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Proposals to support advanced driver assistance systems and automated vehicle technologies.

Freight on Rail would like to thank the DfT for the opportunity to comment on this consultation.

Freight on Rail, a partnership of the rail freight industry, the transport trade unions and Campaign for Better Transport, works to promote the economic, social and environmental benefits of rail freight to local, devolved and central Government.

We have limited our response to issues relating to HGV platooning

Enabling platooning in the UK

Question 3B: Do you agree with the proposition to allow platooning by relaxing Highway Code rule 126 (which recommends a 2 second gap between vehicles)? (Y/N) Why? (free text) 

Question 3C: What, if any, other restrictions should be considered regarding use of platooning technologies, and why? (free text) 

Questions 3B &3C

We do not believe that Highway Code rules should be relaxed to allow HGV platooning until more research and analysis is carried out to evaluate whether platooning is viable in the UK for the following reasons:-

Whilst the aim of platooning is to reduce adverse impacts of HGVs it will not fundamentally reduce these adverse impacts or improve the current lack of internalisation of HGVs charges. If freight costs are reduced for road haulage operators, there is a danger that the same freight will be transported further causing more adverse impacts to economy and society (rebound factor).

Whilst platooning could be viable in some other countries, there are serious obstacles to HGV platoons being practical in the UK. The UK’s road network is already very congested, with frequent motorway exits close together, and it is unclear how platoons will interact with other road users or how vehicles will overtake and enter and exit junctions safely. There are still so many technical questions unanswered, such as what would happen if a vehicle in the platoon breaks down, how to tackle the threat of cyber-crime or how these platoons will perform in bad weather. Where will HGVs formulate road trains and who pays for this? HGVs would need to be able to disengage in road side refuges. How does this fit with smart motorways? And how does a platoon overtake slow vehicles?

Furthermore, there are insurance issues to be resolved.

Therefore, HGV platooning should not be seen as a panacea for reducing freight congestion  and emissions or reducing road crashes. There is a compelling case for rail freight as part of an integrated multimodal solution as stated in DfT Rail Freight Strategy due to be released shortly, which highlights the role of rail freight in reducing freight’s overall emissions. Rail and road complement each other and rail is especially well placed to provide the long distance trunk haulage in a low carbon safer way than HGVs which reduces road congestion considerably. This is precisely the market platooning is designed for, which would undermine rail freight. Each consumer freight train can remove up to 70 HGVs. Source Network Rail Value of Freight 2012  

We believe that rather than aiming to reduce carbon dioxide emissions by 10 per cent through platooning, the Government could be cutting emissions by three quarters by switching more freight to rail. Source Rail freight produces 76 per cent less carbon dioxide emissions than normal HGVs. DfT Logistics Perspective December 2008 p10

We believe the best way for the Government to reduce the adverse impacts of freight transportation including congestion, collisions, pollution and road damage should be supporting and promoting rail freight and introducing a distance based lorry road charging scheme see section on distance based lorry road user charging. As well as reducing emissions platooning is being promoting as a way to reduce hauliers’ costs, but this fails to acknowledge the increased costs to society and the economy if more sustainable transport modes are undermined further. Reducing HGV costs is likely to lead to more lorry miles as freight is carried further. This has huge cost implications for the taxpayer as recent research both here and in Europe has shown that HGVs are only paying around 30% of their external costs including congestion, road damage, road crashes and pollution, due to various subsidies and tax breaks. This market distortion makes it difficult for rail to compete. If platooning reduces HGV costs further, it will make it even harder for rail freight to compete and could result in trainloads of freight going back onto the UK’s congested road network.

Platoons will not reduce road infrastructure damage
HGVs are up to 160,000 times more damaging to road surfaces than the average car. Source Road damage from HGVs is worked out using the Generalized Fourth Power Law- that damage caused by vehicles is 'related to the 4th power of their axle weight.

Cost of overloading to infrastructure, especially bridges and pavements
It is estimated that between 2.3 and 5.3% of maintenance costs are caused by overloaded HGVs  across EU, which amount to an estimated cost of 25 billion Euros. FTA published figures show that 61% of UK registered lorries, stopped in roadside checks were overloaded in 2014*
Source International Society on Weigh in Motion WP4 costbenefit analysis.pdf 

Safety costs of HGVs
Cost of Fatal crashes on motorways £2,203,179 and on all roads £2,066,732 

Source Table RAS60002

As DfT research states that because of their size and weight, when they are involved in accidents the level of injury tends to be higher. Statistics show that HGVs are six times more likely than cars to be involved in a fatal collision on minor roads. Source statistics table TR0104, Accident statistics table RAS 30017 September2014.

Research on external costs of HGVs which shows the lack of internalisation of its costs

The CBT research uses DfT Mode Shift Benefit Values February 2015
Latest DfT Mode Shift Benefit Values issued December 2014 were used. 

European research issues this April 2016

Platooning does not overcome the lack of efficiency in road transport
HGV efficiency which is related to safety given the added risk of each HGV mile driven 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

Distance based road charging would reduce the adverse impacts of HGVs
Distance based lorry road charging, which takes into account lorry track costs, CO2, air quality, congestion and collision costs would also make HGVs more efficient, should be recommended. There are concrete examples of how distance based systems in Germany and other Member States have resulted in better vehicle utilisation and internalisation of HGV costs.

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.

Lack of compliance with road regulations puts other road users at extra risk
Platooning will not overcome these added safety problems

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. 

Issues for platoon rear drivers – Will they be deemed to be driving and if so in a period of availability this could result in fatigue as it is not counted for WTD hours in the same way as driving.


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