Consultation outcome

48 tonne intermodal freight trial: consultation document

Updated 24 August 2021

This was published under the 2019 to 2022 Johnson Conservative government

Applies to England, Scotland and Wales

Executive summary

The standard maximum laden weight for 6-axle articulated lorries when used on public roads in Great Britain is 44 tonnes.

Some organisations have identified that allowing 6-axle articulated lorries to be operated at 48 tonnes during domestic intermodal journeys would improve efficiency and support rail freight.

This could be permitted for repetitive container loads that travel along a set route. Increasing the load capacity for each lorry involved could reduce the number of lorry movements to service each train, with the operations liable to happen frequently, feeding into scheduled trains operating on one or more days a week.

The Department for Transport (DfT) has made some technical assessments and this consultation is about the possibility of a limited trial for this type of operation.

The core of the proposal is for 6-axle articulated lorries run by specific operators to operate at 48 tonnes, while continuing to follow other existing rules, including maximum axle weights. These operations would:

• be restricted to specific routes
• likely be limited to a maximum journey length (proposed to be 50 miles)
• have to be part of domestic intermodal (road and rail) operation

Accommodating a trial within the existing load-bearing constraints of bridges and other infrastructure is not straightforward, and it may not be possible to include some otherwise useful routes. The design and state of the national stock of bridges and infrastructure rules out a wider consideration of allowing 48-tonne operation outside specified and authorised routes.

The DfT has conducted a preliminary technical assessment. This indicates:

• there might be significant public benefits if these operations help rail freight to a larger market share than would otherwise be the case
• that on routes where the road legs do not result in specific extra costs for relatively weak infrastructure, the quantified public benefits are likely to outweigh the costs and disadvantages

A real-world trial would provide a full and accurate picture of the costs and benefits of this proposal, along with highlighting other practical and commercial considerations. These results would allow a fully informed decision to be made around whether to roll the trial out further.

This consultation seeks views and evidence about whether in principle to have a trial, its likely effects and processes required to implement such a trial.

Commercial road transport operators interested in taking part in such a trial are invited to register their interest and provide information on some more detailed technical questions in the impact assessment.

Bridge owners are invited to consider implications on their infrastructure and operation.

Secondary legislation is likely to be needed to allow the trial to take place. This consultation will inform whether we put such legislation forward and gather information on potential operators interested in taking part in the trial.

How to respond

The consultation period began on 9 November 2020 and will run until 4 January 2021. Please ensure that your response reaches us before the closing date.

If you would like alternative formats (Braille, audio CD, and so on), please contact IntermodalHGVConsultation@dft.gov.uk.

Please email consultation responses to IntermodalHGVConsultation@dft.gov.uk.

Due to remote working for the foreseeable future, we cannot accept hard copies of responses but please let us know if you are unable to respond by email.

When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.

If you are a freight operator interested in taking part in a possible trial, please provide the additional information requested in the expressions of interest section and – if possible – respond to the more detailed technical questions in the impact assessment.

Freedom of information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the DfT.

Data protection

The DfT will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

The DfT is carrying out this consultation to gather evidence on the use of 48-tonne heavy goods vehicles (HGVs) for intermodal freight. This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT will, under data protection law, be the Controller for this information.

As part of this consultation, we’re asking for your name and email address. This is in case we need to ask you follow-up questions about any of your responses, or to get in touch with you if you express interest in taking part in a possible trial. You do not have to give us this personal information. If you do provide it, we will use it only for the purpose of asking follow-up questions, or to contact you about taking part in a possible trial.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact our Data Protection Officer.

Your information will be kept securely on a secure system within DfT and destroyed (within 12 months) after the consultation has been completed.

If you do take part in a trial, there will be a further registration process detailing how your information is used and how long it will be kept.

Background

Request made to the DfT

Several interested parties have approached the DfT to request that we consider allowing the operation of 6-axle articulated lorries up to a maximum laden weight of 48 tonnes as part of domestic intermodal journeys on specific, limited-distance routes, to move repetitive loads between railheads and origin/destination points such as factories and distribution centres. Their proposition has been labelled ‘48 tonnes for 48 miles’.

It has been proposed to make such journeys more efficient, with cited benefits relating to securing or increasing the attractiveness of the intermodal (rail and road) option compared with an all-road alternative. The distance threshold is intended to enable loads to be moved by road to railheads from a good range of relevant origin and destination points, while ensuring most of any journey is done by rail. We have used a 50-mile threshold in our analysis.

The standard weight limit for a 6-axle articulated lorry in Great Britain is 44 tonnes. Loads outside normal weights and dimension can be carried if they cannot be divided, under processes related to abnormal indivisible loads. The request to the DfT is to allow divisible loads to be carried so that the maximum laden weight is 48 tonnes, but within the existing weight limits that apply to individual axles.

The extra payload will allow each loaded container to carry the same payload as a 44-tonne maximum payload articulated 6-axle lorry. This then allows fewer road legs than is currently needed to be operated when using intermodal road/rail transport (as it compensates for the extra unladen weights of containers used on trains compared with those used for all road operations). This extra unladen weight (and hence payload penalty for intermodal compared with rail journeys) is around 4 tonnes.

Domestic intermodal operations

Domestic intermodal freight can be defined as goods transport by more than one mode of transport within the United Kingdom. The interested parties have requested the 48-tonne allowance for road vehicles be trialled in the context of certain types of intermodal road or rail journeys within Great Britain.

Intermodal transport of lorry-sized loads tends to be only viable for longer distance journeys – for example, those between Scotland and England – because of the time and costs of changing modes, and the way rail transport operates.

The DfT operates a mode shift revenue support grant for domestic intermodal flows, in recognition of the non-commercialised effects of freight transport (such as pollution and congestion for other road users). Most domestic intermodal traffic supported by the grant is containerised. Work in the context of the grant indicates that these transports tend to be only just viable with the grant. They are far less numerous than port intermodal flows, where rail transport is used to move containers from ports to final destinations, possibly also with final road legs.

The DfT has assessed the effects of 48-tonne operations on example intermodal routes. There is a public interest case for intervention so we’re putting forward the proposals in this consultation.

Proposal for consultation and UK government role

The proposal being consulted about is for a trial, lasting up to 4 years, of a number of routes, which will be cleared for specified operators to run 6-axle articulated lorries at a maximum laden weight of 48 tonnes, within all other applicable current regulations about weights and dimensions (including for maximum axle weights).

There would be a maximum length for any cleared route, proposed to be around 50 miles.

The operations would need to be part of an intermodal journey with a rail leg, both ends of which have to be within Great Britain, or one end of the journey in Great Britain and the freight travelling by rail through the Channel Tunnel (excluding the Euroshuttle).

The UK government is responsible for regulations about road vehicle weights and dimensions allowed on public roads across Great Britain. That function is devolved in Northern Ireland. This consultation covers routes in Great Britain.

Many road transport responsibilities, including for trunk road networks, are devolved in Scotland and Wales. Any routes in – or partly in – Scotland or Wales would require the approval of the relevant devolved administration, along with relevant local authorities.

The UK government would arrange for an evaluation of the trial, which will be released before its end. Some specific safeguards are also proposed for the trial operations.

Legislation is likely to be needed to enable the trial operation proposed in this consultation.

48-tonne loads and structures

Preliminary technical assessments clearly show that the operation of lorries at 48 tonnes is outside the limits and tolerances permissible for many bridges and other structures on British road networks. All routes will need to be checked in advance for suitability and some are liable to be ruled out because of structural issues.

In Great Britain, a maximum laden weight for 6-axle articulated lorries of 44 tonnes was first allowed on intermodal journeys and then allowed more generally.

If this trial goes ahead, it would not be allowing the use of 48-tonne maximum laden weights for all intermodal journeys in Great Britain because most bridges and structures are not designed to accommodate these loadings.

Feedback from stakeholders

We have discussed the possible proposals with a small number of road and rail freight stakeholders.

Road freight organisations have provided some technical input about how the proposal might be implemented.

Rail freight representatives have highlighted the importance of ensuring the proposal supports intermodal journeys and is not a precursor to more general 48-tonne operations.

Assessment of the issues and options

Proposals for consideration

The core proposal for consideration is:

• allow the operation of 6-axle articulated lorries carrying divisible loads at a maximum laden weight of 48 tonnes (as opposed to 44 tonnes) on specific distance-limited routes in Great Britain on a trial basis
• for road legs of an intermodal journey with both ends of the journey within Great Britain, or one end of the journey in Great Britain and the freight travelling by rail through the Channel Tunnel (excluding the Euroshuttle); the origin and destination of the intermodal journey would be points of production (including manufacture) or inland distribution (including centres where the load is broken for onward transport), but neither would be a port where product has arrived from abroad or goes abroad

Question 1

Should a trial of 48 tonnes maximum laden weight on specific routes for domestic intermodal journeys in principle be permitted?

The proposal could:

• be restricted to intermodal journeys with a rail leg, or it could also allow for inland water and coastal shipping components; we would like to check for any interest related to waterborne freight
• have a restriction on the length of road legs; the proposal upon which the DfT seeks views is that there should be a length restriction on any road leg of 50 miles
• include some specific monitoring and reporting requirements, to ensure the trial is running safely and to allow for post-trial evaluation

Question 2

Should a trial be restricted to intermodal journeys with a rail leg or also include domestic intermodal journeys with a water leg?

Question 3

Is 50 miles the right maximum distance for any road leg? If not, should the distance be shorter, longer or should there be no distance limit?

The proposal would be suitable for road legs covered frequently between points of production or distribution and railheads.

We invite applications from interested road transport operators – please register your potential interest via the expressions of interest section so we can contact you in the future.

We envisage a limited number of routes being included in the trial and criteria will be used to decide which, if interest exceeds that level. A trial lasting 4 years is proposed, with an assessment after 2 years as to whether the trial should continue.

Question 4

Is 4 years the right duration for a trial? If not, should it be shorter or longer?

Based on the characteristics of some possible examples of trial routes, we have made an assessment of the possible public outcomes and other effects of a trial, which are outlined in the impact assessment.

If the trial helps secure existing intermodal freight traffic or enables more, it might result in net public benefits, including those due to the reduction of:

• road congestion
• carbon emissions
• pollution
• noise
• road safety risks

and those related to the rail legs of journeys.

The road legs of journeys would have a number of positive and negative effects, compared with the way they are delivered using the existing maximum laden weight of 44 tonnes. These have been assessed in a similar way to the valuation of net public benefits used for the Mode Shift Revenue Support grant, based on standard valuations of the effects.

The trial would operate only on routes where infrastructure could accommodate the 48-tonne load. Even here, the extra loading may accelerate the need for significant maintenance work on specific structures or require specific assessments. The way any such costs arising should be met is discussed later in the Process for approval of route for a trial section.

Besides costs related to specific structural assessments and strengthening, the road legs would be associated with some increases in roads and structural maintenance costs. Some costs are directly proportionate to vehicle weight; others vary in proportion to the power of 4 of vehicle weight.

Our assessment is that these extra costs might be outweighed by public benefits arising from fewer lorry movements (including benefits related to congestion, carbon emissions, pollution and safety). Controls would be designed to support safe operation of the heavier lorries.

Not all the public policy outcomes have been quantified or expressed in monetary terms in the impact assessment – for example, the more efficient use of lorry drivers, besides benefiting their employers, may also at the margin be helpful in the context of substantial and long-lasting labour shortage for drivers. The true costs and benefits of this proposal will become more apparent at the trial stage, hence why a trial has been proposed in the first instance to understand these in more detail.

Question 5

Does the impact assessment consider the main likely effects of a trial sufficiently? Are there any additional effects or impacts that you think have not been reflected?

In summary, for the public interest, this proposal seeks to encourage a modal shift from road to rail and supports intermodal journeys. By removing lorries from the road or reducing the distances they travel, it aims to lead to lower emissions and reduced congestion, and may marginally ease the shortage of available HGV drivers.

Implementation

Applying for the trial

How to apply

The DfT invites road transport operators who may be interested in working under the trial conditions to register that interest alongside this consultation by contacting IntermodalHGVConsultation@dft.gov.uk by 4 January 2021 with the information listed in the expressions of interest section of this consultation.

At this stage, operators should submit information about the:

• routes they propose to follow under the trial
• flows involved
• envisaged frequency of journeys

There are further specific questions in the impact assessment for operators who are interested in taking part in a possible trial.

Subject to the outcome of this consultation, the DfT would then contact the operators for more information.

Eligibility

We anticipate that the trial will only be open to operators that, when they join the trial:

• are members of the Driver and Vehicle Standards Agency (DVSA) Earned Recognition Scheme
• have a green rating under the DVSA Operator Compliance Risk Score, or
• are highly rated under similar types of assessment

Routes

If there are more technically feasible routes suggested than the number appropriate for a trial (estimated as a maximum of about 10 at this stage), the DfT will prioritise which should be taken forward.

Likely criteria for deciding which routes to trial are related to:

• the level of net positive outcomes as assessed by the DfT
• establishing a geographic spread of routes across Great Britain
• the ratio of public positive outcomes to forecast public costs and dis-benefits

Once a route has been selected for the trial, the operation of vehicles with a maximum laden weight of 48 tonnes (under trial conditions) would not be restricted to one operator. Other operators could join and use the specific route involved, but would need to also meet the requirements of the trial and agree to abide by its conditions.

Specific trial conditions and controls

While there is likely to be an intrinsic safety benefit if the trial results in the reduction of HGV mileage via a reduced incident rate, the additional weight may lead to negative safety impacts on individuals, structures and infrastructure.

It will therefore be important to implement controls as part of the trial to reduce this impact. Suggested controls include:

• use of specific loading models to ensure vehicles and individual axles are not overloaded.
• route planning to permit only specific pre-agreed routes and seeking permission of structure owners
  • this may also include contingency planning were there to be disruption on the route requiring diversion – if a route becomes unavailable during the trial, an alternative route may be sought and agreed with structure owners: however, the presumption is that if a route approved for 48-tonne vehicles is not available then vehicles would revert to 44-tonne operation
  • relevant highway authorities must approve the operator’s routes before operation can commence
  • 48-tonne vehicles would not be able to operate in convoys, as multiple 48-tonne vehicles on one structure simultaneously (due to traffic) could cause structural problems – departures of vehicles using the same route would therefore need to be staggered to ensure this did not happen
• incident notification, both of the heavier HGVs incident rate and the operator’s standard fleet – this would include damage-only incidents

Reporting requirements for trial participants

The DfT proposes to make specific reporting requirements on operators taking part in the trial related to 2 issues (or to both):

• information to ensure that the trial is working safely
• information to assist the evaluation of the trial

The requirements are subject to further development. In respect of information for evaluation, it’s likely that the DfT would seek quantitative returns with a similar level of burden on operators, as was the case with the earlier stages of the longer semi-trailer trial.

Trial safety monitoring conditions:

• a) GPS tracking of participating vehicles to ensure they only use pre-agreed routes and do not operate as convoys
• b) load weight records to be kept for relevant journeys and available for inspection by relevant parties (the trial monitoring organisation, DVSA, DfT, Traffic Commissioners for Great Britain, affected structure owners, and so on)

Post-trial evaluation conditions:

• c) monitoring of load weights carried via intermodal rail and road versus road-only by participating operators, for analysis of the effect of the extra maximum weight allowance – in order to allow a counterfactual comparison, retrospective data may be needed; this is discussed in more detail below in the Reporting requirements for trial participants section and in the impact assessment
• d) average fuel consumption to allow comparison of the 48-tonne and standard vehicles
• e) any increase in running costs of 48-tonne vehicles compared with standard vehicles – for example, components wearing out more quickly than usual
• f) any increase in staff costs – for example, due to any extra training required
• g) any adaptation costs required to allow vehicles to operate at 48 tonnes – for example, modifications to trailers

Safety monitoring or evaluation conditions:

• h) incident reporting, as described previously in Reporting requirements for trial participants – this is evidently important for safety monitoring, but is also key for evaluation, as a reduction in overall HGV mileage is anticipated as bringing safety benefits, but could be offset if there is an increase in incidents on the road legs to or from railheads

A key evaluation question is whether the increase in permitted maximum weight has a positive impact on the volume of intermodal rail freight transported by an operator.

The ideal counterfactual group would be operators who also carry out intermodal freight operations, but continue with the current maximum weight limits. However, there is limited incentive for operators to agree to data sharing without the benefits of taking part in the trial. This could lead to less diligent data collection and it may be very difficult to convince operators not permitted to use the higher weights to take part in a counterfactual group at all. While we propose the use of retrospective data, further scoping work will be carried out during the consultation period to determine the best trial design and counterfactual group. Potential alternative methods to source counterfactual data are discussed in the impact assessment.

Question 6

Do you have any views on the potential trial designs discussed in the impact assessment or suggestions of alternative ways to source counterfactual data?

With regards to loading levels, the DfT anticipates it would require records to be kept of the weights of loads moved. This is partly for evaluation but also to help guard against overloading. It’s likely that extra compliance checks would be made and that normal enforcement tolerances for overloading would not apply.

Overloading in excess of 48 tonnes would not only be illegal, but would also be liable to lead to disproportionate road wear or damage to structures.

Significant breaches of requirements, including those related to routing or loading, may result in operators being removed from the trial early.

Compliance-related record-keeping related to the trial is likely to be a key implementation issue. More specific information on the likely monitoring requirements is in the impact assessment.

Process for approval of routes for a trial

Not all routes – even on the strategic road network or other major roads – are suitable for any 48-tonne operations due to the strength and resilience of specific bridges or suitability of highway infrastructure. Therefore, some proposals from operators may be ruled out due to constraints related to infrastructure.

On the main motorway and other modern dual carriageway trunk road networks, constraints related to structures are unlikely. If there are cost issues, they would be considered in the assessment of proposals for trial routes. Problematic structures or infrastructure are more likely on local authority roads or the junctions onto motorways or other major trunk roads.

The DfT proposes to seek local highways authorities’ views about proposed trial routes involving roads for which they are responsible. We would also check if there are any specific issues connected with bridges or infrastructure that would rule out certain routes or be associated with specific costs connected to structural assessments or strengthening.

The DfT is considering how costs to local authorities can be mitigated and minimised, including securing a contribution from a commitment from participating operators, and using existing DfT budgets to cover excess. It’s suggested that participating operators could be asked to contribute up to 50% of local authority costs related to structural assessments or strengthening required as a result of the trial operations.

The DfT also proposes to allow local highway authorities to block routes being included on the trial if they result in excessive additional costs related to bridges and infrastructure being incurred during the trial. A threshold of such costs is likely to be between approximately £0.15 million and £0.5 million. These costs would need to be related to specific structural assessments and planned strengthening required by the trial, which would not be needed otherwise. General maintenance costs due to increased wear due to heavier vehicles would not be included. Costs would need to be checked and agreed by the DfT before they result in a route not going ahead.

Question 7

Should a local authority be able to block the introduction of routes if a trial route would incur excessive costs related to assessment and strengthening of specific structures? Is between £0.15 million and £0.5 million a suitable level for excessive costs? Should local authorities be able to seek financial contributions for such costs of up to 50% from participating operators?

The inclusion of a route – wholly or partly – in Scotland and Wales would require the approval of the respective devolved administration. The DfT is keen to trial routes across Great Britain and ensuring a geographic spread of routes will be a selection factor if more viable routes are proposed than intended to be trialled.

As the proposal was initially made by a Scottish haulier and there is likely to be significant suitable freight traffic moving between Scotland and England, it’s anticipated that there will be a high level of interest in the trial from Scotland.

It’s also possible that the condition of a bridge or other structure on a route may deteriorate within the period of the proposed trial. The DfT, on advice from the relevant authority responsible for the structure, could in those circumstances choose to terminate the permission for that route. We anticipate a minimum notice period of 3 months, although emergency short notice restrictions for safety reasons would not be ruled out. Operators would be able to propose an alternative route, which would need to be approved by the relevant structure owners, similarly to the original route proposal.

Full list of consultation questions

Please include your name, organisation and email address in your response.

Main questions (for all respondents)

1. Should a trial of 48 tonnes maximum laden weight on specific routes for domestic intermodal journeys in principle be permitted? 2, Should a trial be restricted to intermodal journeys with a rail leg or also include domestic intermodal journeys with a water leg?
2. Is 50 miles the right maximum distance for any road leg? If not, should the distance be shorter, longer, no distance limit?
3. Is 4 years the right duration for a trial? If not, should it be shorter or longer?
4. Does the impact assessment consider the main likely effects of a trial sufficiently? Are there any additional effects or impacts that you think have not been reflected?
5. Do you have any views on the potential trial designs discussed in the impact assessment or suggestions of alternative ways to source counterfactual data?
6. Should a local authority be able to block the introduction of routes if a trial route would incur excessive costs related to assessment and strengthening of specific structures? Is between £0.15 million and £0.5 million a suitable level for excessive costs? Should local authorities be able to seek financial contributions for such costs of up to 50% from participating operators?
7. Do you have any further comments?

Impact assessment questions (for operators only)

There are further, more specific questions in the impact assessment, which relate to the costs to businesses of taking part in a trial.

If you are an operator interested in taking part in a possible trial, please also answer the following questions and provide the information requested in the expressions of interest section.

1. How many intermodal containers per year have you moved via rail over the last 5 years?
2. How many intermodal containers per year do you expect to move via rail over the next 4 years? Will this be more or less than you would expect to move if the trial does not go ahead?
3. How many containers per year have you moved via road only over the last 5 years?
4. How many intermodal containers per year do you expect to move via rail over the next 4 years that would have otherwise been shipped via road only? Will this be more or less than you would expect to move if the trial does not go ahead?
5. How many miles is the route that the 48-tonne HGV will travel from warehouse to rail depot at each end?
6. If you move(d) goods via road only, how many miles is each typical journey from origin to destination?
7. How many miles are travelled via rail for each typical journey from origin to destination?
8. How many tonnes of goods on average per journey did you transport over the last year?
9. How many tonnes of goods per journey do you expect to transport during the trial?
10. Is the time taken to review the trial conditions reflective of the expected time taken to carry out these tasks? If not, what would be a reasonable estimate for the number of days?
11. Is the time taken to review the trial conditions reflective of the expected time taken to carry out these tasks? If not, what would be a reasonable estimate for the number of days?
12. What employees do you expect to be involved with the review of the trial conditions? How many hours would you expect each individual in your organisation to take to review? – for example, how many hours for each employee? (director, transport manager, admin staff, etc). What is the average wage for each of these types of employees?
13. Do you anticipate there being any costs associated with upgrading or replacing your existing fleet or trailers to be able to carry the additional weight? If so, how much will it cost per trailer and how many trailers would this impact?
14. Do you anticipate that you would have to provide training to employees? If so, what would you expect the cost of this to be per employee?
15. If yes, how long would you expect the training length to be?
16. If yes, who will deliver this training? Will it be in-house, or will you source an external company?
17. If yes, do you expect to deliver this training on a one-to-one basis or a group basis? If a group, how many would you expect to deliver to at any one time?
18. How long do you anticipate it will take to scope out proposed routes for your fleet to and from a rail depot?
19. During the trial, do you expect that there would be additional time associated with carrying out the route risk assessments/re-routing than already considered for standard trailers? If so, how much longer would you expect this to take?
20. Are the employee costs presented by the Transport Engineer report reflective of your average employee costs (salaries of £37,184)? If not, how much different is this?
21. Is the annual mileage per driver of 85,000 presented in the Transport Engineer report reflective of your average driver mileage? If not, how much different is this?
22. Are the costs provided by the Transport Engineer report representative of the standard trailer annual running costs? These are presented in the table beneath the call-out box.
23. Are the annual running costs the same for vehicles carrying 48 tonnes as the current standard trailers? If not, by what percentage are these different?
24. Are there any costs involved with adapting trailers to carry 48 tonnes, or buying suitable new trailers?
25. Do you anticipate increased tyre costs associated with operating 48-tonne vehicles due to the increased weight? If so, how much more expensive would you expect this to be per trailer each year?
26. Have you experienced increased/decreased repair and maintenance costs while carrying additional weight? If so, how much was this increase?
27. Do you expect increased/decreased fuel costs while carrying additional weight? If so, how much do you think this would be?
28. Would the introduction of this policy result in a reduction in your fleet size and thus a reduction in vehicle excise duty (VED) and road user levies (RUL)? If so, how much would the fleet reduce by and thus how much would VED and RUL be reduced by?
29. How many 48-tonne load-bearing vehicles do operators with less than 10 employees intend to use in the trial?
30. How many 48-tonne load-bearing vehicles do operators with less than 50 employees intend to use in the trial?
31. Are either of these operators (with less than 50 employees) subject to higher costs than those which have been assessed in this consultation document?

Expressions of interest

If you are a freight operator interested in taking part in any potential trial of 48-tonne vehicles for intermodal freight, as well as your answers to the consultation questions, please include the following information.

• your name
• the company you are responding on behalf of
• an email address and phone number
• the routes you propose to follow under any trial (please be as specific as possible
• the envisaged frequency of these journeys (please be as specific as possible)

This information will only be used to contact you about your responses or a trial.

What will happen next

A summary of responses, including the next steps, will be published within 3 months of this consultation closing. Paper copies will be available on request.

If you have questions about this consultation, please contact:

Rob Evans, Freight, Operator Licensing and Roadworthiness team

Email address: IntermodalHGVConsultation@dft.gov.uk

Annex A: Impact assessment

The impact assessment (PDF, 509KB) is listed separately.

Annex B: Consultation principles

The consultation is being conducted in line with the government’s key consultation principles. If you have any comments about the consultation process, please contact:

Consultation Coordinator
Department for Transport
Zone 1/29 Great Minster House
London SW1P 4DR

Email: consultation@dft.gov.uk