The Connecticut General Assembly
OFFICE OF LEGISLATIVE RESEARCH
January 11, 1995 95-R-0062
FROM: James J. Fazzalaro, Principal Analyst
RE: Federal Definition of Truck and Commercial Vehicle
You asked for information on whether there is any federal definition of the terms "truck" and "commercial vehicle" and how this compares to Connecticut's registration law for commercial vehicles and combination vehicles. The central point of your inquiry is whether a federal definition creates a distinction that any truck, regardless of its size, is considered commercial if it is used for business purposes, but a small truck used for recreational or private passenger purposes is considered a passenger car.
We are aware of three places in federal transportation regulations where terms like passenger car, truck, and commercial vehicle are defined. There may be others. The distinction between passenger cars and trucks you mention seems to most closely resemble the definitions that implement the federal Motor Vehicle Information Cost Savings Act, but these definitions do not match exactly. The regulation where the term commercial vehicle is defined does not make its distinction based on use for "business" purposes either, nor for that matter do any of the other federal definitions.
Federal definitions do not, for the most part, relate to Connecticut's definitions used for motor vehicle registration purposes. The various federal definitions apply mostly to matters under federal jurisdiction and states are basically free to determine their own vehicle registration classifications. Connecticut law defines a "commercial motor vehicle" separately from its requirement that certain vehicles must have a "commercial registration" because drivers of vehicles with commercial registrations that fit the definition of a commercial motor vehicle must get a special license.
Regulations implementing the federal Motor Vehicle Information and Cost Savings Act define the terms "automobile," "passenger automobile," and "light truck." The primary purpose of these definitions is for vehicle classification under national requirements for fuel economy applicable to manufacturers (49 CFR § 523).
The terms "passenger car," "truck," and "multipurpose passenger vehicle" are defined in regulations implementing national motor vehicle safety standards that cover things like occupant protection, braking systems, lighting, window glazing, tires, and many other areas. These standards are also applicable to manufacturers (49 CFR § 571).
The third area of federal regulations are the interstate motor carrier safety standards in which the terms "commercial motor vehicle" and "truck" are defined. These are equipment and operational standards that apply to private, contract, and "for-hire" motor carriers (49 CFR § 390).
Definitions Under Fuel Economy Standards
These regulations define an automobile as any four-wheeled, fuel driven vehicle manufactured primarily for use on public roads and that either (1) is rated at a gross vehicle weight of 6,000 pounds or less or (2) is rated at more than 6,000 but less than 10,000 pounds and is determined to be a type of vehicle for which average fuel economy standards are feasible and will result in significant energy conservation, or which is determined to be the type of vehicle that is substantially used for the same purposes as vehicles rated at 6,000 pounds or less.
A passenger automobile is defined as any automobile, except one capable of off-highway operation, manufactured primarily for use in transporting up to 10 people.
A light truck is considered to be an automobile other than a passenger automobile which is designed either for off-highway operation or to perform at least one of these functions: (1) transporting more than 10 people, (2) providing temporary living quarters, (3) transporting property on an open bed, (4) providing greater cargo-carrying than passenger-carrying volume, or (5) permitting expanded use of the automobile for cargo-carrying or other nonpassenger-carrying purposes through the removal of seats provided for this purpose by the manufacturer or through the use of simple tools, and thereby creating a flat, floor level surface inside the vehicle.
A vehicle is considered to be capable of off-highway operation if (1) it has four-wheel drive or is rated at more than 6,000 pounds gross weight or (2) has at least four of the following characteristics: (a) an approach angle of at least 28 degrees, (b) a departure angle of at least 20 degrees, (c) a breakover angle of at least 14 degrees, (d) running clearance of at least 20 centimeters, or (e) front and rear axle clearances of at least 18 centimeters. Approach, departure, and breakover angles are technical terms that measure the angle formed between the ground upon which the vehicle stands and the tangent line running from the point of contact of the tire with the ground to, respectively, the underside of the vehicle to the front of the front tire, the underside of the vehicle to rear of the rear tire, and to the intersection of the tangent lines from the front and rear tires to a point on the underside of the vehicle between them.
The regulations relating to the light truck fuel economy standard also differentiate between a light truck and a "4-wheel drive, general utility vehicle." A utility vehicle is a four-wheel drive, general purpose automobile capable of off-highway operation that has a wheelbase of not more than 280 centimeters (about 110 inches) and that has a body shape similar to a 1977 Jeep CJ-5 or CJ -7 or the 1977 Toyota Land Cruiser (49 CFR § 533).
Definitions Under the Federal Motor Vehicle Safety Standards
The federal motor vehicle safety standards are the basic requirements that manufacturers must follow when making motor vehicles. There are more than 50 separate standards covering things from braking systems and lighting to head restraints and windshield washing systems. Passenger cars, motorcycles, school buses, trucks, and multipurpose passengers vehicles are all covered by one or more of the standards.
Under the regulations, a passenger car is defined as a motor vehicle, other than a motorcycle, multipurpose passenger vehicle, or trailer, that is designed to carry up to 10 people. A multipurpose passenger vehicle is designed to carry up to 10 people, but is constructed on a truck chassis or with special features for occasional off-road operation. A truck is a motor vehicle designed primarily for the transportation of property or special purpose equipment.
Definitions Under the Federal Motor Carrier Safety Regulations
These are regulations that establish the equipment and operating rules for motor vehicles that operate in interstate commerce transporting goods or people. The regulations define a "commercial motor vehicle" as any self-propelled or towed vehicle used on a public highway in interstate commerce to transport passengers or property when the vehicle: (1) has a gross vehicle weight rating of 10,001 pounds or more; (2) is designed to transport more than 15 passengers, including the driver; or (3) is used to transport hazardous materials in a quantity that requires placards under federal hazardous materials regulations (49 CFR § 390.5).
A separate set of federal requirements governing uniform licensing standards for commercial vehicle drivers uses a slightly modified version of this definition. The difference in the definition is in the gross weight limits. The licensing standards apply to operators of vehicles with gross weight ratings of 26,001 pounds or more rather that 10,001 pounds or more (49 CFR § 383.5).
RELEVANCE TO CONNECTICUT VEHICLE REGISTRATION LAW
Connecticut's vehicle registration law serves a different purpose than these federal requirements. As is generally the case in all states, registration classifications are created for each state's administrative purposes and are not necessarily intended to be consistent between states. Different states generally agree upon the reciprocal recognition of each others validly registered motor vehicles.
Connecticut has long made a distinction between vehicles used strictly for private passenger purposes and those used strictly for commercial purposes. But it also has recognized that certain types of vehicles, for example pick-up style trucks used by tradesmen, are frequently used both in the owner's business and as his personal means of transportation. This has led to the creation of what is known as the "combination" classification which is issued to a motor vehicle used for both private passenger and commercial purposes as long as the vehicle's gross weight does not exceed 10,000 pounds. (CGS § 14-1(9)) The fee for a combination registration depends on whether it is a passenger vehicle used in part for commercial purposes or is a motor vehicle "used in part for commercial purposes and as a passenger motor vehicle" (CGS § 14-49(e)).
In effect, whether the owner of a vehicle in the combination classification pays the passenger vehicle-based fee or the commercial vehicle-based fee depends on whether or not the vehicle fits the statutory definition of a passenger motor vehicle, (i.e., its body style). A "passenger motor vehicle" is defined as a motor vehicle used for the private transportation of persons and their personal belongings, designed to carry occupants in comfort and safety, with not less that 50% of the total area enclosed by the outermost body contour lines (excluding the engine enclosure) used for designated seating positions and necessary legroom, and with a carrying capacity of not more that 10 passengers, including the driver (CGS §14-1(59)).
This definition essentially requires at least half of the vehicle's enclosed area outside the engine compartment to be devoted to carrying passengers. If the vehicle meets this requirement, it qualifies for a passenger registration. If it meets this definition, but the owner indicates on the registration application that it is also used for commercial purposes, it gets a combination registration and the owner pays the fee based on the passenger vehicle rate. If it does not meet the definition and the owner indicates that it will also be used for private transportation, it gets a combination registration, but the owner must pay a fee based on the commercial vehicle rate (i.e., a variable fee based on gross weight).
The law requires a vehicle to have a "commercial registration" if it is designed or used to transport merchandise, freight, or people in connection with any business enterprise (CGS § 14-1(12)). But some vehicles for which a commercial registration is required do not necessarily come under the technical definition of a "commercial motor vehicle" as it is used under Connecticut law. This is because the commercial motor vehicle definition is intended to apply to the federally-mandated program for issuing commercial drivers licenses (CDL) and not all people that may be driving vehicles that require commercial registrations fall under the CDL requirements. Someone is driving a commercial motor vehicle, and therefore needs to have a CDL, if the vehicle: (1) has a gross weight of 26,001 pounds or more, (2) is designed to transport 16 or more passengers, including the driver, or more than 10 passengers if they are students going to or from school; or (3) is transporting hazardous materials requiring placarding under federal law. Vehicles used for farming purposes, fire apparatus, authorized emergency vehicles, and recreational vehicles are exempt from the definition. This definition was intentionally established to reflect the federal CDL requirements and therefore follows the federal definition closely, with certain obvious differences to accommodate Connecticut's requirements.
The important distinction to be drawn between federal definitions of a commercial vehicle and state definitions is that, with the exception of the federal definition that serves as the basis of states' implementing federal CDL requirements, none of the federal definitions are intended to apply to state programs. For the most part, states are left unencumbered by federal requirements when deciding how they intend to classify vehicles for purposes of registration.