This joint response opposing the Government's proposal to increase trailer
lengths is from the following organisations Campaign for Better Transport,
Freight on Rail, CTC - the national cyclists' organization, Friends of the
Earth, Living Streets, Parliamentary Advisory Committee on Transport
Safety (PACTS), Sustrans and Road Peace.

Joint response to the DfT Consultation on proposals for Longer Semi Trailers from

 

We are grateful for the opportunity to comment on the consultation. The above mentioned organisations are all totally opposed to the introduction of longer semi trailers on safety, economic and environmental grounds.

Our response below draws upon the MTRU report Review of government proposals for Longer Semi-Trailers (LSTs) which has analysed the Impact Assessment and reports in detail and forms the major element of our response. Review of government proposals for Longer Semi-Trailers (LSTs) by MTRU

Summary
We are concerned that the assessments undertaken significantly under-estimate the safety, road congestion and environmental impacts of longer lorries on society and the economy and that the proposal if implemented, would put certain lorry industry interests ahead of road safety and carbon reduction despite the consultation document’s stated aims to reduce CO2 emissions and road freight miles.

The safety analysis seriously under-estimates the increased collision risks associated with longer trailers and fails to acknowledge that most of these collisions happen because of a combination of factors. It assumes that very few collisions involving articulated HGVs (15%) are in any way influenced by length. Before even considering exposing other road users to the increased risks associated with longer trailers the Government should adopt policies to improve existing road safety and enforcement of existing road regulations. It should take into account the fact that the road haulage industry overall does not have a good record in complying with existing road regulations and this puts other road users at extra risk.

We question how allowing an increase in the maximum permitted length of semi-trailers can be defined as a policy objective on page 1 of the Impact Assessment.
 
The case for longer lorries relies on the same questionable presumption used in the past to justify each increase in lorry dimensions, that there would be fewer but bigger trucks on the roads. In practice however, since the previous increases in dimensions there is no direct evidence of larger or heavier lorries leading to improvements in average payloads or a reduction in empty running. In fact one in four HGVs are driving around empty 1. A reduction in empty running would have a far greater impact on congestion and emissions than increasing lorry dimensions. Germany has reduced empty running by 20% to below 20% over the past decade, at least partly as a result of its lorry charging scheme.

Freight on Rail’s legal advice is that, under current EU legislation (EU Circulation directive  96/53)  the UK Government can only introduce longer trailers on a trial basis. And that any attempt to change the legislation so as to legalise this extra length on a permanent basis will strengthen the already heavy external lobbying for much large “mega trucks” of 25 metres 60 tonnes weight, to which the Government has expressly stated it is opposed.

Were the correct economic assumptions used with proper consideration given to congestion implications,  longer trailers would be shown to cause additional carbon dioxide emissions, more road freight tonne miles, more road congestion and more collisions, the reverse of what is being claimed would happen. The longer lorry will become the default vehicle, small hauliers will find it even harder to compete with the big operators and rail freight will be undermined. Further increases in weight and size will be likely, possibly including mega trucks from continental Europe. 

1. Road Safety
While the Government admits that the longer trailer would increase tail swings and susceptibility to cross winds in its executive summary, the assumption is made that neither the 1 nor 2 metre trailer would  be any more dangerous than existing HGVs per mile driven.  Even on the basis that the longer trailer will occupy more road space, this analysis is not credible.  It is generally acknowledged that collisions are normally caused by a combination of factors. However, the Impact Assessment has assumed that 85% of collisions involving HGVs are unaffected by length 2. For example, in relation to fatal crashes within 20 metres of a junction, one of the largest categories, 99% were assumed to be outside the scope of the report 3.  Such adjustments have a major impact in reducing the predicted safety effects of LSTs. Without these exclusions, the longer lorries could be calculated using DfT figures to cause an additional 6 fatalities per annum and increase overall accident rates between 4-8%.

DfT research underestimates the extent to which the longer vehicle will be individually more dangerous in non motorway situations
In urban and rural environments where tight turns are made, the out-swing of the rear of the trailer will double to over 2 metres and this will occur in the driver’s increased blind spot. Even many recently designed junctions could not accommodate such trucks without their entering ‘wrong’ lanes or mounting the footway or traffic islands. This will be particularly dangerous for all other road users who may get side swiped as it will not be obvious to them how the back of the lorry will swing out into another lane.
(See computer modeling attached in MTRU appendix 1 pdf file junction euro lorries by Alasdair Massie CEng MIStructE)

Conflict between tail swing problems and cruising stability
This added length brings unanswered questions about how to overcome the conflicts between dangerous tail swings and snaking at higher speeds (rear amplification) as the ideal positioning of axles  for weight distribution is not the ideal one to avoid snaking. If axles are positioned at the back of the vehicle there is less snaking but there is less maneuverability. There are complex interactions between load distribution, axle type and positioning and the safety, road damage and congestion effects which have not been fully addressed in this research. 

Implications for urban and rural road junctions and loading bays.
In urban areas, these longer lorries could get stuck half way through a manoeuvre and have trouble negotiating ramps and be too big for many loading bays. In practice, local authorities will in some cases, as a result of the extra space taken by these longer vehicles, suffer increasing damage. The report includes no analysis of the additional costs to local authorities as a result of these impacts, which will have to be borne by the taxpayer.

Compare like with like in safety analysis
There is also the important principle of comparing like with like, accepted for EU studies.  This means that is wrong to compare a new trailer with additional safety and maneuverability features with a lower standard trailer type which is currently in use.  The highest standards of trailer technology available should be implemented as soon as possible on current 16.5 metre HGVs and then future longer trailers compared to these higher standard vehicles. 

Before even considering exposing other road users to the increased risks associated with longer trailers the Government should adopt policies to improve existing road safety and enforcement of existing road regulations.

The fact that the road haulage industry overall does not have a good record in complying with existing road regulations which put over road users at extra risk should be taken into account.

• Existing HGVs are over three times more likely to be involved in fatal accidents than cars on major roads due to a combination of size, lack of proper enforcement of drivers' hours, vehicle overloading and differing foreign operating standards (Road Statistics 2008, Tables 3.2 and 3.6, Road Freight Statistics 2008 Section 5, both UK Department for Transport)

• Over 83 per cent of HGVs exceeded the 50 mph speed limit on dual carriageway non-built-up roads and 75 per cent exceeded the 40 mph limit on single carriageway non-built-up roads (DfT, Road traffic speed congestion, June 2010)

• The Mayor of London, at considerable public expense is phasing out the bendy bus, which at 18 metres are a similar length to the proposed longer trailer, as they caused more than twice as many injuries as other buses (Evening Standard June 7th 2007)

2. Economic analysis against longer trailers
Same flawed argument being used again to justify increasing lorry dimensions
The case for longer lorries relies on the same questionable presumption used each time to justify lorry dimension increases, that there would be fewer bigger trucks on the roads.  However, in practice since the last increases in dimensions there is no direct evidence of larger or heavier lorries leading to improvements in average payloads or a reduction in empty running with one in four HGVs driving around empty 4. A reduction in empty running would have a far greater impact on congestion and emissions than increasing lorry dimensions.

Longer trailers will add to road traffic
The claimed environmental benefits of longer trailers would rely on very high levels of load utilisation – in excess of that routinely achieved within the haulage sector. If the sector is unable to consistently fill smaller vehicles, it is unclear why or how it will be able to fill longer ones? The current argument for this length increase is that some loads are volume constrained (42% according to DfT figures) but that is because weight limits were increased from 40 to 44 tonnes in 2001. If you increase the volume you will hit new weight limits, so you have a see-saw between length and weight increases as it is difficult to optimize for both weight and volume. The proponents of longer lorries are using the same flawed arguments used previously to justify dimensions increases.

FTA already pushing for increased weight limit to 46 tonnes
The Freight Transport Association’s lobbying for a weight increase to 46 tonnes both undermines the volume constrained argument for the longer trailer and demonstrates that the industry goes on asking for bigger heavier HGVs.  The DfT research 5 shows almost half cargos are neither weight or volume limited (ie only partially loaded). This proposed longer and thus heavier trailer, will be able to carry even less weight than an existing HGV.

Load factors and traffic reductions
The  DfT research appears to assume that significant number of partially loaded existing HGVs will no longer be partially loaded in the new bigger lorry. (We did ask the Department for clarification on these figures at our meeting on 17th May) Given that these load factors are currently low, why would they increase.  As 37% of the predicted benefits in terms of lower vehicle kilometres are derived from this category, we are awaiting clarification from the DfT.

Longer lorries will become the universal HGV size
The reality is that it is a 7 foot increase in lorry length and 17% increase in trailer length for what will become the standard lorry on UK roads. Statistics show that hauliers tend to buy the largest vehicle permitted and use it for large and small loads, irrespective of the impact on efficiency and consolidation. (see 6).

Longer trucks would mean more lorry miles not fewer because demand will be stimulated as longer trailers would reduce road haulage costs by up to 13%. Distribution centre are likely to be rationalised, saving on real estate costs, with lorry tonne kilometres increasing as the same freight is carried further.The economic assumptions in the report are not realistic as they underestimate the extent to which longer vehicles will add to road mileage.

Longer trailers will be slower to negotiate road junctions and add to road congestion
The actual length of traffic lane occupied and the time that the lane is occupied needs to be fully taken into account. HGVs are considered to take up almost 4 times the space of an average car when stationery (passenger car units). Then one has to allow for the fact that HGVs are slower to negotiate junctions and need longer front and rear headway than cars as braking distances are greater.

DfT research has only assumed that a third of the additional length will increase the requirement for road space and thus impact on congestion; however if a two thirds adjustment were applied which is an more accurate way of allowing for all the different road conditions, DfT uses it as a sensitivity test, 90% of the congestion benefits are removed from option 6 the 2.05 metre increase matching current regulatory standards and two command steer axles. As a guide line, in situations where headways are a relevant factor with stop start traffic, the change in pcu value would be close to the percentage change in length plus headway ie the increased time taken to negotiate junctions will increase in a similar % as length increase.

3. Instead of having larger HGVs make existing road haulage more efficient.
There are alternatives. The Government should look at incentives to improve efficiency of existing sized HGVs, instead of increasing lorry lengths. The Road Haulage Association has pointed out that many longer trailers would have less volume capacity than existing double decker HGVs.  In the past decade, Germany, which initially started  with a vignette lorry road user charging system and then moved to a distance based one in 2005, has reduced empty running by 20% to below 20%.

The European Commission acknowledges that Europe needs to take action to reduce freight’s carbon dioxide emissions and transfer 50 per cent of long distance freight to rail and water by 2050 to achieve this 8. In the foreseeable future, electric technology offers little scope for lorries, unlike cars.

4. Road Haulage Industry divided on the merits of longer trailers
While certain logistics operators and their customers will undoubtedly be able to make use of the extra volume and will be able therefore to increase their efficiency, (typically big logistics operators tied to supermarket logistics), who are lobbying Government for this increase, the bulk 9 of freight operators and users are not big companies or big hauliers, and these will lose out by having to buy and run new longer vehicles for general use, mostly not utilizing the extra capacity. Small and medium sized hauliers have been muted in their concerns about longer trailers in the public domain for fear of jeopardizing relationships with their customers. 
 
MTRU has estimated that small and medium sized hauliers would lose up to  £1.8  billion over 5 years in depreciation costs, a figure that the DfT has not attempted to calculate.

5. Non-monetised environmental factors ignored
Non-monetised environmental factors related to length such as severance and visual intrusion which impact on pedestrians and, cyclists and non-road users are omitted entirely. Similarly, nuisance and intimidation caused to drivers and passengers in other road vehicles are not included, which are likely to be very significant and are not included in the IA, despite these being standard items in transport appraisal. There are also impacts on the built and natural environment which are unaccounted for, from trees and hedgerows to buildings and other roadside structures.

6. Longer lorries would contradict Government policy to increase rail freight   
The DfT central case is built on the prediction that road operators will increase their share of goods traffic as a result of introducing longer lorries, despite its stated commitment to increase rail freight which is backed by the public and has grown its surface market share from 6 to 11% since 1996. In particular, consumer rail freight which has grown for the 8th consecutive year and now outstrips coal traffic per billion tone km, would using the DfT figures be severely undermined and forecasted growth would be cut by two thirds.

Lower rail use is a major source of benefits in having longer trailers according to DfT research.
Between 27% to 32% of the environmental benefits of longer trailers are assumed to be gained by running fewer trains. By 2025 - 84% of the industry operational savings would be from lower rail costs. The assessment is very sensitive to the way that less rail traffic translates into fewer train kilometers and a realistic picture would be of external costs rising significantly. Also, if trains were electrified or became quieter, the benefits of not running them would fall and so would the benefits of longer trailers.

Longer trailers would undermine low carbon energy-efficient rail, particularly the emerging supermarket (domestic intermodal) rail traffic, the sector with the highest growth potential of up to 12 times in a 25 year period 10. Even the DfT figures states that the 2 metre trailer would reduce rail freight growth by two thirds (down from 732% to 262%) by 2025. This is because the relative costs of road and rail will be adversely affected by the new units, and rail will face a cost disadvantage; savings of up to 15% are predicted by some in the road haulage industry. However the DfT suggest that this impact would be offset by rail operator being able to use longer intermodal units than at present, increasing their own efficiencies.  However, this assumes that customers will want to invest in such units, ahead of investing in road fleet and also that the existing equipment, much of which is new, can be written off. All this is likely to result in a downward spiral for rail freight in this sector as critical mass is lost.

• Rail freight produces 70 per cent less carbon dioxide emissions than the equivalent road journey (DfT, Logistics Perspective, December 2008, p8 section 10)

• A tonne of goods can travel 246 miles by rail as opposed to 88 miles by road on a gallon of fuel (Network Rail, Value of Freight, July 2010)

• An average freight train can remove 50 long distance HGVs and an aggregates train can remove up to 160 long distance HGVs from our roads. (Network Rail 2010)

7. Increasing lorry sizes risks opening up the way to mega trucks of 25 metres 60 tonnes from Europe
Any increase in semi-trailer length, even for national traffic only, seriously risks opening up the current Directive 96/53 EC on grounds of unfair competition, which treats semi trailers and road trains ie draw-bar operations differently. Legally, this means that the DfT can only allow 2 metre longer HGVs on a trial basis unless it wants to risk opening up the circulation directive. Once opened, amendments can be made for increasing the length and weight which could lead to mega trucks of 25.5 metres and up to 60 tonnes in weight coming to the UK.

8. Claims for better cab designs are not viable
The DfT claims that one of the benefits of longer vehicles will be safer and more energy efficient cabs. But the benefits of what it is proposing would be very marginal. The DfT favours a 0.2 metre cab enhancement which would allow it to have a 2.05 metre trailer length increase and remain within the 18.75 metre limit. This would only have a 2% fuel efficiency gain and very limited safety gains. The marginal benefit of 0.2 metre proposal would render the cab redesign commercially unviable which raises the question about whether this a serious review of aerodynamic  cab design.

DfT Consultation Questions – please refer to MTRU research as below

Q1. Longer lorries will become the universal HGV size
The reality is that it is a 7 foot increase in lorry length and 17% increase in trailer length for what will become the standard lorry on UK roads. Statistics show that hauliers tend to buy the largest vehicle permitted and use it for large and small loads, irrespective of the impact on efficiency and consolidation. (see MTRU report P22 chart 3).

See MTRU report section Buying tailers which are larger than needed for most work
P 21-22 chart 3

Q2  Please refer to the safety analsysis in MTRU report section 2 pages 11-15

Q3 Refer to MTRU report P21-22 chart 3 to see pattern of purchasing of largest permitted HGV.

Q4 Detailed economic analysis using industry standard elasticities and proper consideration for congestion impacts of longer trailer show overall monetarised external costs in introducing either 1 or 2 metre longer trailers see MTRU report all Chapter 3 and chart 4

Q5 Table 5: Summary of LST Take Up Input Assumptions for each Scenario

Scenario			Conventional HGV-km in 2009	Low	Best Estimate	High
				Distance threshold
			%	150km	120km	100km
Category	1	Volume-constrained but not weight-constrained travelling distances greater than threshold	34.1%	50%	90%	100%
	2	Volume-constrained but not weight-constrained travelling distances less than threshold	8.4%	0%	45%	75%
	3	Not volume or weight constrained travelling distances greater than threshold	34.3%	50%	90%	100%
	4	Not volume or weight constrained travelling distances less than threshold	12.3%	0%	45%	75%
	5	Weight constrained travelling distances greater than threshold	8.9%	0%	20%	25%
	6	Weight constrained travelling distances less than threshold	2.0%	0%	5%	10%

Source: Impact Assessment of Longer Semi-Trailers, DfT 20/12/2010
Table 5 shows that almost half of loads (46.6%) are neither weight or volume constrained ie partially loaded which does not make a strong case for increasing lorry lengths and makes an even poorer case for weight increases, for which some in the industry are already lobbying.

In particular we think that the argument that all loads neither volume nor weight constrained will benefit from 50% of the increase. If existing sized lorries are not filled, why would even larger ones be full?

Go to MTRU report Load factors and traffic reductions P16-17

Q6 No allowance for the cost of early retirement of existing semi-trailers by all operators, especially public hauliers, to ensure fleet interoperability and ability to maintain competitiveness this could be as much as £1.8billion over 5 years.
See MTRU report chapter 4 P20-P22 including chart 2

Q7 Cannot offer specialist information

Q8  We believe that the full costs to society in safety, environmental and road congestion terms has not been properly evaluated. Nor is there any analysis of the extra driver stress  negotiating the road network and trying to find vehicle parking. There does not seem to be a question about external costs to the wider society as a whole.

See  all chapters in MTRU report summed up on Page 26 in chart 6
 
Non-monetised environmental factors related to length such as severance and visual intrusion which impact on pedestrians and, cyclists and non-road users are omitted entirely. Similarly, nuisance and intimidation caused to drivers and passengers in other road vehicles are not included, which are likely to be very significant and are not included in the IA, despite these being standard items in transport appraisal.

Q9,10,11,12,13 Safety considerations
The safety case for longer trailers has not been satisfactorily made in the research as it is simply not credible to state that a 2 metre longer lorry will present zero increase in accidents, even based on the amount of extra road space a longer vehicle will occupy.

There is no “like for like” safety comparison – there is no introduction of best available technology for the base line, and instead new and improved trailer designs are compared to existing trailers.
It is assumed that very few accidents involving articulated HGVs (15%) are in any way influenced by length, this is based on a series of individual judgements and takes no account in the increasing probability of accidents occurring.
This leads to the assumption that there is a zero increase in danger from longer vehicles and that there is no difference between 1 or 2 metres extra length.

For detailed analysis of safety issues see chapter 2 Safety of MTRU report

Q12. Enforcement of locking of steering axles could be a problem

Q14 & 15  Claims for better cab designs are not viable
The DfT claims that one of the benefits of longer vehicles will be safer and more energy efficient cabs. But the benefits of what it is proposing would be very marginal. The DfT favours a 0.2 metre cab enhancement which would allow it to have a 2.05 metre trailer length increase and remain within the 18.75 metre limit. This would only have a 2% fuel efficiency gain and very limited safety gains. The marginal benefit of 0.2 metre proposal would render the cab redesign commercially unviable which raises the question about whether this a serious review of aerodynamic  cab design.

In order for serious improvements in safety and fuel efficiency, it is likely that a cab increase of around 0.8 to 1 metre would be needed. Under EU vehicle type and circulation directives no increase in cab length could be carried out.  

Q16 & Q17. There could be considerable problems with load bays and ramps.
Draw bar lorries often do not fit into existing loading bays

Other infrastructure costs because of the extra tail swing include repair to street furniture.

Load distribution factors and the resulting extra wear and tear costs on road surfaces need to be fully evaluated.Even slight axle overloading has a disproportionate effect on road damage. See MTRU report P14/15

Q17 We would point out that overloading also has safety implications.

Q18 Impact on rail freight
This question underlines the whole justification of longer trailers and raises questions about Government policy to promote rail freight, reduce carbon dioxide emissions and road congestion. What is the purpose of longer trailers which will undermine rail freight the low carbon energy efficient long distance alternative.  Is the purpose of longer vehicles to undermine rail – or cause road to be more efficient in itself?

Even the DfT’s own figures forecast that intermodal rail freight growth will be cut by two thirds if longer trailers are introduced.  

Lower rail use is a major source of benefits in having longer trailers according to DfT research.
Between 27% to 32% of the environmental benefits of longer trailers are assumed to be gained by running fewer trains. By 2025 - 84% of the industry operational savings would be from lower rail costs.

See MTRU Less rail use augments LST benefits P24-25 see chart 5.

Q19 Rail freight industry experts to comment

Q20 & Q22

(As above Q6)

No allowance for the cost of early retirement of existing semi-trailers by all operators, especially public hauliers, to ensure fleet interoperability and ability to maintain competitiveness this could be as much as £1.8billion over 5 years.

See MTRU report chapter 4 P20-P22 including chart 2

Q21 outside area of expertise

Way Forward

Q23,Q24,Q25

Presumption in these questions appears to be that longer trailers will be permitted

Q23 Our understanding is that under existing EU rules which treat semi trailers and road trains differently, longer semi trailers are not permissible, even for national traffic, because it conflicts with fair competition  other than for trial purposes    

It states that the maximum length for semi trailers is 16.5metres; road trains are handled separately in the directive with maximum length of 18.75m.
Ref  Directive 96/53 EC, International traffic, Annex 1 1.1 Page 11

 

Philippa Edmunds Freight on Rail Manager - Campaign for Better Transport
20th June 2011

 

1. DfT figures CSRGT MTRU report 2011 P24 Chart 6

2. Table 20 page 60 TRL PPR 526

3. Table 19 TRL report PPR 526

4. DfT figures CSRGT MTRU report P8 Figure 1C.

5. Table 5: Summary of LST Take Up Input Assumptions for each Scenario
Source: Impact Assessment of Longer Semi-Trailers, DfT 20/12/2010

6. MTRU report 2011  report P22 chart 3

7. Review of Income and price elasticities of demand for traffic, Final Report Graham and Glaister Imperial College July 2002

8. EU Transport White Paper Monday 28th March

9. Lorry fleets of 10 or less vehicles make up almost half lorry fleet in UK  Source Vehicle and Operator Services Agency

10. Network Rail The Value of Rail Freight July 2010 Domestic intermodal growth highest forecast 1200% in  tonne km between 2006/07 and 2031