Consultation outcome

Heavier intermodal freight trial: government response

Updated 24 August 2021

Introduction

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 increase in weight is intended to offset the heavier trailer and container needed for intermodal freight, thereby encouraging modal shift of freight from road to rail, with reductions in emissions and congestion.

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

A real-world trial of this proposal would provide a full and accurate picture of the costs and benefits, 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 or not.

In November 2020, the Department for Transport (DfT) published a consultation to seek views and evidence about whether in principle to have a trial, its likely effects and processes required to implement such a trial.

The consultation contained 2 sets of questions. The main set sought views about whether the trial should go ahead in principle of the trial and how a potential trial could be run.

A further set asked more detailed technical questions of transport operators, answers to which would help inform further analysis of the proposal. These mainly related to the costs of running a vehicle and any adaptations that would be required to run a vehicle at 48 tonnes.

This response has only considered the answers to the first set of questions. A very limited number of responses was received for the second set. However, we are grateful to those who did respond to these questions and their answers will be used to help develop the analysis of the proposal further.

A total of 29 responses to the main set of consultation questions were received. Of those, 21 were from freight industry organisations, highways authorities and road safety groups. The remainder were from private individuals. We are grateful for the considered evidence and opinions submitted in response to this consultation.

Summary of organisations responding to the consultation

Type of responder	Number of responses
Private individual	8
Freight operator	5
Trade association	5
Regional public body	4
Consultancy	2
Lobby group	2
Charity	1
Professional body	1
National public body	1

Summary of responses

Question 1

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

Of the 29 responses, 11 said yes to trial going ahead without raising any further conditions, 10 said yes but with conditions and 8 said no.

Of the 10 responses identifying conditions, the main concerns arise from the number of heavy goods vehicles (HGVs) that can safely transport additional weight, the number of routes that cannot accommodate the additional vehicle weight and the safety issues that arise due to the higher vehicle weights.

It was suggested that other issues related to the rail freight system could be the determining factor in whether intermodal transport is used rather than exclusively the maximum payload weight available on the road leg of these journeys.

Concerns related to local authority highway maintenance budgets were raised in several responses, with suggestions that any extra maintenance (or prior inspection) due to the higher vehicle weights could not be paid for from existing funds.

A suggestion was made that when granting an operator permission to enter the trial, DfT, via the Driver and Vehicle Standards Agency (DVSA) conducts an appraisal of all trial vehicles and trailers, ensuring vehicles and trailers are suitable for intermodal operations at 48 tonnes.

A number of specific issues that would need to be checked, or rules adhered to during the trial were suggested, such as outer axle spread of tractor units, trailer neck loading limits, trailer braking requirements, front axle plated weights and ensuring careful loading and balancing of trailers.

Several respondents raised concerns that the previous general maximum weight increase from 38 to 44 tonnes happened after initially only being permitted for an intermodal trial. Seeing this process repeated would negate any intent to encourage modal shift towards intermodal journeys.

Eight people disagreed with the trial going ahead. Of these, 5 objected without comment and the remaining raised various concerns, mainly related to safety and road maintenance.

Question 2

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

Twenty respondents agreed that the trial should be open to water transport if available. Several of these respondents were happy for water legs to be permitted but thought that there may be no (or very few) suitable operations taking place.

There were 8 ‘no’ responses, which were from the private individuals and organisations that in principle opposed any trial. It was also suggested that the inclusion of water routes would introduce another set of issues and make the trial more difficult to evaluate than if it was exclusively aimed at increasing modal shift to rail.

There was one ‘other’ response where no comment was made.

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?

Thirteen responses agreed that a 50-mile road leg was the right maximum distance for the trial, with some commenting that any distances above this may negate the intention to reduce road mileage in favour of rail and (if permitted) should be confined to a limited number of high-volume regular routes.

Five responses agreed that 50 miles should be the distance limit, but with conditions. The majority suggested longer distances should be considered in cases where there was no rail freight depot within 50 miles so that intermodal journeys which start in more remote regions could still participate in the trail.

It was also suggested that routes should be restricted to going to the nearest suitable rail depot, rather than any depot within 50 miles, or that routes only be permitted if they are on main roads (where problems related to road structures are less likely).

There were 8 ‘no’ responses from the private individuals and organisations that in principle oppose a trial.

There were 3 ‘other’ responses, where no comments were made or the response did not relate to that question.

Question 4

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

Eleven responses agreed that 4 years is about the right duration of the trial.

Ten responses agreed to the duration of the trial but with conditions. Of these, 3 commented that the trial could be shortened if the interim assessment at 2 years if demonstrates the effectiveness of the initiative, the trial should be made permanent at that point.

Two responses agreed to the duration but commented that the trial may need to be longer in order to allow any investments in infrastructure to be realised within the timeframe of the trial.

There were 8 ‘no’ responses from the private individuals and organisations that in principle opposed the trial

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?

Eight responses agreed that the impact assessment considered the main likely effects of the trial sufficiently.

Five responses agreed but with conditions, several of these respondents pointed out that further monitoring, audit and review should take place during the trial, using GPS tracking, automatic number plate recognition (ANPR) cameras and dynamic weighbridges. Also, that measuring changes in rail freight volumes would be a key indicator of the success of the trial.

It was also suggested that further information on road infrastructure considerations should be included within the impact assessment, as this is likely to be a significant issue for highway authorities.

An error in the consultation document was highlighted with paragraphs 77 and 79 quoting ‘noise’ rather than accident and environment statistics.

There were 12 ‘no’ responses, the majority from the private individuals and organisations that are opposed to the trial.

A number of detailed suggestions were made, as to what additional information should be considered in the impact assessment. In particular, various issues related to how heavier vehicles would affect road structures and surfaces, both under normal conditions and in the event of a collision with either road structures or other road users.

It was commented that the impact assessment does not account for the effect of heavier vehicles on the safety of people cycling and other vulnerable road users and that the trial proposals should contain more detailed consideration of how to reduce the risk these groups arising from any trial.

A further comment was that the impact assessment mentions an assumed increase in maintenance cost, but the rationale behind this is not discussed and this area of the impact assessment needs to be developed.

There were 4 ‘other’ responses in which no comment was made.

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?

The majority of respondents broadly agreed with the potential trial design, with 21 responses having no comment on the overall design.

Eight respondents provided comments on the trial design.

It was suggested that a broad geographic spread across the UK is unnecessary and DfT should not attempt to control or influence where the trials occur – open competition should decide where any routes are.

It was commented that a counterfactual group of operators could be unnecessary, either via participating hauliers providing retrospective data, or Network Rail providing data on previous rail freight volumes.

Some respondents commented that any interim assessment should appreciate that the trial could stimulate further private investment into freight facilities at or near to railheads that may not have been completed within the suggested 4-year trial and this should be acknowledged.

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?

Eight respondents agreed with the proposed options for local authorities (LAs).

Four respondents agreed to the proposal with conditions, indicating that the government should provide additional funding to the LAs to assist with costs due to the trial. The majority felt that either a small or no contribution should be sought from the operators, as that would mean fewer volunteers participating in the trial.

There were 9 ‘no’ responses, mostly related to the private individuals and organisations that are opposing the trial. With one respondent agreeing to the overall trial, but thinking that there should be no additional burden on the LAs and all costs should be met by trial participants or central government.

There were 8 ‘other’ responses, from respondents that did not comment on this question.

Question 8

Do you have any further comments?

There were 22 respondents with further comments, the majority were in relation to points already raised and addressed under the other questions in this consultation response. In particular, comments related to safety, monitoring with the trial and how additional infrastructure costs should be addressed.

Seven respondents had no further comments.

One suggestion was to mandate that vehicles participating in the trial should be of the latest engine standard (Euro VI) and use low carbon fuels, to increase emissions savings.

It was suggested that drivers operating vehicles within the trial undertook further safety training to reduce danger to cyclists and other vulnerable road users.

Comments were made about the risk of higher maximum weights becoming generally allowed, as was the case with the current 44 tonne general weight limit.

Expansion in the impact assessment of the costs to businesses was raised, as there may be costs related to adaptation, monitoring and reporting within the trial.

Next steps

Having considered the responses to this consultation and following discussion with the Welsh and Scottish governments, DfT will continue to work towards implementing a trial of 48 tonne vehicles for intermodal journeys, within Great Britain (vehicle weight limits are devolved in Northern Ireland).

It was agreed by most respondents that the proposal could contribute to modal shift of freight to rail, with particular benefits via reductions in emissions (both of carbon dioxide and other air pollutants) and congestion.

However, there was a clear view in the responses received that further consideration needs to be given to the effects of heavier vehicles on road infrastructure and maintenance by highways authorities. DfT has therefore developed the impact assessment further in relation to these issues.

The approach to financial support for highways authorities will depend on the level of impact that the operation of 48 tonne vehicles would have. Any routes requiring costly adaptations such as significant bridge strengthening would not be included in the trial (unless trunk road or local authorities specifically and voluntarily agree to fund or part fund work).

Routes that would only incur costs related to faster road wear and desk-based bridge checks would be required to be included without extra financial support for local highway authorities.

Exceptionally, routes that would incur significant specific costs could be included in the trial, with some support from DfT towards those costs.

Various respondents were concerned that the current 44 tonne weight limit was initially only for intermodal journeys, before being generally permitted. DfT would like to make clear that there has been no consideration of making a 48-tonne weight limit generally available.

Doing so would undermine the intention of modal shift of freight to rail. It would also be practically infeasible. Respondents to the consultation made clear that there would be cases where use of 48 tonne vehicles was not possible on current road infrastructure, hence the intention to only permit their use on pre-agreed and checked routes.

Allowing 48 tonne vehicles in general circulation would mean checking and agreeing routes would not be possible.

The effect of a trial on vulnerable road users was raised as a concern in the consultation responses. We will consider further how this could be accounted for during the implementation of a trial, in particular during route selection and how interactions between trial vehicles and vulnerable road users could be minimised.

The proposed duration of the trial was generally deemed to be reasonable. There were few responses on the trial design proposals, but the suggestions received will be investigated. Various suggestions around issues that should be monitored and conditions imposed on operators during the trial were received and these will be considered.