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Regulations for longer semi-trailers (LSTs) call for information.

2 September 2019

Freight on Rail thanks the Department for Transport (DfT) for the call for information, set out in the Minister’s letter, dated 23rd July, regarding the longer semi-trailer (LST) trial. 

Definition of Freight on Rail

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.

Summary

As we have stated since the inception of LSTs in 2011, local authorities and their representative bodies,should have been treated as partners, not merely stakeholders. This should have happened during the initial consultation and throughout the trial because of the impact LSTs have on the local road network, for which local authorities are responsible.

We continue to oppose the wider role out of LSTs on the following grounds:

  1. Undermining of rail freight, the low carbon safe alternative to HGVs and LSTs,  which also reduces road congestion.
  2. Increased exposure to road collisions and infrastructure damage on minor roads.  

However, before the DfT decides to go ahead with any changes to the current trial the following must be taken into account:

  1. Proposals for change would need to be assessed by all levels of Government before any decisions are made to change from the existing LST trial parameters.
  2. Significant control measures are essential because any new regulatory system for a new vehicle category would have huge impacts and costs.
  3. Before any changes are made to the current arrangements for LSTs, the DfT needs to solve the problems of existing HGVs using unsuitable minor roads and give local authorities more powers, including issuing fines to lorry drivers who ignore road restrictions. 
  4. The DfT needs to provide funding for local authorities to make sure any new regulatory framework is properly implemented otherwise there are likely to be severe safety and infrastructure damage implications on the local road network.

Need a regime of permitted routes for LSTs on safety grounds

DfT cannot allow unfettered access for LSTs because of their manoeuvrability issues off the Strategic Road Network (SRN). LSTs need to be restricted to designated authorised local authority controlled roads to reduce the risks to other road users, especially cyclists and pedestrians. This is because of the extended rear tail swing when standard left-hand and right-hand turns are performed on minor roads.
Detailed response

  1. Wider circulation of LSTs would undermine domestic intermodal rail freight

    The fact that wider circulation of LSTs would undermine domestic intermodal rail freight must be taken into account given that Government policy recognizes the socio-economic benefits of expanding rail freight as part of its freight solution. The Government’s Freight Carbon Review, issued in February 2017, states shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits 1.

    A further increase in LSTs is likely to undermine domestic intermodal rail, which is the sector expected to grow the most over the next twenty years, with forecasted growth of almost two and a half times between 2016/7 and 2033/34 as shown in the following MDS Transmodal forecasts, prepared for Network Rail in 2018.
     
    Table 1:  National rail freight TONNES by sector (thousand tonnes per year). Central forecast neither favours nor disfavours rail relative to road with central market growth.
     
  2. Sector

    Actual 2016/17

    2033/34 E (central)

    Domestic Intermodal

    2,481

    6,046

    Figures on HGV involvement rates in critical incidents on the Strategic Road Network (SRN) make the economic and safety case for rail freight

    The average monthly figures for HGV involvement in critical incidents on the Strategic Road Network (SRN) from January to-November 2018 show the following: for incidents of more than five hours, the HGV involvement rate is 42.8 per cent of incidents and for incidents of more than ten hours the HGV involvement rate is 55.72 per cent; even though HGVs make up just under 12 per cent of motorway traffic miles in 2017 2. Undermining domestic intermodal rail freight by expanding the use of LSTs will only exacerbate these problems on the road network.

  3. Road Safety

    While in principle, these longer semi-trailers might be able to operate safely on motorways and dual carriageways, longer semi-trailers are particularly unsuitable for many urban, town centre, local and rural roads. This is because of the extended rear tail swing when they perform standard left-hand and right-hand turns. Inevitably these longer semi-trailers will make use of local roads to access depots. These local roads are operated by local authorities, and they make up 97% of the length of all roads. Many urban and local roads in the UK are not able to accommodate such large vehicles, resulting in the vehicle drivers performing movements that put other, more vulnerable, road users at risk. These manoeuvres include the following:

    • Mounting kerbs or traffic islands;
    • Swinging over kerbs, traffic islands or adjacent lanes; and
    • Entering adjacent lanes, parking bays or footways.

    These encroachments will occur because the longer semi-trailer has an extended tail swing and blind spot - which is almost double the length of that of standard HGVs when making standard right and left turns. These encroachments make these vehicles especially dangerous for cyclists and pedestrians. 

    The original DfT impact analysis in 2011 acknowledged that the longer semi-trailer, while meeting the existing turning regulations, did not have the same manoeuvrability performance as existing 44 tonne 16.5 metre trucks. The DfT claimed that active steer axles, which were claimed to allow longer semi-trailers to match existing HGVs’ turning performance, were being proto-typed. However eight years later, active steer axles are still not available and many traffic engineers do not consider that, given the length of the longer semi-trailers, that basic geometric rules mean that LSTs could not meet the performance of existing 16.5 metre trailers, irrespective of axle technology. The Technical Advisers Group (TAG) and CfBT had two separate LST demonstrations in 2013 and 2016, organised by the DfT, which confirmed our data. Furthermore, the swept paths of rear axle technology has not changed since then.

    Safety record of existing HGVs needs to be taken into account
     
    The DfT needs to take into account the safety record of existing 16.5 metre trucks in its safety evaluation on the future of LSTs because there is a danger that LSTs could become the default HGV over time as current industry practice is to buy the largest lorry available to use for all loads large or small. See section 3.(c) for statistics. 

    • The safety records of HGV involvement rates of traditional HGVs has not significantly changed in the past eleven years.
    • A trial cannot replicate real live conditions and is therefore not a substitute for actual  DfT statistics on HGV road collisions. 

    Campaign for Better Transport has compiled figures for the last eleven years which show that overall road fatalities have reduced on UK roads; however the ratio of fatal road accidents involving HGVs compared with those involving cars has been climbing year on year 3.
    The figures depicted in the graph show the involvement of HGVs in fatal crashes compared to cars on motorways, A roads and minor roads for the last eleven years. They reveal little or no improvement in the rates of fatal collisions involving HGVs on motorways and A roads, and an increase in the case of minor roads.  There are many large, heavy lorries on roads which are often totally unsuitable for them, as the high rate of crashes on minor roads shows.
    The latest safety figures (2017) show the following:-

    • HGVs were nearly five times (455 per cent) more likely than cars to be involved in fatal crashes on minor roads
    • On average across all road types HGVs are almost three times more likely than cars. HGVs are 332 per cent more likely than cars on A roads
    • On motorways HGVs are almost four times more likely to be involved in fatal crashes than cars. 

    While actual figures vary from year to year the overall figures are consistent over the past 11 year which the following graph shows.


    Graph showing the involvement in fatalities with HGVs over 3.5 tonnes compared to all traffic

    (Source:Traffic Statistics table TRA0104, Accident statistics table RAS 30017 both DfT)

    It should also be noted that the latest DfT valuation of the benefits of prevention of road accidents puts the costs per fatality at over £1million 4.

  4. The trial is not representative of real life

    We believe that the trial conditions are not representative of real live conditions as participants are self-selecting using experienced drivers with better load utilisation than in normal operations. So even though, the DfT trial safety data looks good, we believe that  LSTs needs to be restricted to designated defined local authority authorised routes because if LSTs were allowed in general circulation the following could happen:
     
    1. LSTs could replace the existing 16.5 metre trucks as the industry workhorse.
      Numbers of LSTs would therefore rise and they would have serious manoeuvrability problems off the Strategic Road Network.LSTs  are unlikely to get the same levels of efficiency as current trial LSTs once LSTs allowed in general circulation. This factor needs to be assessed as the current DfT case for LSTs is based on calculations that
    2. LSTs reduce lorry miles and therefore reduce congestion, pollution and exposure to collisions which are based on higher utilisation levels of the trial than commonly found in 16.5 metre HGVs.
    3. Even Risk Solutions says figures cannot be directly applied to any national roll out of LSTs (Annual report for 2017 P76 paragraph 7.53) Therefore using an assumption that increasing lorry sizes will result in fewer, better loaded trucks on the roads cannot be applied if LSTs were allowed in general circulation, when there is simply no evidence to show this is achievable once LSTs are operating in general circulation. Currently only 32 per cent of HGVs on the roads are fully loaded in terms of by volume and 29 per cent are travelling around completely empty. Current industry practice is to buy the biggest lorry available and use for all jobs, big or small. The over 33 tonnes category increased by five 5 per cent and all artics by four per cent between 2017 and 2018 (DfT RFSO109 Goods listed by type and weight of vehicle 2018) and statement from haulier - One operator said that the extra capacity gave the operational flexibility of having extra capacity available when required P36 5.29 Annual Risk Solutions report for DfT on LSTs 2017.

  5. Need to work with local authorities as partners not merely stakeholders

    The DfT needs to work with local authorities as partners to study the impacts of longer lorries on all minor roads including urban, town centre, rural roads. Because these are the roads where LSTs are likely to incur problems, due to their extended tail swing and blind spot - which is almost double that of standard lorries when making right and left turns - putting other, more vulnerable, road users at risk.

    Were the Government to consider allowing LSTs to operate outside the current trial parameters:
     
    1. It must solve the serious problems with existing HGV drivers who ignore road restrictions by giving local authorities powers to issue offending lorry drivers with fines – see section 7 enforcement of regulations.
    2. It must work with local authorities before any statutory consultation about any proposed changes to regulations, is considered.

    We believe that LSTs should only be allowed within a strict regime with specific regulatory controls. A proper impact assessment is needed on the impacts of longer semi-trailers on all minor roads including urban, town centre, rural  roads, which make up 97% of roads and are managed by local authorities.
     
    Moreover, local authorities do not have the funding to support the introduction of a new and separate category of vehicle for the LST in its regulatory system. There are huge potential knock-on impacts of introducing a new vehicle category with huge resource commitments. So the financial impacts of any new regulatory system need to be fully assessed before any decisions are made to change from the existing LST trial parameters.
     
    Issues include:

    1. Changes to design of road junctions
    2. LSTs may get stuck more frequently than standard 16.5 metre trucks
    3. Tail swing (kick out) of LST rears would have safety, damage to street furniture, buildings and planning implications
    4. Existing loading bays would not be long enough
    5. Depots entrances may need to be adapted

    A considerable number of existing major depots are very tight for the existing 16.5 metre trucks. Local authorities cannot assess the engineering requirements of LSTs when they have not been issued with the necessary parameters for swept path analysis. At present, different LSTs have different turning characteristics, these should be standardised by the DfT and published so that engineers can design the road junctions accordingly and the manufacturers produce LSTs that conform to set standards. Then the use of swept path analysis software would enable the engineers to determine minimum requirements for LSTs where needed to avoid off-tracking as is normally done for any major change at a junction.

    We understand that the DfT wrote to local authorities asking for a list of roads suitable for bigger and longer vehicles as part of the process of updating the National Street Gazetteer. However, the DfT must be aware that most local authorities do not have the funding resources to provide these engineering specifications for their local road network to validate whether LSTs should be permitted access on identified roads. It is essential that the engineering of each road is suitable for LSTs and that the safety of pedestrians and cyclists is protected. The administration and enforcement costs of this exercise should be borne by the haulage industry, the beneficiaries of LSTs.

  6. LSTs should only be allowed to use local authority designated routes on local authority controlled roads

    All such roads and junctions need to be checked with Auto-TRACK or similar software so that the SRN, MRN and local roads are capable of handling LSTs without danger, as spelt out by RIDDOR. Councilshae the power to ban HGVs from certain routes through the use of traffic regulations orders but they do not have the ability to enforce them.
     
    Road classifications

     
    The DfT needs to issue a definition of what class A type roads are within MRN, as local authorities are responsible for class A type roads. We understand that there is a map but do not know whether it has been published publically yet.
    While DfT states that 90% of journeys should be on MRN, 10% of journeys most commonly at their start and finish, will be off the MRN on ordinary local authority roads, some of which will have engineering issues with LSTs.
     
    A regime of permitted routes is needed for non SRN roads.

     
    Any regulation should state that LSTs must be permitted on a designated route by the local authority concerned, as opposed to saying LSTs are prohibited from using certain local authority roads. When asked by the Freight Transport Association at the launch of the 2017 annual LST report, whether it would start a programme of modification of junctions to cater for LSTs, the DfT stated that junctions will not be adapted for LSTs. We fully support this approach as adaptation would be highly likely to make them more dangerous for cyclists and pedestrians and the solution is for LSTs not to use unsuitable roads and junctions.
     
  7. Use of LST specific Sat-Nav

    For the past five years, we have been calling for the trial participants to be required to use GPS so that the trial can be properly monitored to establish what road types are being used and for how long. So we welcome the fact that the DfT is now prepared to consider a comprehensive technology approach to stipulate and enforce where LSTs go.
     
    The DfT and the industry should fund a specific satnav system for HGVs and a subset system for LSTs to state which roads are suitable for standard HGVs and LSTs respectively. If the DfT is proposing supporting an HGV based Sat-Nav, with a restricted set of roads it should be straight forward to produce a reduced set of roads for LSTs (SRN and MRN) with the addition, where requested, of a limited set of additional local authority roads. For any satnav system to be suitable it must be national and compulsory and funded by the DfT, otherwise it will not be complete.
     
  8. Enforcement of regulations

    As previously stated, although councils have the power to ban HGVs from certain routes through the use of traffic regulation orders they have no ability to enforce them. However, existing HGV restrictions are not widely enforced by the police so it is unlikely that new restrictions for LSTs would be enforced either.

    Local authorities need powers to stop existing HGVs using unsuitable roads


    Before any changes are made to the current arrangements for LSTs operating on minor roads, the DfT needs to solve the problems of existing HGVs using unsuitable roads which are causing huge problems, as highlighted on 31st August 2019 by the Local Government Association (LGA). The LGA is stating that councils must be given the power to enforce moving traffic offences - including heavy goods vehicles using rural roads not designed to take their weight, vehicles driving the wrong way down a one-way street or making a banned turn. This would help them act on community concerns and improve road safety, tackle congestion and reduce pollution. Furthermore the LGA said lorry drivers should also be required to use dedicated HGV sat navs. These are like normal car sat navs, but they include bridge heights, narrow roads, and roads unsuitable for trucks. They also allow the driver to input the lorry's dimensions - height, width, weight and load – so they are only guided along suitable roads.

    The LGA wants all local authorities to be able to issue fines to lorry drivers who ignore road restrictions. In England, these powers are currently only available to councils in London. The LGA states that there have been a spade of collisions involving lorries blocking streets, damaging local areas and crashing into bridges on an all-too regular basis showing that action needs to be taken by Government in the upcoming spending round. With powers to enforce moving traffic violations also given to councils outside of London in England and in Wales, they could act to prevent disruptions by the minority of rogue lorry drivers that incorrectly use weight restricted roads through towns and villages and cause havoc on our local roads 5.

    A specific combined satnav and tracking system should be compiled to show local authorities any movements of LSTs off permitted routes. 

    It is already possible to introduce restrictions (TROs) based on length, hence if LSTs are easily distinguished by say rear plates, this could be done via camera, assuming it was a shot of the rear of the trailer. If Civil Enforcement were permitted, this could be achieved without the use of Police (use DVSA/VOSA, Traffic Officers or LA Civil Enforcement staff). Were there to be ‘permitted routes', signage could be minimal if a specific set of Sat-Nav links, which could so easily be kept updated, were used. Central Government funding must be made available for  local authorities to use TRACK  or  similar software products to check their local roads for LSTs. They could then assume all such roads are suitable for all HGVs.

    Therefore, LSTs need to be differentiated from other HGVs because they handle differently. Currently it is not easy for other road users to differentiate LSTs from existing standard 16.5 metre trucks. So distinct visual identification using plates stating extra length and different coloured trailer rears is needed, so that LSTs can be easily identified.

    Ubiquitous surveying of LSTs movements is needed. Standard traffic surveying techniques, such as automatic traffic counters (ATCs) that can differential LSTs using either the pattern of their axles or their chassis length to identify LSTs should be considered.
     
  9. Safety categorisation of whether an incident is LST related is worrying

    Even though it does not affect the total figures the categorisation of whether an incident is LST related is worrying,– (incidents where the fact that the trailer was an LST rather than a standard length was considered to be at least part of the cause).
    Of the 22 incidents 19 were considered not LST related.
    For example, even where:-
     
    1. A LST left the road and overturned injuring the driver it was deemed stress not work related (incident 7),
    2. A LST left motorway it was deemed driver fatigue not LST related (incident 9),
    3. The LST river hit cyclist form behind when moving from slip road to dual carriage way was not LST related (incident 12)
    4. Five people were injured it was deemed not LST related (incident 20).

    In 2017, 4 additional personal injury incidents involving LSTs resulted in 3 serious and 5 slight injuries, none of which were judged to be LST related.

    Where there was loss of control and snaking because of a sudden course correction at speed is worrying and is being further investigated by the DfT (incident 17) 6.

    (References are from the DfT Annual report for 2017, the latest full report currently issued)
     

  10. Changes to the LST quantity cap, currently 2,800

    Until LSTs are restricted to urban, rural and town centre roads, deemed suitable by the local authority concerned, with tested enforcement measures, we do not believe that the DfT should increase the number of LSTs allowed in the trial.
     
  11. Education programme on LSTs

    If the current trial arrangements are changed there will need to be an education programme for the traveling public, especially cyclists and pedestrians, who need to know that LSTs are going to have different manoeuvrability characteristics and in particular have a wider out-swing and blind spot. 
     
  12. Lack of independent verification of data submitted by trial participants

    All the so-called congestion, environmental and safety benefits are based on the figures submitted by the hauliers on the loads carried ie self-reporting (chapter 3). For example, it is the operator who determines whether the injury is recorded as slight or serious (7-3 P56). However there is no independent verification of the details submitted by the haulage operators to Risk Solutions who is working for the DfT.

 


1. DfT Freight Carbon Review February 2017. P43 Key messages

2. Source: Highways England HILO data 2018

3. https://bettertransport.org.uk/sites/default/files/research-files/HGV-fatal-collision-rates-2007-2017.pdf

4. DfT RAS6001

5. Local Government Association 31st August https://www.local.gov.uk/about/news/lga-all-councils-need-powers-tackle-lorry-mayhem-blighting-communities

6. Risk Solutions Annual Report for DfT 2017 Executive summary

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