California Basic Inspection of Terminals (BIT) Program and Government Fleets
David Renschler, Association Coordinator for MEMA NorCal and Fleet Manager for the City of Fairfield has provided information from the California Highway Patrol (CHP) regarding the Basic Inspection of Terminals (BIT) program and the application to two axle motor trucks with a gross vehicle weight rating (GVWR) of less than 26,001 pounds. David was kind enough to share this information for our MEMA members. Please remember this response specifically applies to government fleet vehicles.
Date: February 23, 2016
File No: 62.17067.A12586.062 2016 02012
Dear Mr. Renschler:
This is in response to your electronic correspondence dated January 25, 2016, in which you requested clarification regarding the applicability of the Basic Inspection of Terminals (BIT) program to government fleets. Specifically, you requested clarification regarding the applicability of BIT to two axle motor trucks with a gross vehicle weight rating (GVWR) of less than 26,001 pounds, operated by the City of Fairfield.
During conversations with Mr. Craig Weaver, of my staff, you indicated your specific concern relates to vehicles identified in Section 34500(j) of the California Vehicle Code (CVC) which became subject to the BIT program January 1, 2016. Section 34500(j) CVC identifies motor trucks, not otherwise identified in Sections 34500 (a) through (h) and (k) CVC, but are regulated by the Department of Motor Vehicles (DMV), the California Public Utilities Commission (PUC), or the United States Department of Transportation (US DOT). These include two-axle motor trucks operated singly with a GVWR of 26,000 pounds or less; those not transporting hazardous material; those towing a trailer not exceeding 10,000 pounds GVWR; and, those operated in combination not exceeding 40 feet in length when coupled.
The PUC regulates operation of motor trucks in household goods movement only. Vehicles operated by federal, state, and local governments are specifically exempted from regulatory oversight by the US DOT pursuant to Title 49, Code of Federal Regulations, Section 390.3(f)(2). Two-axle truck tractors and motor trucks operated singly, or in combination with certain trailers (including utility trailers) which are never operated commercially, are specifically excluded from the commercial vehicle definition contained in Section 34601(c)(2)(G) CVC. Consequently, the aforementioned vehicles are not subject to the Motor Carrier of Property permit requirement and not subject to regulatory oversight by the DMV for this purpose.
As a result of the foregoing, two-axle motor trucks operated singly with a GVWR of 26,000 pounds or less; those not transporting hazardous material; those towing a trailer not exceeding 10,000 pounds GVWR and in combination not exceeding 40 feet in length when coupled are not identified in Section 34500(j) CVC. Therefore, the aforementioned vehicles and their operation are not subject to the BIT program or motor carrier safety requirements contained in Title 13 California Code of Regulations, Division 2 Chapter 6.5 and not required to undergo carrier performed vehicle inspections pursuant to Section 34505.5 CVC.
I trust this has adequately addressed your concern. Should you require further assistance in this matter, contact Mr. Craig Weaver, of my staff at (916) 843-3400.
B.E. Goldhammer, Lieutenant
Commercial Vehicle Section