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Manchester Freight Strategy.

  1. Freight on Rail thanks Transport for Greater Manchester (TfGM) for the opportunity to comment on its Freight Strategy.

    (The Page numbers referred to are your page numbers in the consultation document)
  2. The Vision

    Increasing the use of rail freight, the low carbon safer congestion busting alternative to HGVs, will enable TfGM to achieve its vision, as part of integrated freight distribution. Need to highlight that freight transport is a very important part of the North’s economy which has approximately a quarter of the UK’s population but hands around a third of multi-modal freight.TfGM needs to be a strong voice alongside TfN to help deliver the rail infrastructure capacity and capability needed for rail freight forecasts to be met.

  3. Rail freight can help achieve the following outcomes:-

    To support sustainable growth

    With less congested roads, more reliable journey times, a resilient network.

    To improvethe quality of life for our residents

    Improved road safety through reduction in HGVs and local environments not dominated by traffic, noise & pollution.

    To help protect our environment

    A reduction in harmful emissions from freight vehicles, a reduction in the damage that transport can do to natural environments.

    To develop Greater Manchester as an innovative city region

    Reduce environmental impacts
  4. Page 5 Spatial Planning

    Devolved and local Government has a key role in safeguarding potential suitable sites for rail freight terminals of differing sizes and protecting rail alignments. Therefore it is vital that the Greater Manchester Spatial Framework recognises the importance of safeguarding suitable sites for road/rail transfer points, without which rail freight volumes cannot be achieved to enable more sustainable freight distribution. Sites with good rail and road connections therefore need to be safeguarded as they are limited.
  5. We agree that there is significant potential for the North West to increase its market share of logistics sites.  Manchester and the North as a whole has lower land and labour costs than the Midlands and the SE. Manchester’s proximity to ports is also key.TfGM needs to work with TfN to deliver several Strategic Rail Freight terminals in the North and add around 2 million square metres of distribution centre capacity on multimodal sites which could create 25,000 to 38,000 new jobs in the logistics sector by 2030s.
  6. This strategy needs to be aligned on a regional and national basis. Therefore, it is crucial that this Freight Strategy is integrated with the TfN intermodal freight strategy, into which we have contributed. Freight on Rail ran a rail freight workshop jointly with Darren Kirkman of TfN to which all the key relevant transport planning officers across the region were invited. The aspirations of the TfGM freight strategy are dependent on infrastructure upgrades across the Northern Region and north/south routes. So we urge TfGM to work with TfN to press for infrastructure upgrades to the strategic rail freight network.
  7. Especially because rail is well placed to offer long distance trunk haul consumer (container) services into consolidation/rail freight terminals with freight traffic then transferred to low emissions vehicles for the final mile.
  8. Page 7 The strategy does not take a very optimistic view of the existing and potential opportunities for rail freight which, given the need to reduce road congestion and pollution, could and should play a larger role.
  9. Port Salford will enable considerably more freight traffic to be carried by rail so it is important that the increase in rail freight services is fully supported by TfGM. 
  10. We agree that NW is becoming more attractive for warehousing distribution parks, p10.
    Rail freight terminals of differing sizes have significant regeneration benefits and green credentials.The point about SRFIs is that because of economies of scale, these sites allow rail to compete with road in the very competitive consumer market by providing warehousing and other ancillary costs as well as reducing the transhipment costs.
  11. See economic benefits of SRFIs section 15
  12. The SRFI at Daventry removes 23 million HGV road miles a year
    Therefore it is important that as many of these terminals are rail connected or at least capable of being rail connected. As well as terminals for consumer products, more aggregates terminals are needed so that rail freight should be used to bring in construction materials for the building boom in GM.
  13. P10 Our commodity types
    There is no mention of rail freight and its suitability for consumer traffic, domestic and industrial waste removal and construction traffic.
  14. Employment and GVA
    Economic Value of SRFIs
    SRFIs typically generate 6000 jobs per SRFI and 4000-6000 indirect jobs and contribute £10m in business rates per annum to local authority. These are good quality jobs with a mix of 35% admin, 50% skilled/semi-skilled and 15% managerial/technical with an average salary of £28,000 compared to the national average of £20,000.
  15. P12Road safety and HGVs
    Transferring more freight to rail would significantly reduce road collisions. DfT research acknowledges that because of their size and weight, when they are involved in accidents the level of injury tends to be higher.

    In 2013, HGVs were six times more likely than cars to be involved in fatal collisions on minor roads, in 2012 it was five times.Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT

    London Safety Statistics from TfL are relevant to the GM debate
    Lorries are disproportionately involved in fatal collisions with pedestrians and cyclists.  Lorries only make up around 5% of London traffic in miles driven

    Between 2010 and 2014, lorries were almost 10 times more likely to be involved in a fatal collision than cars;
    Seven of the nine cyclist fatalities in London in 2015 have involved lorries; in 2011 12 of the 16 cyclist fatalities involved HGVs
    79 per cent of fatal collisions with cyclists in the past three years have involved lorries designed to be driven off-road. 
  16. Lack of compliance with road regulations puts other road users at extra risk
    UK HGVs had a 61% overloading rate in road side checks in 2011, 60% in 2012, 59% in 2013 and 2014.
    UK HGVs roadside prohibition rates due to mechanical errors have increased from 28% in 2011, 30% in 2012, 31% in both 2013 and 2014. 

    HGV efficiency which is related to safety given the added risk of each HGV to other vulnerable road users.
    The number of HGVs completely empty has consistently remained at around 29%.
    In 2011 it was 30.2%, in 2012 - 28.5%, in 2013 - 28.6% and in 2014 - 28.8%. Source FTA Logistics Report 2016
    Nationally large goods vehicles over 3.5 tonnes are involved in approximately 15% of cyclist and 10% of pedestrian fatalities. However it should be added to the statistic that HGVs only make up around 5% of miles driven. 
  17. The dangers of 7ft longer semi trailers, currently in a DfT ten year trial.
    TfGM should take steps to ensure the 7ft longer trucks, currently being trialled by the DfT, only use local authority safe urban roads because these vehicles are not suitable for many standard manoeuvres on  urban roads.
    The 7ft longer HGVs, currently being trialled by DfT which it admits have bigger tail swings and blind spot, should only be allowed on local authority designated safe routes. The Chair and Vice Chair of the Assembly Transport Committee Caroline Pidgeon and Val Shawcross recognized these dangers when we met them in March 2015 which resulted in the Deputy Mayor writing to the Secretary of State for Transport to highlight these vehicles as a problem.  The response received from the Secretary of State was factually incorrect as he stated that these 7ft longer HGVs could match the turning performance of existing standard articulated trucks, which is wrong. See Addendum on why SoS was wrongly informed.

    These longer HGVs are particularly dangerous for cyclists and pedestrians as the tail swing is double that of the standard 44 tonne artic. This attached graphic explains the problem of the even bigger trucks; currently there is no mechanism to stop them using unsuitable roads in the capital. In urban environments where standard left or right hand turns are made, the out-swing of the rear of the trailer will up from 1.7m (5.5ft)on the standard 13.6 metre trailer  to 3.3m (10.8ft) on the LST under normal road conditions and this will occur in the driver’s increased blind spot. Many urban 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.
  18. P13 air quality
    Given that Manchester is exceeding NOx limits it is imperative that NOx and particulate emissions are reduced as soon as possible.- GM road transport contributes 75% of Nox and 81% of particulates. Levels of NOX in GM city region are more than double the EU limit of 32 ugm3
    Putting rail at the heart of freight policy can help reduce air pollution as rail freight produces almost 90% less PM10 emissions than road freight and up to fifteen times less NOX emissions 1
    CO2 emissions- GM road transport contributes 32% of CO2 emissions.Rail freight produces 76% less CO2 emissions per tonne than HGVs for the equivalent journey. HGVs account for 17% of CO2 emissions nationally even though they only account for around 4% to 5% of vehicle miles driven.
    Therefore, as previously stated, TfGM should make its policy recommendations to increase rail freight a priority.
  19. Consolidation/terminals should be rail connected.  
    Terminals and consolidation centres typically on the edge of the conurbation for consumer products. Rail connected terminals of all sizes are needed.Consolidation centres allows rail to compete as both modes have the transhipment costs.

    Use rail for long distance consumer traffic and low emissions vehicles for final mile. Bring construction materials into Manchester by rail. London receives 40% of its aggregates by rail currently.

    Therefore it is important that as many of these terminals are rail connected or at least capable of being rail connected. As well as terminals for consumer products, more aggregates terminals are needed to bring in construction materials for the building boom in GM.
  20. More freight capacity needed as identified and defined in the strategy. For example Trans-Pennine corridor for consumer and bulk traffic needs capacity and gauge enhancements.
    The North Transpennine upgrade is a current priority, as the existing remit does not permit for freight growth, and Network Rail and DfT are presently considering how this might be addressed.  Other constraints include the South Transpennine route which is critical for construction materials by rail.
  21. As you highlight in your strategy freight distribution is changing. TfGM should look at bringing train loads of freight into passenger terminals the heart of Manchester at night for onward transportation in low emissions vehicles. Two trials into Euston have been carried out by Colas Rail. One with Stobart Rail and the second with TNT. Both trails, which each removed around 30 HGVs were successful and demonstrated the potential for large quantities of freight to be delivered in this way. The plans have stalled because of the uncertainty about the use of some of the Euston rail lands for HS2.  But similar proposals could be applicable in GM.
  22. Ultra Low Emission zone limiting freight vehicles to Euro VIneeded as air quality issues have to be addressed by 2020.
  23. Embracing opportunities and rising to the challenges P16
    Rail freight can help create more green jobs in GM if rail connected terminals are built and thereby help reduce congestion, CO2 and air pollution emissions as well as improving road safety. Therefore, pursuing the right policies to expand rail freight must be a priority. With the right policies and support from all levels of Government rail freight can and should play an expanding role, especially given that road congestion road collisions and pollution are key problems in GM.
    As mentioned before, more rail connected terminals of differing sizes are needed
    Bring in trainloads to heart of city to combat congestion and pollution as seen in Colas Rail trials
  24. Surely there are more rail linked suitable sites which may serve Manchester but be outside its strict boundaries?
  25. P17 As the study states road freight is highly competitive however, the study does not highlight the important point that HGVs are not very efficient which mean that society is being exposed to extra dangers, pollution and congestion when almost a third of trucks are driving around completely empty.

    The number of HGVs completely empty has consistently remained at around 29%.In 2011 it was 30.2%, in 2012 - 28.5%, in 2013 - 28.6% and in 2014 - 28.8% -Source FTA Logistics Report 2016
  26. External costs of HGVs need to be taken into account
    As the Government acknowledges, HGVs do not pay for many of the costs they impose on the economy and society which make it difficult for the sustainable modes to compete on price because of the lack of a level playing field. In fact, research carried out for the Campaign for Better Transport, using DfT criteria, found that HGVs pay less than a third of the costs associated with their activities, in terms of road congestion, road collisions, road damage and pollution which equates to an annual subsidy of around £6.5 billion.
    These conclusions are in line with a MDS Transmodal study in 2007 which found a very similar amount of underpayment: £6billion.
    Link to research on

    DfT criteria

    Latest DfT Mode Shift Benefit Values issued December 2014 were used. 
    Latest Transport & Environment research of April 2016  also shows that HGVs only pay around 30% of their external costs

  27. Distance based lorry road user charging can correct some of the market distortions.
    When the UK Government imposed a time based lorry charging system instead of a comprehensive distance based system in 2014, CBT said it was a missed opportunity to adopt a system which would encourage better efficiency in road haulage and thus reduce road congestion and pollution as well as addressing the inequalities between UK and non-UK hauliers. A distance based system could lead to better internalisation of HGV external costs and thus address distortions in the freight market; HGVs currently receive a £6.5 billion subsidy each year in the UK.  

    A distance based lorry charging system where HGVs are incentivised to increase loading and reduce empty running would benefit hauliers and the economy as a whole by reducing road congestion, road damage, collisions and pollution. Furthermore, it would allow rail and water to compete with HGVs on a level playing field.
    The evidence from the schemes operated in Germany and Switzerland demonstrates that efficiency of the HGV sector has improved with less empty running and better load utilisation. Additionally, rail freight volumes have increased which in turn reduces road congestion as well as greenhouse gas and NOX emissions per tonne of freight carried.
    We believe that any new legislation should include have differentiated values for CO2, have values for accidents, track costs as well as congestion, air pollution and infrastructure costs. 
  28. P18 details on rail freight constraints
    barriers to growth in the North
    No daytime capacity on Diggle route for loaded trains over700 tonnes
    No W10/W12 trans-Pennine route
    Incomplete W10/12 gauge clearance on ECML- North
    Lack of capacity on the Felixstowe to the North corridor
    Waiting delivery to enable longer trains from Southampton to the North.

    What is needed to continue improving efficiency
    Capability to haul intermodal trains at 775m/1800tonnes;north-South or East-West
    Capability to haul bulk trains at up to 2400tonnes
    A W10/W12 gauge cleared route TP, preferably the Diggle route
    Capacity on TP routes to meet the desired capacity
    A 24/7 railway that matches the M62
    Improved journey times for our services – freight is time critical
    Capacity and capability to support any new terminal development
    Additional north-south rail freight capacity on both WCML and ECML to support routes to the North from and to the ports.
    Additional capacity needed to support Strategic Rail Freight Interchanges across the country as well as in the north as they are need to be linked with good rail freight capacity which is needed in the short to medium term in N|R control periods 6 and 7.

    TfGM must jointly press with TfN  for upgraded rail freight strategic routes in the region as there is significant suppressed demand for rail freight services, both intermodal, bulk including biomass and construction materials.Given the socio-economic benefits of rail freight, a step chance in capacity in the region is needed. Precise specifications need to be agreed with the rail freight industry.
  29. GM generates and attracts between eight and 10 intermodal train journeys on an average weekday from the key Trafford Park terminal, linking Manchester to London Gateway, Southampton and Felixstowe. A very limited number of trains run cross-Pennine, these carrying either domestic waste or aggregates/cement,routed via the Calder Valley line. Finally, considerable quantities of aggregates are generated from the PeakDistrict, with much of these heading south to the London area and not entering GM 
  30. Rail network constraints pose problems for future freight growth. The access route to the Trafford Park terminal is along the already highly congested Castlefield corridor. Deansgate to Oxford Road Picadilly and further franchise committed services will exacerbate this issue. Logistics companies often require railservices to meet key time windows for delivery and collection, timed relative to major port arrivals/departuresand as such the solution of pushing intermodal services to run either early or late in the day at Trafford Parkis not always possible, with the requirement for a regular interval freight train “path” throughout the day.

    In answer to this paragraph in the strategy a degree of expansion in capacity is needed as soon as possible to provide private sector with confidence to invest in additional facilities, especially in the case of the Trans Pennine route.
  31. A second significant constraint is that of the cross pennine links with the South TP route via Edale effectively full, the North TP route via Huddersfield also full and likely to get worse with planned extra passenger services and the Calder Valley route via Rochdale the best suited but also expected to see passenger services increased. When combined with gradient restrictions and the inability to accommodate deep sea containers of 9ft 6 in height rail currently has little scope to compete against the M62 T-P route. The electrification of key TP routes could improve this position.

    In answer to the above paragraph, the North Transpennine upgrade is a current priority, as the existing remit does not permit for freight growth, and Network Rail and DfT are presently considering how this might be addressed.  Other constraints include the South Transpennine route which is critical for construction materials by rail. Train lengthening work at Buxton which is part of the CP5 Network Rail funded upgrades will lead to more efficient aggregates trains on this route. The ability to use 750 metre intermodal trains will make the T-P routes more financially viable.

    The electrification and route enhancements are a significant opportunity to ensure the right T-P capability and capacity upgrades are carried out for both freight and passenger services. The DfT/HA Route Studies in 2014 stated that rail was the best mode to use on the T-P for socio-economic reasons. The rail freight industry needs 3 freight paths per hour in each direction crossing the Pennines.
  32. HS2 has the potential to deliver additional rail capacity for freight, but presently there is no comfort on how this will be achieved in practice.  We are concerned that on key sections of the existing network, freight capacity will be less than today once HS2 trains are in operation. This is particularly true on the West Coast north of Birmingham, and, once HS2 is open to Crewe, beyond Crewe to Scotland.  There is also no guidance on how and whether released capacity will be allocated to freight.  TfGM may wish to consider how it can support freight benefits from HS2 as part of its wider strategy.
  33. While there are constraints to growth on the rail network, there are huge economic, social and environmental benefits of solving these problems. The strategy emphasises the problems created by HGVs but does not highlight also the huge external costs imposed on the economy and society by this sector which are paid by the taxpayer. Were rail freight to expand, freight’s external costs could be significantly reduced and thereby the costs to the economy and society.
    When evaluation whether to upgrade the rail or road network, it is crucial that extent of the subsidy to HGVs is taken into account. The Government and devolved authorities can compensate rail freight for the market distortion by taking these disparities into account in the forthcoming freight access charges review and by upgrading the rail freight network.
    There is suppressed demand for container rail freight services out of both Southampton and Felixstowe. Every additional path that becomes available is immediately used.
  34. Rail freight is well placed to run long distance consumer services from ports to conurbations for city links. However, the strategy makes no mention of rail freight suiting this traffic. Nor how rail freight can offer long distance traffic for transhipment into low emissions vehicles for last mile deliveries.  
  35. City to City links
    The situation on availability of SRFIs is changing, with more sites likely to come on stream shortly and thus enabling a network of SRFIs. There is a SRFI near Doncaster already approved and another one in the East Midlands. Other existing SRIFs are DIRFT, Grangemouth, Mossend and London Gateway For example,  there will hopefully be an SRFI in the West Midlands called Four Ashes which is situated on junction 12 of the M6 near Cannock and near the WCML. The proposals for Parkside Terminal in the NW have re-started again.
  36. P18/9 Getting into and around the regional centre
    Last mile is the most inefficient part of goods movements predominantly relation to congestion and low reliability of the highway network. Construction traffic for the ongoing re-generation of GM is an additional problem. Each aggregates train can remove up to 136 HGVs from our roads. Therefore use rail freight where possible as part of supply chain.
    In GM the biggest problem is NOx- Levels of NOX in city region are more than double the EU limit of 32 ugm3. Therefore rail could be part of a solution using low emissions vehicles for the final mile and rail freight for the trunk haul from the ports and between cities.

    P20 With regard to the access problems for HGVs to Trafford Park, the wider overall benefits of removing HGVs needs to be considered as well as the local disbenefits. Could better road junctions and layout improve this situation as well as designated HGV routes and restrictions in the immediate vicinity of Trafford Park. For example, the SRFI at Dirft removes 23 million lorry miles a year off key strategic corridors.
  37. P19. Why have LDFs only identified one future freight facility which is rail connected?
  38. We agree with the vision for freight and logistics on P21 and highlight that rail freight can help meet the vision if as stated action is taken now to plan the necessary rail infrastructure, provide the right pricing environment which reduces the market distortion between HGVs and sustainable freight. The reason why HGVs are cheaper than rail and water is because 70% of their costs are paid by society not the industry which makes it very difficult for rail to compete on price. 
  39. We agree with objectives on P22 but the strategy needs to clarify for whom it recommends keeping freight costs low (reference point 2)? As there is a potential conflict here because HGVs only pay 30% of their external costs therefore so-called cheap freight is not cheap for public who pick up the bill in terms of congestion, pollution, collisions and road damage but is cheap for haulage operators.  GM should therefore have a policy of making the different freight modes internalise their costs. This would enable the sustainable modes to compete more fairly with road and air freight. 
  40. P22 All these aims show how increasing rail freight is important.

    HGVs do not pay external costs. See section 26
  41. Conflict on 2, keeping total cost of freight and logistics as low as possible for operators and society.Road freight is competitive but not efficient.
  42. Distance based Lorry road user charging could change this.
    P23 In proposals and interventions, reducing externalities is mentioned. Government, whether national, devolved or local, needs to take action to charge HGVs for the costs they impose. Introducing a distance based lorry road charging system which charges HGVs for congestion, CO2, air pollution, collision, road infrastructure damage impacts would lead to more efficiency in road haulage, in terms of load utilisation and empty running. Furthermore, it would enable rail and water freight to compete more fairly. 
  43. Colas nighttrials of freight trains into Euston show the potential to use rail freight in this way. Trainloads of freight were transported into Euston in two separate trials with Stobart Rail for Sainsburys and TNT and then transhipped into low emissions vehicles for the final delivery.
  44. Dangers of 7ft longer HGVs under safety and regulationSee section 17 and addendum 
  45. Need a more bold vision to improve city centres in environmental safety and congestion terms
  46. Remove HGVs from centres, transfer to low emissions vehicles as the right sized, low emissions vehicles should be doing deliveries in the centre, given all the external costs which are passed onto society.And plan to set up a clean air zone.
  47. P25 section 11 Rail connected terminals should be supported for construction materials.
    Support consolidation centres but should try to get rail connected ones to solve the key urban problems p26/27
  48. There is a need for a bolder visionfor rail freight given all theuse rail into city centres like the Colas Rail trials.
  49. P28 the planning and vision for rail and water – this is good but needs to be high priority
  50. Planning and research
    Councils need to safeguard suitable sites. Need integrated approach
  51. Rail freight can help GM meet all its objectives, safety emissions congestion so all the items in 23-26 on P28 are crucial to help GM meet its objectives.
  52. P29 Potential conflict in keeping freight costs as low as possible for operators and public. As it is cheaper for operators to use the biggest lorries which cause more congestion, more road damage, more collisions and more pollution than transhipping into smaller low emissions vehicles, as their external costs  are imposed costs on society. So these factors need to be differentiated. 
  53. Addendum - why the Secretary of State for Transport’s reply to the Deputy Mayor was incorrect 
    The reply from the Secretary of State for Transport to Isabel Dedring’s letter on 7ft longer HGVs was factually incorrect and underplayed the significant threat to cyclists, pedestrians and other motorists from these 7ft longer lorries when negotiating left and right hand turns on urban roads.
    Therefore, Campaign for Better Transport (CBT) and  the Technical Advisors Group (TAG) , supported by British Cycling, Cycling UK, Living Streets and RoadPeace, believe that TfL should take action now to restrict these trucks to suitable roads before there are collisions.
    CBT and TAG saw again in our second demonstration on 14th April 2016 that the rear tail swing from the LST when turning corners was significantly greater than normal HGVs, up from 1.7m (5.5ft) to 3.3m (10.8ft) under normal road conditions.   Our graphic explains the problem. Many urban roads are not able to accommodate such large vehicles, forcing them to perform movements that put other, more vulnerable road users at risk such as:

    Mounting kerbs or traffic islands
    Swinging over kerbs, traffic islands or adjacent lanes
    Entering adjacent lanes, parking bays or footways 

    The Secretary of State said in his letter to the Deputy Mayor that the vehicle used in the demo we had in July 2013 was not representative. The second DfT demonstration of the 7ft longer trucks on 14th April 2016 proved that the claim that the truck in the first DfT demonstration was not representative, was wrong as the rear outswing from the truck in the second demo is even greater than at the first demo.

    We would like to highlight the fact that the Secretary of State for Transport’s reply of 24th June 2015 to Isabel Dedring’s letter on the safety implications of LSTs was factually incorrect on the crucial safety point of the tail swing of the longer semi-trailer compared to the existing standard 44 tonne 13.6 metre trailer. As you are aware, there is a significant difference between meeting existing standards and performance.

    It is wrong for the SoS to say that these 7ft longer trucks match the actual performance of the standard 16.5 metre truck. In its own DfT research its consultants confirmed that the 7ft longer semi trailer LST does not have the performance of the existing standard truck.   DfT consultation Page 7 para 23/24  Called Consultation on the possibility of allowing an increase in length of articulated lorries-  main document.

    a. Same document mentions option 7 using new generation active technology not yet in production which DfT claims would be able to meet performance of standard truck. Both our vehicle tracking experts say they believe it would be impossible for the 7ft longer ones to meet performance of standard ones with any steering technology as the geometry would not work.
    As you are aware, there is a significant difference between meeting existing standards and performance. The DfT research states that the 2.05 metre trailers could meet existing turning standards ie regulations set out in the national Construction and Use legislation as stated by SoS. The fact that the longer HGV complies with the regulations is not the point, it does not meet the performance of the standard truck and that is why it has problems manoeuvring standard right hand or left hand junctions on urban streets.
    Both our demonstrations in July 2013 and April 14th 2016 show that these 7ft longer trailers do not have the same manoeuvrability performance as the standard full length articulated lorry and that the rear outswing of the 7ft longer one is almost double that of the standard one.  

1. DfT Logistics Perspective Dec 2008 P8 paragraph 10

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