Topeka Transport LLC - Petition for Rulemaking

Administrator Federal Motor Carrier Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, DC 20590 RE: Petition for Rulemaking – Authorization of B-Train Configurations in Doubles and Triples Operations Dear Administrator: Pursuant to 49 CFR § 389.31, I respectfully submit this Petition for Rulemaking requesting that the Federal Motor Carrier Safety Administration initiate rulemaking to evaluate and authorize the use of B-train configurations in approved doubles and triples operations within the United States. Petitioner Information: Russ King Commercial Motor Carrier Topeka, Kansas I am an active commercial motor carrier operating in the Midwest. Based on operational experience and industry review, I believe that permitting B-train configurations presents a meaningful opportunity to enhance safety and efficiency in longer combination vehicle (LCV) operations. Background Currently, doubles and triples operations in the United States predominantly utilize A-train configurations, which rely on converter dollies. In contrast, B-train configurations connect the second trailer to a fifth wheel mounted directly on the rear frame of the lead trailer. This design eliminates the need for a converter dolly between the first and second trailers. B-train configurations are widely used in Canada and other jurisdictions with established safety oversight systems. Safety Considerations B-train configurations offer several potential safety advantages that warrant formal evaluation: • Reduced rearward amplification compared to A-train doubles • Improved lateral stability due to rigid fifth-wheel connection • Improved off-tracking control characteristics • Fewer articulation points compared to dolly-based systems • Reduced sway under dynamic driving conditions The rigid connection between trailers reduces pivot points and may improve handling predictability, particularly during evasive maneuvers and adverse weather conditions. Operational and Infrastructure Considerations Authorizing B-trains would not require increasing currently permitted overall combination lengths or gross vehicle weight limits. Instead, this proposal concerns configuration type rather than dimensional expansion. Potential operational benefits include: • Reduced equipment complexity • Fewer mechanical components subject to wear • Improved fleet maintenance efficiency • Potential reduction in crash-related costs Requested Action I respectfully request that FMCSA: 1. Initiate a Notice of Proposed Rulemaking (NPRM) to evaluate B-train configurations for use in approved doubles and triples operations. 2. Conduct or commission a comparative safety analysis between A-train and B-train configurations. 3. Consider implementing a pilot program in selected states currently authorized for LCV operations. 4. Establish appropriate operational parameters, including training requirements and route limitations, as deemed necessary. Conclusion The trucking industry continues to operate in a highly regulated and safety-focused environment. Evaluating proven configurations used successfully in comparable regulatory jurisdictions aligns with FMCSA’s mission to improve safety while ensuring efficient transportation of goods. This petition does not request expansion of weight or length limits, but rather the evaluation of an alternative configuration that may offer measurable safety and operational advantages. I appreciate your consideration of this petition. Respectfully submitted, Russ King Commercial Motor Carrier Topeka, Kansas