RHA response to DfT LST consultation
Comment or questions: campaigning@rha.uk.net
RHA response to DfT LST consultation
Contents (In order added to site):
RHA response to DfT LST consultation
LST height clarification
Investment and length of trial
Longer semi-trailer – DfT consultation highlights
Consultation questions
Click in the link for the LST DfT Response (22.06.2011):
LST DfT Response June 2011.pdf
Click on the link for full document in PDF: RHA response to DfT LST consultation
LST height clarification
The Department for Transport has clarified an important point on trailer heights in its longer semi-trailer (LST) consultation that led to us mis-reporting its proposal in our summary last week. The Department accepts that the consultation could have been clearer.
Ministers’ intention and proposal is to allow 15.65 metre LSTs to run operationally without height restriction. Those vehicles will be in tractor/semi-trailer combinations that have performance levels that meet UK and EU turning circle requirements but which perform a little less well than the artics the industry is used to running at present.
The DfT has also identified a running height limit for operational trials of 4.57 metres, for trailers that perform as well as existing trailers.
The lower height limit, tail swing and other detailed requirements for meeting existing performance would potentially give ministers a fall-back position should there be need to retreat from the intention to allow the LSTs without a height limit; they would be able to authorise LSTs with a performance no worse than existing artics. It is understood that at least one large operator is willing to trial at the lower height, embracing also the other, tougher requirements for existing performance.
The 4.57 metre height is considered to have about the same stability and blow-over risk of a full-height current artic.
There will, therefore, be two tall trailer trial heights for 15.65 metre LSTs, assuming trials are authorised: full height, as now, which meets the legal standards; and 4.57 metres meeting current performance. (See Level 1 and Level 2 specification: http://www.dft.gov.uk/consultations/open/2011-06/consultationdocument.pdf Annex B pages 21 and 22.)
Tests could take place, of course, at full height and meeting current tail-swing performance, although that option is not spelled out in the consultation.
One complication is that the consultation document repeatedly states that the technology for the 15.65 metre trailer to meet current artic performance is unlikely to be ready for 18 months – the latest estimate is summer 2012. But some firms may want to run their operational test before that if they are able to accelerate availability.
The consultation sets no standard for stability for full-height 15.65 metre trailers but asks if that should be done and if so, how.
In addition, there is much discussion around LSTs that are around one metre longer than the current limit, with a single self-steered axle. The height issue and other technical requirements are not separately addressed for these trailers.
Investment and length of trial
Operators would be able to put LSTs on the road under Vehicle Special Orders (VSOs) from the DfT. A key issue is likely to be the length of those VSOs and whether they can be guaranteed for the full term. Periods of one year to six years have been mentioned in discussion and this is expected to be an important issue in consultation responses. It is unclear when regulation would be enacted but the latest indication is by the end of 2012.
The VSOs could be issued as early as late summer 2011. However, we are advised that it is impossible to say, for example, that they will be authorised from September 1, as some members have been advised by suppliers. The three-month consultation results have to be assessed – which could happen quickly. The European Commission has of course been advised.
Longer semi-trailer – DfT consultation highlights
The Department for Transport issued a lengthy and detailed consultation on Longer Semi-Trailers (LSTs) at lunchtime today. Key issues include a likely height limit and acceptance of greater swing-out. LSTs could be on the road by late summer.
Throughout what has been an extended process, the RHA has sought to engage with government and to inform members. In surveys, the balance of members has been opposed to the proposed increase, although many members have declared themselves in favour. This split applies to small, medium and larger member companies.
We now plan to engage and consult intensively with government and with members, in confidence.
Initial viewing of the consultation highlights:
Consultation is “on the possibility of allowing an increase in the length of articulated lorries”.
DfT is proposing an increase in permitted semi-trailer lengths of 2.05 metres to 15.65 metres, to allow same load length as a truck and trailer combination.
Overall artic length to be increased to 18.75 metres – the truck and drawbar length – to allow for an increase in the length of tractor unit cabs. (Note: It follows that the load length on truck and drawbar combinations will reduce, if cab lengths increase. This would be a Europe-wide issue and we are unaware of any proposal in the short term.)
DfT proposes to specify existing EU turning circles standard and accepts that the standard permits greater swing-out than is the performance of current artics with 13.6 metre trailers.
This issue has concerned many RHA members – and a proponent of LSTs at DHL noted in the House of Commons a year ago that the firm did not want to operate them in urban areas. Nonetheless, DfT says that while accident risk per truck may increase slightly, it forecasts a net reduction in accidents due to reduce lorry numbers.
New active steer technology would enable LSTs to perform to current standards but the technology will not be available for another 18 months. This may be a highly significant point and it is referred to repeatedly in the Executive Summary. (Note: This is thought to refer to electronic steer technology being pioneered by Cambridge University.)
The DfT also discusses an increase of up to 1 metre to 14.6 metres, which would be technically simpler but would, it says, effectively limit gross weight to 40 tonnes, because of trailer axle loading, where the axles are unsteered. The 44 tonne limit can be achieved with one self-steer axle at 14.6 metres.
No increase in the 44 tonne limit will be allowed, DfT says.
The DfT says research findings show the longer trailers “could have a significant potential net benefit to road haulage as well as wider benefits in terms of reductions in congestion, local air pollution, carbon emissions, accidents, noise and infrastructure costs”. (Note: We have not yet had the opportunity to review the evidence. A group of mostly medium-large members who met the DfT 18 months ago questioned the extent of carbon benefits.)
Depending on the outcome of the consultations it may permit the operation of LSTs “on a trial basis pending the introduction of the necessary changes to current Regulations”. (Note: LSTs could, therefore, be on the road by late summer. I similar approach was taken by the Dutch to the introduction of 25.25 metre rigs.)
The DfT says the consultation will enable it to “identify proportionate mitigation measures to minimise the risk of unintended adverse consequences”. (Note: Officials declined to be drawn on what that might mean.)
Importantly, the DfT is asking for further input. It accepts that its research is based on desk modelling and asks for financial and business analysis of the impact of the proposed change, which will – it emphasises – be treated as commercial in confidence.
Lastly, the DfT has adopted the term “high-volume semi-trailers” in the consultation, in order, it says, the avoid confusion with 25.25 metres rigs run by the Dutch and Swedes and proposed here by Denby Transport. This may also address the concerns of the strongly pro-LST lobby, which is concerned that LST may have a negative connotation. However, “high-volume semi-trailers” seems to us to be less accurate than LSTs and potentially misleading.
Many of the longer trailers will have much less volume than a standard length double-decker, for example. LST says exactly what is proposed and, as the DfT acknowledges, is well-accepted. The RHA is therefore continuing to refer to LSTs, to allow people to understand what the debate is about.
The RHA will be engaging intensively with members, suppliers and government and we will be developing this briefing. We welcome all feedback, which will be treated in strict confidence.
Links:
- WMS-
http://www.dft.gov.uk/press/speechesstatements/statements/penning20110330b
- Consultation - http://www.dft.gov.uk/consultations/open/2011-06/
- Research paper - http://www.dft.gov.uk/pgr/freight/research/longersemitrailer/
General note: This issue is regarded entirely separately from the 4 metre trailer height problem currently being played out in Brussels. Our best guess is that the 4 metre limit will ultimately be removed from the draft Whole Vehicle Type Approval Regulation but that is by no means certain.
Consultation questions |
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| Q1. Do you agree that the research has identified the correct sectors that would be engaged in the introduction of high volume semi-trailers? If not, how and why would other sectors be engaged? |
| Q2. In light of the impact assessment and the lead time on the active steering technology, the Government is minded to opt for existing standards instead of tighter standards, at least initially. Under such circumstances what types of trailers would manufacturers and operators expect to develop / purchase as a result of the full 2.05m deregulation and why? |
| Q3. Table 5 of the Impact Assessment and the accompanying text explains the approach to estimating the likely take-up of high-volume semi-trailers in the sectors engaged. Do you have any evidence on the likely take up that would increase the Government’s understanding of the impacts? Please supply business analysis or other evidence to support your position, showing the tonne-km anticipated to move to high-volume semi-trailers. |
| Q4. The research concludes that the greatest benefit derives from allowing increases of up to 2.05 metres in semi-trailer length. Do you agree with this assessment? If not, please give your reasons including supporting evidence. If there is particular data in the Impact Assessment that you disagree with please supply us with evidence to update our assessment. |
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Financial impacts |
| Q6. We require financial analysis of the impact on capital and operational costs for different types of business resulting from this change (including whether there is likely to be early write-down of assets which are not fully depreciated) If you represent a company can you supply us in confidence with financial analysis regarding how your business would implement a change of up to 2.05m. If you represent a trade association can you assist us in gathering data to show how industry sectors are likely to react to the change? |
| Q7. Large, medium and small businesses in varied sectors of the freight industry are likely to react differently to the introduction of high-volume semi-trailers. Can you help us segment the impact on different sizes of companies in the sectors concerned? In particular can you provide financial analysis for individual businesses to show how they are likely to respond? |
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Safety Considerations |
| Q9. Assuming that, at least initially, the requirement is for highvolume semi-trailers to comply with existing standards, how could commercial development of the active steering technology be maintained? For example, would you be supportive of attaching conditions to Vehicle Special Orders (VSOs) to encourage the use of active steering technology or do you see another, more effective mechanism? |
| Q10. If the Government were to opt for tighter standards in the future, when would trailer manufacturers be in a position to supply sufficient actively steered trailers to meet the likely demand? |
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| Q13. Both standards also assume that semi-trailers with steering systems should also comply with certain relevant type approval requirements (as suggested in the draft Technical Requirements for the trial). Do you see difficulties in specifying these requirements for the trial? |
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Improved Frontal Design |
| Q14. An overall increase in the permitted length of an articulated lorry to 18.75 metres would accommodate a safer more aerodynamic frontal design of between 0.2 – 0.4 metres in parallel with an increase of 2.05 metres in the length of a semi-trailer, depending on whether or not the semi-trailer were fitted with a close coupling arrangement. What advantages or disadvantages do you see in allowing an increase in overall length to 18.75 metres? If there are both advantages and disadvantages, which do you see as the most important? |
| Q15. The implications of an improved frontal design for operators and other road users are discussed in section 7 of the TRL report, “Safer aerodynamic frontal structures for trucks: final report”. Do manufacturers agree with the results of the modelling work and in particular do they have any of their own evidence from investigation of this subject? If you represent an operator would you expect to take up these vehicles given the costs and benefits? In particular, do these results suggest the payback would be sufficient to justify investment? |
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Impact on Infrastructure |
| Q16. The Impact Assessment assumes that there will not be a need for significant changes to road infrastructure from the introduction of high-volume semitrailers, as the overall length would not exceed that of a rigid truck / drawbar trailer combination already allowed on the UK’s roads. Do you agree that this is a valid assumption? If not, please give your reasons: e.g. are there potential constraints with loading bays? or at lorry parking facilities? |
| Q17. The Impact Assessment also indicates that an increase in semi-trailer length of 1 metre with un-steered axles would effectively reduce the gross vehicle weight from 44 to 40 tonnes, thereby reducing loading capacity and introducing a risk of axle or axle group overload. Do you see a need for on board weighing devices to ensure that axles on this type of semi-trailer are not overloaded? Do you feel that the potential additional costs would affect the take-up of these semitrailers? |
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Impact on Rail |
| Q18. Has the research correctly identified the rail market that will be affected by the introduction of high-volume semitrailers? If not, can you provide evidence to show why other markets could be affected? |
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| Q19. Is it likely that longer intermodal loading units would be developed as a response to allowing high-volume semitrailers, and would they be used giving an increased loading capacity for domestic intermodal trains? Are there any operational issues or costs that have not been accounted for that arise as a result? |
Impact on Small Firms |
| Q20. The Small Firms Impact Test in Annex 8 to the Impact Assessment explains our knowledge to date of the effect of this proposal on small firms. However, we are keen to gain direct assessments from micro, small and medium size firms3 of the impact that allowing high-volume semi-trailers would have on their businesses. The Impact Assessment provides detailed figures at paragraphs 79-80 of the characteristics and costs of high volume semi-trailers which could help smaller firms assess the impacts on their business. In particular, what costs would firms expect to incur, and what benefits would they expect to gain, from the use of the vehicles? |
| Q21. We would like to further understand the payment methods for small firms when delivering to large retailers: for example, we would like to get evidence from firms of whether they are paid per load or per pallet, and how rates are decided or negotiated. |
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| Small firms: 10 – 49 employees |
| Medium firms: 50 – 249 employees |
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| Q22. We would like a better understanding of the reported pressures on small firms to invest in the largest available vehicles even where this means operating on part loads at reduced fuel efficiency. |
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Way forward |
| Q23. If the proposed modifications to articulated lorry and semitrailer length are permitted (either in a trial or through amendment of existing legislation), what is a reasonable estimation of the time that would be needed to enable industry to make the appropriate investment and acquire new vehicles? |
| Q24. Assuming the proposed modifications are introduced in the first place through a trial involving Vehicle Special Orders (VSOs), how rapidly would interested operators expect to apply for a VSO, how many vehicles would they expect to apply for, how many applications would this imply and by when? (Information about Vehicle Special Orders can be found at www.vca.gov.uk.) |
| Q25. If high-volume semi-trailers were permitted permanently, what proportion of its fleet would your company or organisation expect to switch to these vehicles by 2015 and by 2020? Please supply evidence on your current fleet and your operations to explain the change you anticipate. |