Command And Control

The London Cycling Campaign is running it's "end lorry danger" campaign which has three threads. Two I think are excellent and one, I think, is flawed.

As a member of LCC and a firm supporter of the #Space4Cycling campaign, I am definitely not here to bash them, but to perhaps encourage some wider thought and discussion. I do need to say that we are discussing an area where people are being killed and injured and so I understand the emotion, I just need to keep a little distance in what I write. So, the two threads of the campaign that I am happy with are;

Direct vision lorries - this essentially retrofitting, or prescribing through regulation, arrangements whereby lorry drivers can see what is going on next to them - think bus passenger doors, rather than normal lorry doors. This complements LCC's other idea for lorries cabs lower to the ground so the drivers have much better vision.

Stronger enforcement - this calls for a crack down on rogue operators, unlicenced and untrained drivers. Apart from dealing with these people, it means that responsible and professional operators aren't undercut by the cowboys. So far so good.

The other thread is a call for lorries over 7.5 tonnes to be banned between 8am and 9.30am on the basis that 40% of cycling fatalities occur during the morning peak and this would prevent the majority of people who cycle to work from sharing space with lorries (I assume a weekday ban).

The entirely selfish angle to my objection to the idea is that I am usually sitting at my desk by 8am, or at least making the tea. This idea would increase the risk to me on my cycle commute within which I do have to share the road with lorries. 

As it happens, in my corner of Outer-London, I have to mix with far more buses on my commute than I do lorries over 7.5 tonnes (and bus drivers are not always saints, even with direct vision to the nearside) and even more vans which are often driven poorly. Part of my commute is on a cycle track which isn't fantastic, but unless lorry drivers are going to all of a sudden bounce up and drive along it, means that I feel and am pretty safe. A lorry ban would make no difference to me on the cycle track (other than losing some fumes, but the cars pump out the most.

Mixing with lorries is no fun, but nor is mixing with
rush hour traffic generally

My commute is a snapshot and pure anecdote, but where the danger has been removed from "my" world (i.e., I have a cycle track), then I am safe. When I set off from home, the first 100 metres or so before I get to the track is on a pretty quiet street where lorries tend to be a refuse truck once a week and the odd delivery truck. 

My street has a 7.5 tonne weight limit (although there is little point for lorries to use it) and so this part of my journey is safe. I put up with the section which is on-road. While it doesn't feel "dangerous", the majority of other people I see cycling are on the footway which probably feels dangerous to those walking. My point is that the infrastructure is key.

An old "exempt vehicle" plate from the LLCS, which
was called LBTS at one point. From my shed!

The other issue I have with the idea is one of practicality and here is a bit of a history lesson. London has had its "Lorry Control Scheme" (LLCS) which the Greater London Council brought into force in 1985 using "The Greater London (Restriction of Goods Vehicles) Traffic Order 1985" which has been amended over the years and now managed by London Councils, it is a real geeky piece of London traffic history. Of course, it is controversial as it restricts lorry movements on most London roads at night and the weekends with the Freight Transport Association being particularly upset. Actually, it has been controversial for years, here is a report in the Guardian from 1994 from the dark years of fragmentation of transport in London. For everyone else, the scheme offers some respite to the noise of heavy traffic at night.

The LLCS is in force across the whole of London, including The City and parts of the TfL network, although only 29 boroughs are in the scheme - the LLCS website says "29 of the boroughs allow London Councils to enforce on their roads". Don't be fooled, this is a euphemism for the 3 boroughs who have withdrawn from the scheme to save paying annual fees to London Councils. The Order remains in force in these boroughs, it is just not enforced.

This trunk road is on the ERN. There is a cycle track
to the left, although some cycle on the road because it
is doesn't give way to side roads, there are no
pedestrians in the way and the surface is better.
Are the lorries the threat here or the traffic generally?

The LLCS bans vehicles of 18 tonnes and over from most streets in London overnight between 9pm and 7am during the week, with Saturday between 7am and 1pm unrestricted and Sunday restricted all day. Permit holders are excluded (for those who have a proper reason for travel at those times and have written prior permission which is essentially the permit). Those caught in the restricted times are fined, although there is only a small team of enforcement officers.

There is what is known as the Excluded Route Network (ERN) which comprises of major routes such as the big London Trunk roads (A12, A13, A1, A4 etc, but not into the core area) plus the North and South Circulars. In other words, freight can move through London (although not the centre) and can at least be on the road before the restricted time ends.

The sign on the left is the LLCS sign,
these are all over London just off the ERN.
The sign on the right is a local 7.5 tonne
weight limit.

So perhaps the proposed ban could be tacked onto the LLCS? Perhaps, the ERN comprises of roads which most people wouldn't dream of using anyway and so the ERN could apply as it does now. The LLCS has a hell of a lot of traffic signs - every side road off the ERN has them and they are huge and complicated now, plus many side roads have local 7.5 tonne weight limits now, so how is this going to work exactly? Perhaps a new sign is needed?

We also need to remember that 3 boroughs have jumped ship already because of costs and as the cuts continue to bite, how many more will also jump? How many are needed to keep the scheme viable? I suppose TfL could take over from London Council's, but this will probably need another piece of legislation to make the transfer.

The other problem is that the LLCS does have the ERN and so if the campaign is that all lorries over 7.5 tonne are banned between 8am and 9.30am, then the ERN still lets them in and so I doubt piggy backing on it will prove to be practical.

From the 1st September, TfL will be commencing its "Safer Lorry Scheme". This essentially creates a zone around London which requires all vehicles over 3.5 tonnes to be fitted with basic safety equipment such as better mirrors and side guards which reduce the risk of cyclists being dragged under wheels. Failure to comply will lead to fines. Have a look at the Traffic Management Order, it is rather complicated!

Current UK rules have many vehicles exempt from the rules and so London is effectively creating a higher requirement for the capital. The scheme has similar to the London Low Emission Zone (LEZ) which required better standards of vehicle emissions than the UK at large. Again, failure to comply leads to fines.

The Safer Lorry Scheme essentially covers the same area as the LEZ and it will come as no surprise that the signs for the new scheme are being mounted with those for the LEZ. This involves far fewer signs than the LLCS, although quite a few do coincide with LLCS signs - there are going to be some big signs soon!. There are little gaps in the scheme around the edges of London which give those driving non-compliant vehicles to "escape" back into the Home Counties.

The morning ban could, in theory, piggyback on the Safer Lorry Scheme, although the mind boggles at the signage. A 7.5 tonne weight limit can vary by time of day and day of week and could be the sign on the left, although I think the sign on the right may be more in keeping with the idea.

The Safer Lorry Scheme is a joint effort by TfL, London Councils and Heathrow Airport (yes more historic London traffic reasons there) and it is enforced by the Metropolitan Police, City of London Police and the Driver and Vehicle Standards Agency, so no worries for the boroughs about paying annual fees. In theory, if all agree, the Safer Lorry Scheme could include the morning peak ban and the legislative approach has been tested with the 3.5 tonne scheme.

A reminder of what a 7.5 tonne lorry looks like.

So, it brings me back to the practicality question. My industry is responsible for running a lot of lorries. Sadly, they are over-represented in collisions which kill pedestrians and cyclists (actually more pedestrians that cyclists). They are engaged all over London on construction sites doing all sorts of jobs and driving a lorry is hard work. The usual 8-wheeler lorry which is shifting muck or bringing in materials is rated at 32 tonnes. Many utilities run grab lorries which are pretty similar too - like any city, London needs its utilities to run. Of course, there is also all of the lorries of all different sizes delivering to shops, there are the firms who deliver TVs and sofas - the first drop is easily at 8am.

It is also worth touching on the planning system. It is pretty routine to impose conditions on developments to control the hours of work on site for the amenity of neighbours. A condition could read like this;

All building operations in connection with the construction of external walls, roof, and foundations; site excavation or other external site works; works involving the use of plant or machinery; the erection of scaffolding; the delivery of materials; the removal of materials and spoil from the site, and the playing of amplified music shall only take place between the hours of 8.00am and 6.00pm Monday to Friday, and between 8.00am and 1.00pm on Saturdays and not at all on Sundays and Bank Holidays/Public Holidays

The implication could be that lorries need to get to site before 8am (when the proposed ban would start), but after 7am when the LLCS overnight ban ends - a one hour slot to get lorries into site, concentrating movements. Alternatively, deliveries have to wait until after 9.30am, again creating a peak. These times are pretty common in this type of condition and don't forget, the highway restrictions trump planning conditions.

There will have to be exemptions for local authority vehicles and utilities who often need to react to emergencies or repairs to maintain services. Perhaps the Royal Mail would need an exemption for its lorries and of course, what about other mail companies? You can see the requests for exemptions!

Let's look at a supermarket as again, planning conditions often control deliver times;

No deliveries or servicing shall take place other than between the hours of 07:00 and 22:00 on Monday to Saturday and 08:00 and 22:00 on Sundays and Public Holidays without the prior consent in writing of the Local Planning Authority. 

Again, the same issues as for construction.

This proposed ban will do several things in my view;

• Potentially create busier HGV periods before and after the ban which can potentially create additional risk to those walking and cycling outside of the banned period,
• Put more pressure on lorry drivers trying to "beat the ban",
• Lead to "stacking" of lorries outside of the ban boundary,
• Create the potential (or at least pressure) for legislation to annul or amend (in a blanket way) local planning restrictions on construction and retail deliveries, so that life can continue outside of the lorry ban period,
• Take focus away from safer lorry design,
• Take focus away from changing our streets.

So, what would I do in reaction to the issue of people walking and cycling being killed by lorries, especially construction vehicles? Well, the Safer Lorry Scheme seems ripe for development and manipulation. In the same way the LEZ can be tightened with time. we could add all sorts of requirements in a planned and timetabled way to allow operators to catch up;

• Physical changes to vehicles such as cameras, sensors, mirrors etc,
• Leading from this, setting dates for the requirement of direction vision cabs for lorries operating in London,
• Softer measures such as requiring registration of operators wishing to enter into London with registration forming the basis of regulation by training and inspection of operator procedures to a standard (FORS for example),

There are other things which could be done which are carrot rather than stick, such as working with businesses to create consolidation hubs to reduce the number of lorries delivering in the first place such as the Regent Street scheme which ran before the 2012 Olympics. We could have the boroughs collaborating to set up core, preferred lorry routes, so that where possible, certain routes have to be followed. Roads investment could then be aimed at these corridors to redesign the roads and junctions to make them safe for walking and cycling.

For me, the key principle has to be stopping the need for people and heavy machinery mixing and as I have explained, even with the peak time ban, there is still plenty of heavy machinery operating - being hit by a 3.5 tonne van and a 40 tonne lorry is not going to end well in either case. I understand the sentiment behind the campaign and I understand the urgency, but I think it is a red herring and one which could create safety risks for people travelling outside of 8am to 9.30am.