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Chapter 3. State of the PracticeIntroductionThe research team developed a hybrid approach for this portion of the study, involving an onlinesurvey of various stakeholders and following up with phone interviews and virtual workshopsinvolving key respondents to the survey. This process allowed researchers to collect informationfrom state permitting agencies and other stakeholders (FHWA, FMCSA, etc.). This approachensured broader and more diverse participation and a higher quality outcome.Researchers conducted the online survey, interviews, and virtual workshops between MarchâMay 2023 to (a) compile best practices, procedures, and decision processes for increasing weightlimits during emergencies used by state and local transportation agencies; (b) determine therationale behind these processes, practices, and decision processes; and (c) understand anddocument best practices for harmonization with neighboring jurisdictions. Specifically, thequestions developed for this hybrid approach documented the following: ⢠Stakeholderâs key concerns regarding the movement of overweight trucks during emergencies. ⢠Agency understanding of emergency and emergency commodities. ⢠Agency department and staff positions responsible for emergency coordination with nearby states and local agencies. ⢠Agency lessons learned from implementing emergency special permits for overweight trucks. ⢠Best practices implemented by stakeholders during emergencies.The research team shortlisted and performed outreach to diverse stakeholder members (in termsof background and geography). This process included contacting representatives from stateTruck Permit Issuing Offices, which as noted above can vary in different states. Thus,researchers contacted five DMVsâConnecticut, Maine, Texas, Vermont, and Virginia; twoDepartments of Public SafetyâGeorgia and South Dakota; two Highway PatrolsâNorth Dakotaand Wyoming; and 41 DOTs. Prior to conducting this outreach effort, researchers developedsurvey and interview questions. Researchers then submitted and received approval for thesequestions, along with the stakeholder list, from the NCHRP research panel.The research team distributed the online survey to each stateâs Truck Permit Issuing Office, witha request to forward the invitation to an appropriate staff member responsible for permittingOS/OW loads. Figure 5 shows the first page of the online survey. A copy of the surveytransmittal letter and a full list of survey questions is in Appendix B.The online survey contained 13 questions with nested logic (i.e., the questions changed based onthe survey responses). Researchers also developed another list of follow-up interview questionsto elicit more in-depth responses from the agencies implementing best practices or thosestruggling to implement best practices. Stakeholder interviews and survey responses allowed theresearch team to better understand the processes, procedures, and challenges faced by TruckPermit Issuing Offices when issuing special permits during emergencies and disasters. 41
Figure 5. First Page of Online Survey 42
The research team received 49 survey responses, but three of these were incomplete. The 43responses contained identifiable state information, some of which involved duplicate responsesfrom the same permitting agency. In total, 37 unique state responses were obtained, as shown inFigure 6.The list of responding agencies is included in Appendix C, along with a full list of surveyresponses, grouped by question. The following section summarizes key findings from the survey. Figure 6. Map of Survey RespondentsSurvey ResultsFigure 7 shows the results of the first question on the survey regarding whether the respondentworks for the state OS/OW permitting office/authority and is knowledgeable about permittingand policies for commercial vehicles during emergencies. Out of 46 respondents, threerespondents indicated that they were not knowledgeable or did not deal with OS/OW permitting.Detailed survey responses are in Appendix C.Figure 7. Summary of Responses to Q1 on Being Knowledgeable about Permitting Policies for Commercial Vehicles during Emergencies 43
Figure 8 shows that 37 respondents issued special permits for commercial vehicles for prioremergencies or disasters. Four respondents indicated they had not previously issued specialpermits. Figure 8. Summary of Responses to Q2 on Experience with Special Permitting for Commercial Vehicles during EmergenciesFigure 9 shows the most recent kinds of state-level emergencies where the state implementedspecial permitting. Twenty-eight respondents, a 54 percent majority, issued special permitsduring COVID-19. Based on the surveys and previously discussed analysis performed onemergency declarations posted to the CVSA emergency declaration website, since 2020 therehas been a gradual increase in emergencies related to flooding, hurricane, drought, snowstorms,and wildfire (also see Figure 4 in the previous chapter). Figure 9. Summary of Responses to Q2.1 on Recent State-Level Emergencies and Special Permits 44
Figure 10 shows a breakdown of responses to the question about coordination of the specialpermits with other states or agencies. Around half of the Truck Permit Issuing Offices stated theyconducted coordination with other states or agencies. Respondents listed coordination withfederal agencies (FMCSA, FEMA, FHWA, etc.), state emergency management agencies, localagencies (cities, counties, etc.), and independent commissions and quasi-governmental bodies(port authorities, councils of government, etc.). It was observed that NASTO and MAASTOstates coordinated among themselves with the federal, regional, and local levels, whereas somestates coordinated only with local and federal agencies. Figure 10. Summary of Responses to Q2.2 on Coordination with Other StatesAs shown in Figure 11, 25 percent of responding Truck Permit Issuing Offices (out of 36 whor*sponded) initiated changes to vehicle overweight laws, regulations, or policies duringemergencies or disasters. Figure 11. Summary of Responses to Q3 on Changes in Laws, Regulations, or Policies Based on Prior Experiences with EmergenciesFigure 12 shows that 21 percent of the responding Truck Permit Issuing Office (out of 42) hadbeen impacted by special permits issued by another state during an emergency. Not everyrespondent answered this question. 45
Figure 12. Summary of Responses to Q4 on the Impact of Emergency Special Permits Issued by Neighboring StatesFigure 13 shows that 61 percent of responding Truck Permit Issuing Offices had some sort ofoutreach or education program with the trucking industry to conduct education and provideassistance with overweight special permits. Figure 13. Summary of Responses to Q5 on Outreach or Education Efforts with the Trucking Industry on Special Permits during EmergenciesPhone InterviewsFollowing the survey, researchers conducted interviews with the online survey participants basedon their responses. The questions used in these phone interviews are listed in Appendix B. Theresearch team sent emails to potential interviewees, and based on responses, researchers set upphone interviews and asked questions. The questions focused on understanding best practicesand lessons learned about overweight special permitting during disasters and emergencies.Table 5 shows the state or agency interviewed and the date researchers conducted the interviews. Table 5. Follow-Up Interviews State/Agency Interview Date Participants 1 Georgia 04/14/2023 2 2 Florida 04/17/2023 3 3 Illinois 04/18/2023 3 4 Missouri 04/19/2023 2 5 Montana 04/19/2023 2 6 South Dakota 04/21/2023 2 7 FHWA 05/01/2023 2 8 Highways for National Defense 05/02/2023 3 46
Virtual WorkshopsThe research team conducted two invitation-only virtual workshops that allowed brainstormingand the opportunity to bring multiple perspectives to the table. Researchers selected workshopdates by polling the potential participants identified in cooperation with the research panel. Twodates worked based on the availability of participants needed to reach a critical number of greaterthan 20 persons (as shown in Table 6).These virtual workshops used video conferencing software (i.e., Microsoft Teams) and screensharing for consensus-building. The research team engaged stakeholders with questions andscenarios to gain an understanding of the variety of approaches used for OW special permittingduring emergencies and how state agencies conducted inter- and intra-agency coordinationduring disasters (see Figure 14). The workshop also tried to map information flows during adisaster. Additionally, researchers and participants examined ways to develop a coordinatedemergency plan that might inform the decision support framework developed in Task 5 of thisproject. Table 6. Date and Participation in Virtual Workshops Workshop Date Participants Average Attendance Time 1 04/27/2023 26 1 hour 11 minutes 2 05/02/2023 22 1 hour 9 minutes Figure 14. Screenshot of Virtual WorkshopInterview with the Department of DefenseThe research team also interviewed representatives with the DoD for their perspective on specialpermits during a national emergency or disaster. Several issues emerged in discussions with DoD 47
representatives regarding their requirements for shipping OS/OW loads. These issues occurred inthe continental United States during normal operations, during DoD and state National Guardoperations supporting civil authorities in presidential declared disasters, and during times of warwhen DoD vehicles moved to deployment ports. These issues are further discussed below.During some national emergencies, the DoD needs to move significant quantities of material andequipment to designated ports for shipment overseas. Contracted civilian carriers must drawpermits for some of these loads. This process may limit the amount of material moved, given thenecessity of complying with state OS/OW permitting requirements. Because states have noauthority to issue special permits without a presidential disaster declaration, the DoD cannotexempt these shipments from state permitting requirements, even though the loads directlysupport a declared national emergency and may require urgent handling, since present specialpermitting authority (outside of the Bangor, Maine, exception) does not exist in federal law orregulation for wartime or operations other than war.Some state National Guard and active-duty military forces involved in support to civil authoritiesduring state or presidential declared disasters also may not understand the overweight specialpermitting processes in the states affected by the disaster or the states transited to get to theaffected states.The DoD has an ongoing project to review the deployment routes used by current militaryinstallations to reach their embarkation ports in emergencies/times of war. To date, this reviewdiscovered several issues, including plans for roadways or designated routes serving formermilitary installations, state or federal roads with infrastructure and bridges that cannot supportthe weight of especially heavy military vehicles or trucks carrying such vehicles, heightrestrictions created by newer bridges or overpasses, and assumptions about the availability oftrucks and drivers to deliver material to points of embarkation.The military rarely has organic OS/OW permitting requirements but still requires state permitsfor convoy operations. For these permits, the military uses Transportation Coordinator'sAutomated Information for Movement System II (TC AIMS II), an internal military system, tocoordinate and approve convoy movements, including routes and permits to ensure a harmoniousmovement across multiple states and jurisdictions. Each stateâs defense movement coordinator(DMC) is responsible for coordinating permits within the state, but the TC AIMS II systemprovides visibility to deconflict potential external state issues before they can impact the largermovements. The TC AIMS II and DMC concept may offer a potential template for creating anemergency civilian movement coordination system to support national and regional emergencyoverweight shipments. FHWA suggested this approach in the past.The domestic commercial trucking requirements that support a military deployment or themovement of most military equipment falls below the level of a national declaration of war thatmight authorize extraordinary measures or waive certain restrictions.1 As such, for most militarymovements, the commercial carrier is responsible for coordinating all OS/OW permit requests.1 The last Congressionally declared war on another nation was the U.S. declaration of war against Japan following theattack on Pearl Harbor in December 1941. Since World War II, Congress authorizes U.S. military operations through theWar Powers Act and appropriations without declaring war. 48
The individual carriers or their subcontracted companies are at the mercy of individual states andregional permitting consortiums for coordination and approval of their loads and routes, whichmay impact military deployments or support to ongoing operations.The DoD can benefit from the ability to use an emergency civilian movement coordinationsystem during national and regional emergencies as well as for operational deployments andnational defense requirements that fall below the declaration of war. At present, emergencypowers related to the NEA do not address such situations beyond a specific route on I-95 thatsupplies fuel to a Maine Air National Guard base in Bangor, Maine.Because the DoD currently lacks emergency movement authority under the existing emergencypowers law for emergency OS/OW shipments absent a declaration of war, it may be necessaryfor elected officials or FHWA to pursue special rulemaking to address this deficiency andestablish an expanded system of special permitting to address DoD overweight shipments outsideof a Stafford Act or other national emergency powers declaration. Another potential solutionmay be for lawmakers to include language addressing overweight shipments by both militaryvehicles and commercial shippers under contract to the DoD in any authorization for the use ofmilitary force or national emergency declaration.Related Policy EffortsThe Safer Highways and Increased Performance for Interstate Trucking (SHIP IT) Act wasintroduced in the U.S. House by Dusty Johnson (R-South Dakota) and Jim Costa (D-California)on January 24, 2023. The status of this effort is unclear; however, it includes the followingprovisions that might assist in resolving some of the special permitting issues identified in thisstudy: ⢠Modernize the authority for certain vehicle waivers during emergencies. ⢠Allow truck drivers to apply for Workforce Innovation and Opportunity Act grants. ⢠Incentivize new truck drivers to enter the workforce through targeted and temporary tax credits. ⢠Expand access to truck parking and rest facilities for commercial drivers. ⢠Streamline the commercial driver license (CDL) process, making it easier for states and third parties to administer CDL tests. ⢠Exempt electric vehicle battery weight from gross weight for certain regulatory purposes. ⢠Create a voluntary pilot program to permit states to allow 91,000 pounds on six-axle trucks on interstate highways. ⢠Provide a 150-air-mile exemption from hours-of-service regulations for haulers of agricultural commodities, unprocessed products, and processed products.Summary and ConclusionsThe following discussion identifies preliminary and general trends observed in the survey resultsand further documented as part of the interviews and virtual workshops. 49
Preliminary FindingsResearchers identified the following significant findings related to OW special permitting duringdisasters, with potential solutions drawn from the research project tasks and stakeholder input:Definition of Emergency and Emergency CommoditiesThe Truck Permit Issuing Officeâs understanding of emergency and emergency commoditiescomes from the definition used in the state governorâs executive order (per state statute), thepresidentâs Stafford Act disaster declaration, or as stated by the state emergency managementauthority or FEMA. For most permitting offices, involvement in defining the emergency oremergency commodities rarely occurs.There is no single generic list of emergency commodities, and the commodities needed dependon the nature of the emergency. That said, a number of emergency declarations resulting in OWspecial permitting were commodity specific, usually related to harvests or a particularcommodity shortage like fuel, heating oil, or propane. Misunderstandings as to whatcommodities were and were not covered by any declaration resulting in special permitting led toconfusion and potential abuse of the special permitting process to move overweight divisibleloads that may not qualify as emergency supplies. This led to confusion among shippers andcommercial vehicle enforcement officers and poses potential road damage issues that may not berelated to the disaster in question. Potential Solution: Emergency Commodity Lists For emergencies affecting specific commodities (grain, fuel, etc.) language specifying those commodities should appear in both the disaster declaration and on any special permit. For other disasters requiring a diverse mix of commodities in divisible loads, Truck Permit Issuing Offices and state emergency management should work with FEMA and other federal agencies to develop lists of affected commodities needed in major, well- known disasters (like hurricanes or wildfires) and include those lists with special permits and provide to commercial vehicle enforcement agencies to ensure compliance.Variation in Special Permit IssuanceThere are variations in how states issue permits, depending on the Truck Permit Issuing Officeâsavailable resources and staffing. For instance, some states have in-house permitting systems foremergencies, some utilize third-party vendor products, some have a customizable template formfor emergencies, and a few others have a blanket emergency permit without specifics. One statehas an emergency permit shippers can apply for before emergencies and maintain in theirvehicles that specifies it becomes effective if accompanied by a state or presidential disasterdeclaration. Another state has a policy that the state declaration serves as the special permit inemergencies. Potential Solution: A Menu of Solutions Some state permitting agencies developed applications and processes tailored to issuing special emergency permits (Illinois). These systems provide the necessary information regarding the permit and what it covers to carriers and commercial vehicle enforcement officers. Other states use blanket permit systems (like those mentioned above). 50
Case studies of each may be required to develop models that fit specific state needs. Because of the varied nature of emergencies and disasters, and significant variances in state regulation covering special permitting in those situations, state regulatory requirements and enforcement expectations associated with the different models may prevent a single national model for emergency permitting.Different Enforcement StandardsCommercial vehicle enforcement during emergencies may also depend on available resources.Some states have lenient mechanisms that allow law enforcement officers and the shipper toindividually interpret the OW/divisible shipment requirements and whether the load complieswith the law and disaster declaration. For example, a governorâs disaster declaration is a permitin some states. In contrast, other states require the carrier to carry a general permit and thecurrent emergency declaration. Different states have stricter issuance and enforcementrequirements regarding when a carrier must apply for a special permit in eachdisaster/emergency and what that permit allows.Some states issue general OW special permits that become valid during a presidential or state-declared emergency or disaster. These usually require the declaration with the general permit tobe valid. This practice, while streamlined for efficiency, raised significant issues for enforcementofficers since drivers or companies sometimes treated the general permit as a semi-permanentexemption outside of the period of a declared disaster.Additionally, some commercial vehicle enforcement officers reported using the CVSAdeclaration portal to check permits, especially those from out of state. These officers reportedmisuse or misunderstanding regarding those permits and the use of expired permits beyond thedate of the declared disaster (where an extension did not occur or was not included with thepermit). Potential Solution: Increased Education and Outreach The impact of lenient mechanisms on neighboring states and the potential for safety issues require further study before making any recommendations. One model may not serve all U.S. states or regions. The use of the CVSA declaration portal and education efforts to encourage its use by commercial vehicle enforcement officers in all states could improve enforcement efforts. Additionally, there is a clear need to increase education efforts for carriers using special permits, especially those operating out of their normal service areas, across state lines, or in places where they lack knowledge of the permitting requirements in that state.Confusion Regarding FMCSR WaiversThe language in governorsâ emergency declarations can sometimes confuse carriers andauthorities. Because many states combine declarations waiving the FMCSR (a federal-onlywaiver) and OW special permitting, carriers may presume one, the other, or both conditionsapply when they do not. 51
Potential Solution: Increased Interstate Coordination and Declaration Standardization AASHTO and CVSAâs engagement with the National Governors Association may allow for the creation of standardized emergency declaration language agreements or sample OW special permitting declarations.Confusion About Restricted Loads and Routes During EmergenciesAlthough regular OS/OW carriers understand the restricted load requirements, carriers operatingwith overweight loads during emergencies may not regularly carry OS/OW loads and thereforemay not understand the importance of restricted load requirements. State Truck Permit IssuingOffices should provide the carriers receiving a special permit with written instructions on routingand safety compliance. Likewise, states do not have the authority to issue special permits for theinterstate highway system without a presidential disaster declaration and thus, state-leveldeclarations only affect specific state roads. Some states may only authorize OW special permitloads to travel exclusively on the interstate system and not allow those carriers access to stateroads when transiting through the state to another state where the disaster declaration applies. Potential Solution: QR Codes and Weblinks Among best practices examined, the use of special permit QR codes appeared the most promising. These QR codes embedded in a special permit link to routing and other information carriers and drivers need when moving loads on special permits. The ability to readily update that information on a website allows Truck Permit Issuing Offices to dynamically adjust routing depending on conditions or road closures in a disaster or modify a special permit if the disaster is extended, the permit modified by later declarations, or when specific commodities involved change due to the needs of the response. Further, such information access may provide drivers and carriers not used to frequently operating with overweight loads a more ready resource for understanding permit restrictions. Another benefit of the QR code is that both commercial vehicle enforcement officers and carriers can use it. Enforcement officers can quickly verify the permit, route information, commodities covered, and the period of permit validity via a cellphone or other Internet connected device with a QR code reader application. Although the CVSA disaster/emergency declaration website allows carriers/drivers to filter declarations to aid their understanding of roadway authorization (i.e., exclusive use of the interstate highway system), the implementation of standardized language or sample orders and education programs to instruct carriers and drivers on the specifics of permit authorization is necessary to improve compliance.Standardized Communication ProcessesCommunication is vital during an emergency, and while informal communication channels offersome efficiencies, they may fail in a crisis. Interpersonal relationships form informalcommunication networks between neighboring states, agencies, and regular OS/OW carriers. Inan emergency, personnel and carriers may come from many places, including out of state. Theymay not have experience with overweight shipping or connections to that stateâs Truck PermitIssuing Office or those they may transit through to reach the disaster. 52
Although state and trucking associations use various communication mechanisms forcommunicating about special permits during an emergency, few use anything resembling aformalized system, and most use informal networks developed from working regularly withinstate or neighboring state shippers. A few existing regional coordination mechanisms orsomething akin to the DoD DMC notification process inherent to their permitting, route, andconvoy system might serve as a model.Additionally, most Truck Permit Issuing Offices lack an understanding of emergencymanagement communications and the organizing structures used by emergency management andfirst responders, encapsulated in the National Incident Management System (NIMS). This limitstheir ability to communicate and coordinate with state and federal emergency management in adisaster, especially one that affects a wide area. Potential Solution: Formalize Communication Networks and Align with FEMA Standards In addition to publicizing and educating emergency management officials, shippers, inter- and intrastate commercial carriers, and Truck Permit Issuing Offices on the efficacy of the CVSA Emergency Declaration Portal and the importance of timely submissions to that system, state emergency management agencies, state DOTs, and Truck Permit Issuing Offices should establish uniform, formal communication and organizing principles for emergencies and disasters. National trucking organizations, the National Governors Association, and FEMA should consider developing and incorporating such procedures into NIMS and future emergency management documents. Additionally, these organizations should coordinate with FEMA to create a FEMA Emergency Management Institute Independent Study training course for emergency management, transportation officials, CMV Enforcement, and Truck Permit Issuing Offices on emergency waivers of the FMCSR and special permitting for overweight emergency commodity shipments during declared disasters and other state emergencies.Definition of Divisible and Non-divisible LoadsThe state issues special permits during emergencies with a clear understanding of divisible andnon-divisible loads. However, what constitutes divisible and non-divisible loads may bemisunderstood by nontraditional OS/OW carriers applying for special permits in emergencies.Likewise, shippers and carriers may know state-specific permitting requirements when thecarriers or shippers are in or from other states or organizations unfamiliar with special permittingin other states. Potential Solution: Provide AASHTO Examples AASHTO is already developing clear examples for divisible and non-divisible loads. Truck Permit Issuing Offices should consider including these on their office/permitting websites or provide links to the AASHTO examples when complete and made public.Confusion About Safety RequirementsThere is confusion in the freight community regarding special permits and FMCSR waivers forcarriers and truck drivers. State permitting agencies seem clear that safety requirements do notchange irrespective of weight requirements during an emergency. 53
Potential Solution: Development of training and informational fliers and worksheets for the trucking industry is recommended.Department of Defense Related SolutionsMulti-state Notification of Interstate Movements of Special Permitted Loads The DoD utilizes a system for convoy movements, TC AIMS II, that allows transportation officers to construct convoys in the system designating vehicle types, weights, and dimensions (drawing from a database containing that information for each vehicle). Once users specify their origin and destination, the system displays routing information and alerts each state DMC along that route to coordinate with their state authorities and, if needed, obtain the necessary OS/OW permits from the stateâs Truck Permit Issuing Office. DMCs are appointed military transportation officers or civilian employees in each stateâs National Guard that coordinate military movements with each state DOT. Potential Solution: TC AIMS II The TC AIMS II system is a potential model for coordinating interstate OS/OW special permit planning and permitting. Further study may be necessary to determine applicability. Still, the model of cross-state notification could potentially streamline regional or national emergency permitting in a presidentially declared disaster involving multi-state movements.Road Infrastructure for Oversize/Overweight Movements Although the DoD is involved in an ongoing program in coordination with states and DOTs to improve state and national highways to better support movements of military equipment to embarkation points, some of the same issues the DoD faces may affect emergency shipments of material or equipment during presidentially declared disasters. Examining routing, especially in disaster-prone areas like hurricane zones, could identify similar infrastructure issues that may affect the overweight movement of emergency supplies in a disaster, and improvements to infrastructure may be advisable in some disaster-prone areas based on routing assessments. Potential Solution: Improvement Programs on Designated Routes Hurricanes are a significant and regular disaster faced by many coastal states in the eastern and southeastern United States. These areas are also home to many DoD facilities and designated Ports of Embarkation. Given the ongoing program by the DoD to improve state and national highways and routing to support their movements from DoD bases to ports that may be hit by hurricanes, coordinating DoD specific improvements to infrastructure with those necessary to support broader disaster efforts could provide significant benefit. Further, given that such routes are assessed for overweight loads, state DOTs and Truck Permit Issuing Offices should consider those routes for the shipment of overweight divisible load emergency supplies during disasters and may wish to incorporate them into any disaster supply routing implemented as part of special permitting. 54
Oversize/Overweight and Emergency Routing in Disasters Potential Solution: Solution Similar to DoD Intelligent Road and Rail Information SystemThe Intelligent Road and Rail Information System (IRRIS), developed in 1999 and used by theDoD for many years, could potentially be a platform on which to base OS/OW routing duringdisasters. According to the DoD, âIRRIS is a Web-based system that uses informationtechnology to enable military users to obtain detailed, timely, and relevant information aboutroad conditions, construction, incidents, and weather that might interfere with the movement ofpersonnel and cargo from origin to ports through a user-friendly browser interface on theInternetâ (DTR, 2016). This system, which FEMA signed an MOU to use in 2007, could providea basis for routing in a major disaster or emergency involving intra- or interstate movements ofOW divisible and non-divisible loads, as well as in support of emergency transportationmanagement more broadly.That said, IRRIS no longer exists as a DoD program. According to Transcom, many of theprograms it previously used, like IRRIS, migrated to a new and different government developedgeographic information system collectively known as the Transportation Geospatial InformationSystem (TGIS), which is used primarily for tracking military shipments, though it does offersituational awareness for weather and other potential impediments to military moves, primarilyrelying on an ESRI Enterprise-based ArcGIS system to display ESRI and custom datasets (some,like weather, in real time). The TGIS system no longer provides some of the functionalitydescribed as contained in IRRIS.During this project, researchers were unable to assess IRRIS as it used to exist. However, IRRISwas a commercially developed system, and a private firm, GeoDecisions in Harrisburg,Pennsylvania, that developed IRRIS, still maintains a login website athttps://irris.geodecisions.com/web/login.aspx. It may not function as it once did, but conceivablyit or a similar third-party application may provide similar functionality to that described inprevious DoD reporting.DoD Domestic OS/OW Movements in Operations Other Than War Potential Solution: Regulatory Change or Language Inclusion in Authorizing LegislationPolicymakers and regulators may also wish to consider amending the USC or federaltransportation regulations to allow the DoD to conduct emergency OS/OW special permittingabsent a presidential disaster declaration but in a national emergency. Alternatively, Congressmay consider granting the president powers to include such measures in declarations of nationalemergency, or they may wish to have appropriate language in an authorization for the use ofmilitary force absent the declaration of war. 55
Figure 15. Description of IRRIS, Defense Transportation RegulationâPart III Mobility, Appendix I (3 March 2023) 56
