Consultation outcome

Longer semi-trailer trial

Updated 24 June 2022

This was published under the 2019 to 2022 Johnson Conservative government

Applies to England, Scotland and Wales

Executive summary

Since 2012, a trial of longer semi-trailers (LSTs) of up to 15.65 metres has taken place on roads in Great Britain (GB), enabling 30 standard UK pallets to be transported in a trailer as opposed to 26, offering more efficiency and fewer lorry journeys for commodities limited by bulk as opposed to weight. This efficiency is further enhanced by a number of operators utilising double deck trailers.

The maximum length of a longer semi-trailer plus tractor unit is 18.55 metres, marginally shorter than road train combinations allowed in general circulation in the UK and mainland Europe. Until agreement is given that LSTs can be used on international operations, they will be limited to use in the UK.

The ongoing LST trial now involves around 2,600 LSTs. Up to the end of 2019 the trial results indicated that:

• on average, the use of LSTs reduced journey numbers by 1 in 12, with more than 54 million vehicle kilometres saved
• 48,000 tonnes of CO₂(e) and 241 tonnes of NOx have been saved
• on a per kilometre basis LSTs have been involved in about 53% fewer personal injury collisions and casualties than the GB articulated heavy goods vehicle (HGV) average^{[footnote 1]}

Mainly qualitative information suggests that practices in the trial such as specific driver training, operator practices (including route selection, route assessment, driver selection and driver familiarity) contribute to the better safety performance of LSTs per kilometre. An important issue in considering the more general use of LSTs is how to ensure the safety performance remains as good as or better than standard trailers.

The consultation seeks evidence on the merits of 2 alternative packages of specific regulation for LSTs (on top of the normal rules that apply to heavy goods vehicles). This regulation would be targeted towards requiring or encouraging practices such as route planning, data collection, incident reporting and driver training, to maintain higher productivity and safety performance.

The consultation also seeks views on the assessment that allowing LSTs to operate outside trial conditions would lead to a substantial growth in their use. Projections suggest that in a decade’s time about 16,000 LSTs could be operating - approximately 8 to 10% of the UK’s domestic semi-trailer fleet.

The department’s preferred option is the lighter additional regulatory option, which on top of regulations applicable to standard heavy goods vehicles, proposes:

• the requirement to report incidents involving an LST where a person is killed or injured whether this occurs on a public road or private land and incidents involving LSTs only on public roads where damage is caused
• specific driver training, lasting a minimum of half a day, which could be provided by the operator, but which could also be done via periodic training for driver certificates of professional competence (DCPC)
• underpinning specific identification of LSTs in operator licensing
• the requirement for operators to undertake and retain a risk assessment of the proposed route an LST will follow and to have regard to and record feedback received from drivers on the appropriateness of routes
• operators will be required to undertake an appropriate level of compliance monitoring to ensure LSTs are being operated on the routes set and to take appropriate action where deviations are identified

The assessed effects of this option, based on the retention of much of the trial’s superior productive and safety performance, including significant reductions in the vehicle kilometres travelled and the resulting overall environmental benefits.

This consultation also seeks evidence about a heavier additional regulatory option. On top of the lighter specific regulatory option, this option would:

• require operators to operate LSTs on a defined network consisting of major roads (this includes all motorways and A roads) for a minimum of 80% of each journey an LST undertakes
• require drivers to undertake approved LST CPC training before their DCPC is renewed in order to retain entitled to operate LSTs
• require operators to be able to accurately track the routes LSTs take by GPS, and have a system in place to collect and store this data for a 5-year period. Operators would be required, should the police, Driver and Vehicles Standards Agency (DVSA) or Traffic Commissioners of Great Britain request such data, to provide the data in a required format to identify whether the 80% requirement is being achieved
• require operators to apply to the traffic commissioner on an annual basis for approval to continue to operate a LST once the trailer is over 10 years old

The assessed effects of this option indicate gains in productivity and safety over not having LSTs. However, there is less net gain to business than for the preferred option due to lower take-up and because of the added regulatory burden.

Additionally, this consultation also seeks evidence about allowing LSTs to enter into general circulation without any extra specific regulatory controls. The LSTs would operate under the normal regulatory regime for heavy goods vehicles, including:

• the operator licensing regime overseen by the Traffic Commissioners for Great Britain, with undertakings required to have transport managers, a good reputation and enough financial standing
• requirements for vehicle inspections and maintenance (usually at about 6-weekly intervals), plus the independent annual goods vehicle test
• drivers to have category C+E licences and DCPC

The safety performance of this option is assessed as being similar to that of standard articulated lorries - and the average productivity increase as less than in the trial and the options with specific regulations. Nonetheless, there are substantial benefits for business and the public.

The reference case against which these options have been assessed is the current policy of continuing the trial until 2027, with a maximum of 2,800 LSTs. In this case no other LSTs would be operated following the trial. This is also an entirely feasible option. If this option were taken forward the trial might then be closed to new LSTs.

The consultation also seeks evidence about the specific parts of the lighter and heavier additional regulatory options. A decision could be made to take forward parts of the options in different combinations. The consultation also seeks further evidence about the costs and other effects indicated in the impact assessment (PDF, 1.9MB).

Evidence related to productivity and safety of LSTs is also sought through the consultation. Despite better average incident rates in the trial compared with lorries in normal operation, there have been (to date) 2 fatal incidents involving LSTs. Following investigation, neither of these cases appear to have been caused by factors related to the trailer being an LST.

The evaluation has also considered other technical issues, for example concluding that there has been no significant effect on rail freight volumes.

Background and trial evaluation

Background

The Department for Transport has been operating a trial of longer semi-trailers (LSTs) since 2012. The trial is designed to evaluate the impact of LST operations on efficiency, emissions and safety.

An LST is a semi-trailer with a length of either 14.6 metres or 15.65 metres. This is up to 2.05 metres longer than standard length trailers (13.6 metres) under construction and use regulations. An LST has a maximum total vehicle length, including tractor unit, of 18.55 metres.

The trial began with an initial allocation available of 1,800 semi-trailers and to ensure that operators taking part could incur the expense of purchasing an LST and continue using it until the end of its expected useful life, the length of the trial was set at 10 years. In January 2017, the trial was extended by 5 years and an additional 1,000 LSTs were permitted. All LSTs are required to operate under a vehicle special order (VSO) granted by the Vehicle Certification Agency.

The main findings of the 2019 annual report show that:

• 2,565 (90%) LSTs were registered on VSOs with 2,473 (88%) of LSTs on the road and having submitted trial data
• 54 to 60 million vehicle km were ‘saved’ by LST operations (end 2019)
• 739 million km were travelled by LSTs during the trial, estimated (2019) to be split: 85% trunk / 13% principal / 2% ,inor roads
• 430,000 to 485,000 journeys by 13.6 metre trailers were saved by using LSTs based on 125km average journey. Upper estimate (includes some return legs)
• 1 in 12 (8%) journeys were saved as an average across all operators with the highest saving operators achieving a saving of 1 in 8 (13%)
• savings of 48,000 tonnes of CO₂ and 241 tonnes of NOx 2012 to 2019 (rounded) were made
• on a per kilometre basis, nationally, we estimate LSTs have been involved in around 53% fewer personal injury collisions and casualties than the GB articulated HGV average

Annual reports on the progress of the trial have been published since 2013. The 2019 report is published alongside this consultation.

The Minister of State for Transport wrote in July 2019 to a selection of relevant stakeholders seeking informal views on the trial and how it should proceed. This asked specifically about what regulations could be suitable if LSTs were to be permitted outside of trial conditions, and what restrictions stakeholders believed would be acceptable to address the potential risks associated with wider use. The views received have informed the consideration of the future of the trial.

The department’s view, informed by emerging conclusions from the trial, is that sufficient data is available to answer the key questions that the trial was designed to answer. It is therefore right that we consider whether to conclude the trial prior to 2027, and (if a decision is taken to do so) how to treat LSTs beyond their current limited use.

This consultation sets out the government’s proposals for the future of the trial. However, it should be noted that, until a decision is taken and implemented, LSTs will continue to operate under the current trial regime.

Policy objectives

The objective of this policy is to facilitate more efficient and environmentally beneficial freight transport. It seeks to permit the transportation of an equal amount of freight in fewer journeys by allowing longer vehicles, which will achieve an emission saving as fewer pollutants will be emitted during the transportation of the same amount of goods. It is also anticipated that this will have a positive benefit on congestion as fewer trips will be required.

The lighter and heavier additional policy options propose regulations, on top of those which currently exist for the operation of standard trailers, be put in place with the aim of supporting the safe and productive operation of these vehicles.

Evaluation of the trial

Risk Solutions were commissioned by the department at the commencement of the trial to undertake collection, analysis and evaluation of results during the trial. Their work has been set out in the published annual reports.

The objective of the trial is to provide evidence to the department to support long term policy decisions on the benefits of HGV semi-trailers. The annual reports set out 7 main evaluation questions that are considered in detail. Questions are:

• question 1: What do operators use LSTs for?
• question 2: What are the savings realised in HGV journeys?
• question 3: What are the resulting reductions in emissions?
• question 4: What about safety - will LSTs cause more injuries?
• question 5: What about damage and the associated costs - will LSTs cause more damage on the roads?
• question 6: Might any special operational requirements be appropriate for LSTs?
• question 7: What proportion of the existing GB fleet of semi-trailers might be replaced by LSTs, were numbers not restricted?

The department considers that satisfactory answers to these questions have been established in the course of the evaluation including information in the 2018 and 2019 annual reports.

What do operators use LSTs for?

Data from operators has shown that LSTs are used for a wide range of activities, including transporting fast-moving consumer goods (FMCG), other retail goods, raw materials and supplies, waste materials and industrial products. This has been largely consistent throughout the trial.

What are the savings realised in HGV journeys?

The second question explores what savings could be made compared to a standard (13.6 metre trailer) HGV operation. In this context, savings refers to the additional distance that would have to be operated if the same quantity of goods was transported by 13.6 metre trailers.

The average saving achieved by operators is 8% (1 in 12 journeys) with the most efficient operations saving 13% (1 in 8 journeys). This has been broadly consistent over time.

What are the resulting reductions in emissions?

Evaluation has been undertaken of the resulting emission reductions due to savings made in HGV journeys. Since the start of the trial, it has been estimated that emissions of 48,000 tonnes of CO₂e and 241 tonnes of NOx have been avoided by the use of LSTs.

What about safety - will LSTs cause more injuries?

Establishing whether or not LSTs will have a negative safety impact is an important part of the evaluation. This relates to 2 issues: the reduction in incidents arising from making fewer journeys, and the rate of safety incidents per kilometre compared to standard semi-trailers.

The first measure is an intrinsic benefit and follows from the journeys removed by the operation of longer semi-trailers. In respect to the second measure, under trial conditions, the casualty record is lower per lorry kilometre travelled than the operation of standard articulated lorries. However, in the trial lorries and LSTs are likely to be operated in a non-typical way. An important part of deciding what to do next involves considering how some good practices can be continued and risk controlled.

What about damage and the associated costs - will LSTs cause more damage on the roads?

This question explores whether there would be additional damage caused by longer semi-trailers. Independent evaluators have undertaken a special study contrasting LST damage incidents with damage incidents from the same operators non-LST fleet. This has involved 91 operators. This evaluation has indicated that LSTs are causing no more damage than standard semi-trailers operating in the same company fleet.

Might any special operational requirements be appropriate for LSTs?

This question considers whether special operating requirements may be appropriate for LST operation outside of a trial setting.

Conclusive answers to this question are difficult to fully establish during any trial, due to the impact that trial monitoring itself may have on behaviour by operators. However, we have involved operators in conversations about the most common operational conditions they have adopted, based on their experience operating LSTs. These conversations, as well as our understanding of the impact of trial conditions, have fed into the special operating requirements set out in the preferred policy proposals set out below. This work appears in the 2019 annual report which is published alongside this consultation. It is unlikely that further trial data collection would provide additional insight, unless the trial conditions were to significantly alter.

What proportion of the existing GB fleet of semi-trailers might be replaced by LSTs, were numbers not restricted?

This question seeks to explore what proportion of the GB fleet of semi-trailers may be replaced by LSTs outside of a limited trial setting. Based on a 2016 to 2017 survey of operators, this has previously been estimated to be between 10 to 20%. However, this consultation seeks to garner a better understanding of potential operator decisions, were fleet decisions not affected by onerous trial conditions or quantity caps.

Beyond exploring this issue with operators via this consultation, no conclusive answer to this question can be gained under trial conditions that restrict LST numbers.

Feedback from stakeholders

In July 2019, the Minister of State for Transport wrote to a number of relevant stakeholders to establish their views on a post-trial regime, and to gather views on potential future usage. Although only a limited number of responses were received, these views informed this consultation.

The results were:

• the majority of respondents viewed the use of LSTs favourably and were keen to see the benefits of their use continue. This was not unanimous, with some concerns raised by some stakeholders in relation to road safety
• of those respondents who did view LSTs favourably and gave views on their continued or expanded use, the majority emphasised the importance of maintaining the benefits observed and modelled during the trial and supported this as a policy goal
• the vast majority of respondents supported some form of regulatory regime, with the most popular options involving driver training, which was widely supported
• route selection and management was an area of concern, in particular the potential for longer semi-trailers to use unsuitable roads with potential impact on road furniture and wear. Although there was support for measures to mitigate these concerns, it was noted that this may largely be an issue for local authorities who currently cannot enforce transport regulation orders (TROs) and that auditing routes may be an additional expense

The future of the LST trial: options for consideration

Main options for consideration

Given the findings of the research stated, the time is right to consider the future of the LST trial. There are several options to conclude the trial and which have formed the basis of the accompanying impact assessment. The options are:

• do nothing
• a light regulation approach
• a heavier regulation approach
• allowing LSTs to enter into general circulation

Do nothing

This option would see the trial continue as planned until the current end date, 31 January 2027. The cap of 2,800 vehicles would be maintained. Operators would continue to have to apply for an allocation of LSTs and be required to apply for a VSO covering each LST they wish to operate. Operators would also be required to continue to have to submit data returns every 4 months regarding each trailer’s status, journey data and incidents.

At the end of the trial, trailers would cease to be able to operate as the VSOs would expire and as it stands LSTs are not permitted under construction and use regulations. This may be before the end of a standard lifecycle for some trailers which have been purchased by operators at their own cost.

This option would not achieve the policy objectives but is included as a baseline against which the impacts of other options are estimated. If adopted the department would also consider formally closing the trial to new LSTs at that stage.

Lighter additional regulatory option

This is the department’s preferred policy option as it allows the whole of the freight industry to have unrestricted access to LSTs and therefore make an important contribution to reducing emission levels. The proposed additional regulation beyond that in place for standard 13.6 metre trailers, takes into consideration concerns raised regarding LSTs being operated on inappropriate roads and increasing the road safety risk, particularly to vulnerable road users as well as damage to street furniture.

This option would remove the cap on the total number of LSTs permitted and would allow the market to decide the quantity in operation based on commercial need. To ensure the excellent safety record of LSTs operated under the trial is at least maintained this option proposes that the regulatory measures of:

• accident reporting to the department where there is loss of life, injury (on public or private land) or damage (when on a public highway)
• operators being required to provide drivers with a minimum of half a day’s training in respect to the particular LST design before a driver operates an LST for the first time. This will need repeating or enhancing if a driver uses another LST design. If providing this training in house, operators will be required to have regard to an LST best practice training guide
• operators being required to undertake a risk assessment of the proposed route for the LST to ensure it is appropriate
• operators being required to retain a record of all risk assessments undertaken prior to LST journeys and make them available to the police, DVSA, OTC or traffic commissioner on request
• operators will be required to put in place a system to allow drivers to provide feedback on routes proposed and followed. A record of this feedback and response provided by the operator will be required to be kept on record for 5 years
• operators being required to undertake compliance checks to ensure LSTs are following the routes set and to take appropriate action where deviations are identified. A written record of compliance checks will be required to be kept for 5 years
• operators being required to apply to the traffic commissioner for permission to operate a permitted number of LSTs
• operators being required to ensure that there is a process for managing road closures (planned or emergency) to assist drivers

Heavier additional regulatory option

This option adds further specific regulations to the previous option. This option would require operators to run each LST at least 80% of each journey on the major roads. In order to achieve this, operators would be required to ensure appropriate route planning is undertaken before each journey. Operators would be required to undertake an appropriate level of compliance checks to ensure this requirement was being achieved.

To ensure compliance with the 80% requirement, operators will be required to be able to accurately track the route LSTs take by GPS and have a system in place to collect and store this data for five years. Operators will be required, should the police, DVSA, or the traffic commissioner request such data, to provide the data in the required format to identify whether the 80% requirement is being achieved.

In addition to the training requirements set out in the lighter additional regulations proposal drivers will be required to also undertake approved LST CPC training before their DCPC is required to next be renewed in order to retain entitled to operate LSTs.

Operators wishing to operate LSTs over 10 years of age would be required to apply to the traffic commissioner on an annual basis for approval to continue to operate the LST.

Allowing LSTs to enter into general circulation

This option proposes that LSTs should be allowed to operate under the same restrictions as standard trailers do, therefore placing no additional regulatory burden on operators. Operators would not be required to apply to the traffic commissioner for specific authority to operate LSTs. They would only be required to make an application to the traffic commissioner if they did not have sufficient capacity on their operator’s license and wished to increase the number of trailers operated on the license.

Under this option, drivers operating LSTs would still need to undertake appropriate training, but no minimum time would be put in place for how long such training should last, nor would they be required to have regard to a best practice training guide.

Main effects of lighter and heavier options table

	Light regulatory option	Heavy regulatory option
Number of LSTs permitted	Unlimited	Unlimited
Route planning and management	Undertake and record a risk assessment of the route. Undertake compliance monitoring to ensure LSTs are being operated on the routes set. Put in place a system where drivers are able to provide feedback	Undertake and record a risk assessment of the route. Undertake compliance monitoring to ensure LSTs are being operated on the routes set and the requirement to operate LSTs at least 80% of the time on major roads. Put in place a system where drivers are able to provide feedback
Data collection	Retain records of routes, risk assessments, compliance checks etc, for a period of 5 years and make these records available to police, DVSA, OTC or traffic commissioner if requested.	Retain records of routes, risk assessments, compliance checks etc, for a period of 5 years and make these records available to police, DVSA, OTC or traffic commissioner if requested. To ensure operators are complying with the requirement to operate LSTs 80% of each journey on major roads, operators will be required to be able to accurately track by GPS LSTs they operate and have a system in place to collect and retain this data for 5 years. Operators would be required, should the police, DVSA, or the traffic commissioner request such data, to provide the date in a required format to identify whether the 80% requirement is being achieved.
Incident reporting	Operators to continue reporting serious incidents that led to loss of life, injury or damage to the department.	Operators to continue reporting serious incidents that led to loss of life, injury or damage to the department.
LST-specific driver training	Specific driver training prior to operation of an LST required.	Specific driver training prior to operation of an LST required. Approved LST CPC course required to be undertaken before a driver’s DCPC is next required to be renewed.
Controls on road type usage	None	80% of each LST journey expected to be undertaken on major roads.
Operator licencing requirements	Specific authority for operators to be able to operate LSTs required from the traffic commissioner.	Specific authority for operators to be able to operate LSTs required from the traffic commissioner.
Construction and use requirements	Same as standard lorries	Same as standard lorries
Utilising existing LSTs	As in the trial or move to new regime	Authorisation required annually from the traffic commissioner in order to continue to operate an LST over 10 years of age

Specific issues to resolve

Number of LSTs permitted to be used

The department’s view is that it is now appropriate to consider whether to widen the permitted use of LSTs and increase or remove the quantity limit. Given the findings of the research as set out above, the time is right to consider the future of the LST trial. However, the use of LSTs would not be beneficial in all types of operation and given their higher purchase and maintenance cost, it is not expected that they would wholly supplant 13.6 metre trailers. The management of significant safety concerns raised by the trial is also another significant factor in considering whether to continue to control the numbers of LSTs in operation.

For these reasons we propose not to limit the number of LSTs outside of the current trial setting in any of the options that include ending the trial early.

Data required to be collected by operators

At present, operators must submit data every 4 months including, summary information for the journeys by each trailer, total mileage, and classification of goods type. However, individual trip reports are currently not required. The current arrangements are appropriate within a trial setting. However, if utilised after the current trial, would carry significant cost to industry and the department and would likely reduce take up of LSTs.

However, it has been noted that some of the benefits seen within a trial setting may be linked to the requirement for operators to collect data, giving them access to knowledge of fleet utilisation which may not have otherwise been available.

For these reasons, we are seeking views on 2 levels of post-trial data collection.

The lighter additional regulatory option proposes that operators be required to undertake a risk assessment of the route the LST will take to ensure the route proposed is appropriate for an LST to follow. A record of all risk assessments undertaken prior to journeys undertaken by LSTs, any feedback received from drivers either prior to or after a route has been followed and the response by the operator to such feedback will be required to be kept for 5 years and provided if requested to do so by the police, DVSA, or traffic commissioner.

The heavier additional regulatory option proposes that operators be required to fulfil the data requirements of the light regulatory burden option outlined above, and in addition run each LST at least 80% of each journey on the major roads and requires operators to be able to accurately record by GPS the route each LST takes for each journey, and retain that record for five years. Operators will be required, should the police, DVSA or the traffic commissioner request such data, to provide the data in a required format to identify whether the 80% requirement is being achieved.

LST-specific driver training requirements

Under the current trial the operator undertaking agreement requires operators to provide appropriate training to drivers before they drive LSTs. It is possible that one of the biggest impacts on the safety record of LSTs is the fact that specific training is required prior to operating an LST.

The proposal under both the lighter and heavier additional regulatory options is for a requirement for specific driver training prior to operation of an LST. In the lighter additional regulatory option, operators would be required to provide drivers with training before they are able to operate LSTs. There would be a requirement that this specific training lasts a minimum of half a day and that operators would follow a LST best practice training guidance document when considering what training they would l provide to their drivers.

Operators would also be expected, where a driver of an LST is involved in an incident, to consider whether both the driver involved in the incident and all other drivers entitled to operate LSTs should undertake further training or be provided with information about the incident to minimise the risk of the incident happening again.

In the heavier regulatory option drivers would in addition, be required by the point of DCPC renewal, to have undertaken an approved CPC LST course in order to retain the right to operate LSTs.

Incident reporting required by operators

Consideration has been given to the appropriate level of incident reporting, to avoid introducing disproportionate requirements which could reduce usage of LSTs unnecessarily. Given the significant public concern relating to the safety of longer heavier vehicles in general, the department considers it would be appropriate to maintain oversight of any continuing safety risk after introduction of LSTs more widely.

The department proposes that under both the lighter and heavier additional regulatory options that operators be required to continue reporting incidents that result in a loss of life or injury on public roads or private land. Operators will also be required to continue to report incidents which result in damage being caused where such incidents take place on a public road. This data will be held by the department and could form useful information relating to the risks posed by the operation of LSTs and allow for review of the safety measures in our proposals. Where concerns become evident these may then be acted on through existing enforcement mechanisms.

Controls on usage of specific road types

Consideration has been given to controlling the use of LSTs on certain roads, given that the additional length and manoeuvring requirements may make them unsuitable for some journeys. The current requirement to consider route planning may have impacted the proportion of individual journeys undertaken on major roads. Given the department’s objectives of ensuring the safe and efficient use of LSTs, our proposals seek to maintain this.

As part of both the light and heavy additional regulatory option it is proposed operators will be required to undertake a risk assessment of the route it is proposed the LST will take. A record of this risk assessment would be required to be retained for 5 years. Operators will be required to put in place a system to allow drivers to provide feedback on routes proposed/followed. A record of this feedback and response provided by the operator would be required to be kept on record for 5 years. Operators would be required to make such records available on request to the police, DVSA or traffic commissioner.

The heavier additional regulatory option would additionally include a requirement that 80% of all LST journeys be undertaken using major roads. In order to enforce this requirement, operators will be required to accurately track by GPS the routes LSTs take and have a system in place to collect and store this data for 5 years. Operators will be required, should the police, DVSA or traffic commissioner request such data, to provide the data in a required format to identify whether the 80% requirement is being achieved.

Specific operator licencing requirements for LST operators

We propose that the operation of LSTs would require specific authority from the traffic commissioner under the current operator licencing regime. This recognises the unique and specialist nature of these trailers and the different challenges with operating them. It would enable a record to be kept of all operators using LSTs.

Vehicle specification: LST specific construction and use requirements

Extensive technical requirements relating to LSTs to be utilised on the trial are available. In considering the future usage of LSTs, we have considered whether any technical requirements should be amended.

Kick-out and tail swing of the LST has been raised as an area of concern, and is recognised as a potential safety risk. There is insufficient evidence to show that one form of trailer or axle poses a greater risk than others and work by the department has not resulted in a clear recommendation about maximum kick-out. The department does not propose placing additional specific limits on kick-out but would require that the potential for kick-out or tail swing is covered extensively in driver training (see LST-specific driver training requirements) taking into account the specific LST designs in use by the company.

Technical requirements for LSTs may be altered for those introduced to the market, depending on responses to this consultation. However, the department would not propose immediate disposal of existing LSTs. If any trailers currently on the trial did not fit any new requirements the proposed presumption would be to allow the trial conditions to be retained for them until the expiry of current approvals.

Utilising existing LSTs: maximum trailer age

As part of the lighter additional regulatory option we the department does not propose putting any limit on the life of LSTs or any risk management plan when the LST reaches a certain age.

Under the heavier additional regulatory option, operators would be required to apply to the traffic commissioner on an annual basis for approval to continue to operate a LST once the trailer reaches 10 years old. This requirement would help ensure the expected efficiency benefits continue to be achieved, partly once LSTs have been sold on the second-hand market in order to ensure that they do not become the default in operation thereby replacing the operation of 13.6 metre trailers by a large portion of the industry.

Forecasts of future operation

LSTs in operation and kilometres saved

The use of the scaling model has allowed us to forecast the number of LSTs we would expect in operation based on the average kilometres saved per LST observed in the trial. These have been summarised in 5 yearly periods in the table below for each option.

LSTs in operation	2020	2025	2030	2035	2040
Lighter additional regulatory option	2,655	12, 541	16,557	17,488	18,471
Heavier additional regulatory option	2,655	10, 973	14,487	15,302	16,162
General circulation	2,655	9,580	12,648	13,359	14,110

The scaling model also allows for the calculation of the number of kilometres saved through the introduction of the policy, based on the approaches set out above. These are also summarised in the table below in 5 yearly periods under each option.

Vehicle kilometres saved (million kms)	2020	2025	2030	2035	2040
Lighter additional regulatory option	15.61	73.73	97.35	102.82	108.60
Heavier additional regulatory option	15.61	64.52	85.18	89.97	95.03
General circulation	15.61	56.32	74.36	78.54	82.96

Safety

Introducing longer semi-trailers onto roads in Great Britain would reduce the overall number of articulated HGVs on the road through a smaller total number of trucks on the road and fewer vehicle kilometres travelled. This can lower the likelihood of a road traffic accident involving a HGV and therefore a reduction in the number of casualties per year.

During the trial, this saving has been estimated and reported annually as being in direct proportion to the number of kilometres saved. Although LSTs are expected to reduce the number of vehicles and therefore kilometres travelled, this may free up drivers to use other vehicles and increase productivity for operators. Therefore, the safety considerations only look at the direct effects of LSTs replacing standard trailers with everything else held constant.

Various controls can be used to mitigate against the risk of an increased casualty rate. These are:

• operating standards – operator licensing requirements, qualifications, driver training
• controlled trial conditions – replicating route assessment conditions from the LST trial

An issue considered in the trail was that given the longer length of LSTs, there may be additional risks to pedestrians and cyclists where LSTs operate which may be more pronounced in urban areas. Over the course of the trial, operators have submitted accident reports to the department whenever an incident occurs which resulted in an injury or damage only incident. Summaries of these reports have been included in the annual reporting process, providing an indication of the severity, a description of the incident and those involved and determination if it was caused by the LST specifically.

Up to the end of 2019, there had been 40 reported incidents involving an LST reported to the department, 3 of which have involved either a cyclist or a pedestrian. These are described in further detail below:

• 2015 where an LST hit a pedestrian with the tail end of the trailer while making a turning manoeuvre in an urban location during a driver assessment (rather than a delivery). This resulted in a ‘slight’ injury and judged to be caused by the longer length of the vehicle. The route is no longer used for driver assessment
• 2016 where an LST hit a cyclist from behind when moving from slip road to dual carriageway. This resulted in a ‘serious’ injury which was judged to be not LST-related, in that the event would or could have still happened if the trailer had been a standard one
• 2019 which resulted in the death of a cyclist, where the cyclist fell off while an LST was overtaking. From engagement with the police, it is judged that this being an LST (as opposed to a standard trailer) was not to be the cause of this incident

Further to this, we commissioned the consultant Risk Solutions to consider the collision rates for LSTs when compared to the standard articulated HGV to determine the overall impact. Based on this analysis, the following collision rates were calculated:

		Casualty rates per billion vehicle kilometres
Articulated HGV (2012-2018)	11.27
LST (2012-2019)	4.02

From this, it can be inferred that the casualty rate with LSTs appears to be lower than the corresponding articulated HGV fleet average casualty rate, though this is based on a very small sample size. This will be examined in further detail during any post-implementation review.

Overall assessment of options

Summary

£million, 2019 prices, PV20 years	Lighter additional regulation: low	Lighter additional regulation: high	Lighter additional regulation: best estimate	Heavier additional regulation: low	Heavier additional regulation: high	Heavier additional regulation: best estimate	General circulation: low	General circulation: high	General circulation: best estimate
Business costs	404	269	337	523	349	436	199	133	166
Non-business costs	2	2	2	2	2	2	1	1	1
Business benefits	466	583	486	406	507	423	353	411	368
Non-business benefits	816	953	926	711	830	807	619	723	702
NPV	877	1,265	1,073	592	987	792	771	1,030	902
Business NPV	62	314	149	-118	158	-14	154	308	202

The preferred option is the lighter additional regulatory option. This option allows the whole of the freight industry to have unrestricted access to LSTs where operators identify that LSTs could be of benefit to their business and so ensure the industry makes an important contribution to reducing emission levels.

This would include reducing or even eliminating most of the regulation and monitoring of LSTs currently required under the trial on the basis that the environmental and economic case for operators using LSTs in certain circumstances has been proven. Maintaining such reporting requirements would only discourage operators when there are both business and societal benefits in operating LSTs.

This option is designed to support maintaining a good safety record for LST operation. The trial has shown that operators are individually able to identify and provide the training they feel their drivers require to understand the unique operating characteristics of LSTs, good route planning, risk assessment and compliance checking to ensure LSTs’ are operated at least as safely as standard articulated trailers. Given the success under the trial of the training that has been provided to drivers operating LSTs (shown by LSTs very favourable safety record), the option seeks to broadly replicate what has been done in the trial.

Questions for respondents

Respondent information

1/ Name

2/ Are you responding on behalf of a business or organisation?

3/ Have you or your company operated an LST under the trail?

Consultation Response

4/ Noting the evidence set out in in this consultation and in the annual trial reports, do you believe that the LST trial should be concluded prior to its planned end date of 2027 and replaced by more widespread operation?

5/ Do you prefer no operation of LSTs outside the trial, the lighter additional regulation option, heavier or general circulation?

6/ If LST use is to be permitted more widely, what is your view of the government proposals, in relation to:

• the number of LSTs to be permitted?
• data required to be collected by operators?
• incident reporting required by operators?
• controls on usage of specific road types?
• specific Operator Licencing requirements for LST operators?
• LST-specific Construction and Use requirements?

7/ If LST use is to be permitted more widely, how long would you expect to own an LST for?

8/ If a maximum age should be placed on the life of an LST what do you think that age should be?

9/ Should operators be required to apply to the Traffic Commissioner on an annual basis for approval to continue to operate an LST once the LST is over 10 years old?

10/ Compared to the trial, how much do you consider the lighter additional regulatory option will act as a barrier to you purchasing and operating LSTs?

11/ Compared to the trial, how much do you consider the heavier additional regulatory option will act as a barrier to you purchasing and operating LSTs?

12/ Under the option of no additional regulatory measures, to what extent do you agree or disagree with the below statements:

• I would seek to purchase more LSTs than I would have done under the other regulatory options
• I would now seek to operate LSTs where I would not have done under the other regulatory options
• I would operate LSTs as I can identify a current business need for them
• I have no current business need for operating LSTs but would like to own one to open up further business opportunities
• I would replace one or more of my 13.6m trailers with an LST variant instead

13/ Do you have any further comments/barriers to owning LSTs with no additional regulation? if so please provide them.

14/ Are there any other costs or benefits that we have not considered in the Impact Assessment that you think should be considered? Please could you provide detail for these using evidence where available

How to respond

The consultation closed on 1 February 2021.

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 department.

The department 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.

Data protection

Where personal data is being collected as part of the consultation - for example, names and contact details - you will need to include a privacy statement here.

Alternatively, if your consultation is closed (industry-only), request a template for this purpose from the Data Protection Team directly by emailing [email protected].

In each case, you must clear your draft statement with the Data Protection Team prior to publication using the mailbox details above.

What will happen next

A summary of responses, including the next steps, will be published within 3 months of the consultation closing.

If you have questions about his consultation contact Martin Placek at:

• 07977 436767
• [email protected]

Annex A: consultation principles

The consultation is being conducted in line with the government’s consultation principles.

If you have any comments about the consultation process contact:

Consultation Co-ordinator
Department for Transport
Zone 1/29
Great Minster House
London
SW1P 4DR

Email [email protected]

Footnotes

1. Longer semi-trailer trial annual report 2018 ↩