Tuesday, 4 December 2012

My Response to DfT Consultation on Increasing HGV Speed Limits

Response ID ANON-KMPX-Z9JK-8
Submitted on 2012-12-04 11:05:12.725334
1 What is your name?
Martin Porter
2 What is your email address?
3 What is your organisation?
4 Policy option 1: Raise the national speed limit for HGVs over 7.5t from 40 to 50 mph on single carriageway roads. Is this
your preferred policy option? Please explain your answer.
These roads already have a poor safety record in comparison with other types of road in the UK.
Single carriageway roads are often used by cyclists and the increase in speed in the heaviest vehicles will increase the actual and perceived hazard and danger
to them.
All the problems identified in the consultation papers ('platooning', fairness and competition) can all be dealt with better by lowering the speed limit for lighter
vehicles by 10mph and by better enforcement of limits.
England and Wales is criss-crossed by a fairly comprehensive network of motorway and dual carriageway roads. Heavy traffic will be diverted from motorways
and dual carriageways onto single carriageway shortcuts if there is no longer a significant speed differential.
Above all, lowering speed limits will save lives and this is a step in completely the wrong direction.
5 Policy option 2: Raise the national speed limit for HGVs over 7.5t from 40 to 45 mph on single carriageway roads. Is this
your preferred policy option? Please explain your answer.
For precisely the same reasons given above,
6 Do you consider there to be any additional policy options, or variants of policy options 1 and 2? If so, please explain
fully and provide any evidence you may have.For example, only increasing the speed limit for HGVs over 7.5t on single
carriageways where the national speed limit applies, and retaining the 40 mph limit at other times
Keep the current speed limits for heaviest HGVs and lower the speed limit of HGVs up to 7.5 tonnes to 40 mph and lower the speed limit for light motor vehicles
to 50 mph on single carriageway roads.
7 In your opinion does the current 40 mph speed limit cause any of the following: unnecessary costs to vehicle
operators; congestion; avoidable overtaking collisions; an uneven playing field for businesses; or anything not
mentioned in this list? Please explain your answer and provide any evidence you may have.
No. This is a leading question. The blame for these supposed problems cannot sensibly be laid at the door of the 40mph speed limit. Better enforcement of the
limit would level the playing field as would the lowering of speed limits for lighter vehicles.
8 We welcome views from HGV operators and trade associations about whether they feel the balance of savings and
costs of extra speed detailed in the Impact Assessment reflects their own experience or expectations?
9 If the speed limit for HGVs over 7.5t is not raised on these roads, collisions as a result of ‘platooning’ could continue. If
it is, the frequency of collisions could decrease due to a reduction in ‘platooning’, though on the other hand the severity
of collisions could increase.
The 'platooning' problem is best dealt with by lowering the speed limit of the other vehicles.
10 Do you have any opinion or evidence on the effect of ‘platooning’ on road safety, or on the frequency or severity of
collisions involving HGVs on single carriageway roads and what effect an increase in their maximum speed limit on these
roads would have on safety? If so, please provide it in response here.
An increase in maximum speed limit will obviously have a detrimental effect on road safety. It is amply demonstrated that speed kills. It is beyond any sensible
dispute that equalising speed downward (and not up) would save lives and injuries.
11 Do you have any opinion or evidence on what effect an increase in the maximum speed limit for HGVs over 7.5t on
these roads would have on non- HGV vehicle speeds such as car speeds?
It is likely to increase car speeds which will itself have a detrimental effect on road safety.
12 The Department invites information on where there are single carriageway roads which are subject to the national
speed limit, or are signed at 50 mph, in areas where there are air quality problems.
13 What impacts, if any, do you think there will be to the following if an increased speed limit for HGVs over 7.5t on single
carriageway roads is introduced? a) Air Quality Management Areas (AQMAs). Local authorities may have specific
evidence on the effect on AQMAs in their authority; b) EU air quality standards [1] ; c) Noise levels; d) Areas currently
identified as noise hotspots [2]
14 If as a result of either of the policy options being implemented there was a reduction in ‘platooning’ do you think there
would be a significant impact on: a) Noiseb) Air quality
'Platooning' has a calming effect in slowing general traffic and therefore reduces the adverse impacts on noise and air pollution.
15 Do you think either of the policy options goes against the underlying principles of the EU Environmental Noise
Directive [3] or of the Noise Policy Statement for England?[4]
Yes, both do.
16 Do you think that all of the potential health and social costs of the policy options have been considered in the Impact
Assessment? Please provide details if you think costs have not been included.
It is government policy to encourage cycling. These are roads that are frequently used by cyclists. Overtaking of cyclists by heavy vehicles on single carriageway
roads is potentially hazardous and requires a great deal of care on the part of the HGV driver. The HGV driver travelling at 40 mph has a much greater
opportunity to see a cyclist ahead and to plan his overtaking manoeuvre.
It is a serious omission that the encouragement of cycling has not been considered in the Impact Assessment.
17 Do you believe an increase in speed for this class of vehicle on these roads will cause more HGVs over 7.5t to use
single carriageway roads, which do not currently?
Yes, clearly.
HGV operators are likely to calculate and use the quickest route. Currently it is worth a modest detour to use motorways and dual carriageways, which are far
more suitable for HGVs, because they are then able to travel significantly faster. If the speed limit differential is reduced more HGVs will be attracted away from
motorways/dual carriageways and onto single carriageway routes.
18 Do you think some freight may switch from rail or water to HGVs, if the speed limit is increased on these roads for
these vehicles?
Yes for the same reasons. Any reduction in the time taken to transport by road will increase its attractiveness relative to other modes of transport.
19 Do you think that there may be added wear and tear on these roads if the speed limit is increased for these vehicles?
Local authorities may have specific comments or evidence, with regard to roads in their authority.
Yes, obviously. An HGV braking hard from 50 mph will put far more stress on the road surface than it would braking from 40 mph.
20 Local authorities have powers to alter speed limits on the local road network, including non-trunk primary routes, in
line with guidance set out in Setting Local Speed Limits, DfT Circular 1/06.[5] Do you think that the increase in the national
speed limit for HGVs over 7.5t on single carriageways, would make it more likely that local authorities would introduce
more local speed restrictions, and if so on which roads?
It would mean that they should introduce more local speed restrictions but in practice they may well not get around to doing so until many avoidable collisions
have occurred.
21 If you are an organisation that provides information and you believe that an increased speed for this class of vehicle
on single carriageways would incur costs for your organisation in the form of publicity or conversion costs please
indicate what these may be. Also please advise whether these costs would be reduced given a lead-in time between
announcement and policy implementation as a result of costs being rolled into existing plans.


  1. Well done! That looks tremendously well reasoned and evidence based. Do you mind if I largely copy you, and if I circulate this round my local cycling group to do the same?

  2. Please do, but it may be more effective if you personalise your responses so far as you are able.

  3. One thing that DfT miss is that a car overtaking a lorry travelling at 40mph has much more time, and takes far fewer risks, than a car overtaking a lorry travelling at 50mph.

    I would expect these faster HGV speeds to both increase "platooning" because the lorries are more difficult to overtake, and also increase the number of fatal head-on collisions caused by cars failing to overtake the faster-moving lorries.

    The whole idea is a disaster, and contrary to any sane thinking about road transport and road safety.

  4. AGREE with Fonant the " Dft " are not thinking about Road safety and are ONLY thinking of those who encouraged this Survey .

    Today they announce GBP1billion to be invested in Cycling just as they prepare to raid Tax payers pockets in the Autumn Budget . 2% spend on Cycling when they want to increase Cyclists from 7%(?) to above 20%+ sounds like they are trying to do things on the cheap at the risk of Cyclists lives and health !

  5. Well done. That's pretty much what I said. The interesting thing about Q5 is that they obviously don't think it is worth asking any cycling/ pedestrian/ road safety groups what they think - their opinions obviously don't count.

  6. Well done. Reminds me to submit my response - thank you.

    As a general comment, I'd avoid 'see reasons above'-type responses to questions, even if it means duplicating a response. You never know how responses will be processed.

    It's possible that responses will be broken up and each question's answers compiled in isolation. If 'ditto' is the response, it might mean that a particular question receives under-represented consideration, which would weaken the case.

    Better to copy-paste comments forwards where appropriate (they won't be marking it for style!).

  7. You have the patience of a saint! Such obvious, blundering questions, and you didn't answer with "WELL DUH!!!" once. Chapeau!

    I'd have been swearing at question two!