just use common sense.
 
OP
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The Swamp Fox

LawnSite Member
Location
Michigan
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.
You'll have to forgive my ignorance — what is a D3 and a 580? Regardless, I get the gist of your post. Chances are, I could roll across state lines with a half-ton rated for 10,500 GCWR and a small single-axle enclosed trailer weighing 3,200 pounds fully loaded, and never have an issue.

There's probably a sizable number of folks who've read this post and thought I'm crazy over-thinking this. But from my perspective, I'd rather not risk my equipment, business finances, driving record, and business reputation by gambling on whatever mood a random DOT enforcement officer is in on any given day.
 

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