Friday, 24 July 2015

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.


  1. Stop with this sensible, reasoned thinking! That's just not how we do things here in London!

    But seriously, nice article. One thing that struck me was that in the majority of your photographs of the streetscape there is soooo much room on the margins for proper, Dutch quality segregated infrastructure. Even accounting for the trees, safe routes could be created when those areas are refreshed. What is stopping this kind of infrastructure making in it onto the ground in areas like this, were room is plentiful and benefits clear (i.e. that the roads are, and will continue to be, very busy and entirely unsuited to bicycles [and humans, for that matter])?

    Keep up the good work!

    1. Yes, the places in the photos could pretty easily (in technical terms) be transformed. The trunk road has a cycle track, but it is shared, a bit bumpy and narrow in places - it could be awesome. The urban road could similarly be transformed, although there are a couple of junctions which would have to take motor traffic capacity down in favour of those walking and cycling. We are held up because this is Outer-London and politicians don't have cycling on their radar, other than something done by a small group of enthusiasts.

  2. disclaimer: I'm not London based so this really has bugger all to do with me other than being a possible blueprint for other UK cities.

    I agree with Ranty about a ban being difficult to enforce, especially with limited resource. From previous tragedies, it is clear there are already rogue operators and drivers flouting existing laws. so this is something else they'll ignore.

    Very disappointed that LCC are proposing a ban (the other features are welcome) when they should be shouting for protected infra which would keep people safe 24/7.

    Why can't those temporary concrete roadworks barriers be used to create safe left turning space for cyclists on multi lane junctions? Yes it would reduce vehicle capacity, but look at the toll on lives of that capacity now.

    1. LCC do largely have good campaigns, but this lorry ban one is duff in my view and wastes energy. If they wanted quick change then push for experimental junction changes as you suggest, much more worthwhile.

    2. Up to a point, Lord Copper. LCC do occasionally have good campaigns, in spite of Charlie Lloyd being head of campaigning. But, when left to the `charity' hoppers, it should come as no surprise that the good examples invariably end up buried under passive obstructionism whilst all the effort goes into the more typical nonsense.

      p.s. Is there any chance of your using a passably heavy typeface (ideally Transport Heavy) for these dark-text-on-light-background sign mock-ups in future? Preferably with 1.5sw borders and inner radiuses separated by 2.5sw from the content? Bonus points available for getting the `am'/ `pm' spacing right, although that might be a case of trying to run before getting the hang of walking... Traffic Signs Manual ch.7 s.2! Perhaps even rate the mass of HGVs consistently in tonnes and never Teslas, too? I have to confess that when I look at the header of your 'blog, I often end up thinking `I wouldn't employ him as a highway engineer' :-S.

    3. LCC has a democratically elected set up and I suppose the way to change it if you don't like it is to join and get elected to a position of power.

      The text in the sign mock ups is the "transport" font, but as I am knocking them up in MS Paint rather than Signplot, you'll have to forgive me on the quality and the odd mistake.

    4. What would be the point of attempting to reform an organisation which can only claim to represent a small minority of cyclists in London, has virtually no influence over TPTB and a reputation for being owned & operated, as a useful idiot, by London Councils PLC? In any case, the hoppers are `charity' employees or council secondees and not elected. As it happens, I am probably not eligible to join as I do not live strictly within the parochial boundaries---although I cycle through London very often! If representative `democracy' really was an answer to anything, it would make more sense to infiltrate the national parliament and agitate for a better transport minister. Eric Pickles, anyone ;-)?

      Does your Transport font have a `bold' weight/ alternative width space characters (e.g. U+2000--U+200A)? MS Paint can probably give the borders a more authentic width and separation, but possibly not radius the corners. A manual way to do that would be a 6sw foreground circle over-painted with a 3sw background circle on common centres and chopped horizontally and vertically through same.

  3. I suspect politically a ban seems quick, simple and cheap - I wasn't aware of the complexities before reading this and I've read lots about the idea in the past.

    Infrastructure changes take time in this country - you wouldn't believe the battle over a 6 month *trial* road closure in Lambeth with cyclists surprisingly well represented in the anti's.

    1. Yes, things do move frustratingly so, but it is often that people have a right to object and so we have to follow certain processes. I guess that's democracy!

  4. The two most recent pieces on www/rdrf/ are about this subject, the latest addressing some of the issues above.

    I have always been sceptical about the morning rush hour ban because (a) it muckshifts and (b) it avoids other issues which are more pressing.

    But I can (with qualifications) go along wit the LCC because (a)It could be modified to exempt non-compliant HGVs (with retro-fitted devices and side guards or else new direct vision cab HGVs) and (b) they already have commitments towards infra-structural change plus HGV design + enforcement.

    So I wouldn't worry that much about it.

    Plus non-construction HGVs (about half the HGV problem at the moment are construction vehicles) don't tend to travel so much in a.m. rush hour, so wouldn't have that much of a problem.

    And we need to have the Safer Lorries Scheme extended to, er, safer lorries still. The signing etc. just has to be sorted out to fit in with this.

    I hope I cover this in

    R. Davis, Chair RDRF

  5. If (in London) a lot of the HGV problem is from construction, is there potential for a carrot and stick Planning approach? Heavy restrictions on HGV access to your development OR as part of the development you pay for segregated cycle facilities for your side of the "block", or similar?
    OK, it doesn't deal with the effects of the HGV traffic on other parts of the network, but with enough construction projects the cycle infrastructure would seem to head the right way quite quickly.

  6. RE-last poster: There is loads that can be done, mainly through only allowing vehicles on site that don't have massive gaps between vehicle body an tarmac, then various kinds of vision/recognition enhancement or on new HGVs, as well as training. Re-local environment, that should come up with local Council when planning permission is sought. The Highway Authority will be (should be) thinking of impacts re-traffic generation, and this should extend to dangers during construction.

    Also S.106 monies can be given to support cycling locally as well

    R. Davis

    1. Robert, thanks for your insight as ever. Yes, I agree that there is much more to be made by the planning system and this is something that the GLA planning team could lead on in helping to set up model planning conditions for example (in London!).

      On the S106 front, it seems to be on the wane as the government keeps on changing the rules, but we can build in planning conditions to have routeing agreements and so on.

  7. How much of an issue is it that construction vehicle operators are paid by the load/journey? Might outlawing that practice help improve driving practice?

    1. I'm not sure how widespread this is. I suggested as much to a local traffic copper in relation to an HGV issue (can't remember what it was now) and he asked if I had any evidence as people not meant to be paid by the load. Of course, companies will be putting pressure on to maximise turn round.

  8. The Dutch, as ever smart they are, determined that it would be safest for three categories of goods vehicles to exist, vans up to 3500 kg, light trucks up to 7500 kg, or LGVs, and HGVs over 7500 kg. Vans can go on access roads, IE the 30 km/h zones in the built up areas and the 60 km/h zones in the rural area. LGVs can do on distributor roads. And HGVs can only go on the motorways and trunk roads. The infrastructure helps keep them safe after that. Pedestrians and cyclists don't go anywhere near motorways or trunk roads, nor do they cross them at grade. On distributor roads, the relatively low speed and the physical separation with cycle tracks and protected junctions and roundabouts prevents a hook conflict and crashes at speeds which are dangerous. On access roads, the speed is low enough that A a van can stop much faster, and even if they don't completely stop, they are much slower, and even if they do hit at 30, it's still slow enough to be tolerable, especially with new developments in vulnerable road user protection. Vans are also much smaller and have better sightlines and no underride areas where people are likely to get fatally trapped, and they weigh much less, they create less than a quarter the energy of a 7500 kg truck at the same speed, even assuming a maximum load of 3500 kg.

    It even keeps car users safer, because their masses don't bode well with large vehicles either. A truck with a mass of 12500 kg has 100 times the energy of a 1250 kg car traveling at the same speed, so it's crucial to keep these apart as much as possible. HGVs are relatively good on motorways but even then they still aren't ideal. The angles of conflict, the new steering control systems in cars, better crash barriers and new built in vehicular protection systems like underride bars that protect at motorway speeds. By limiting the trucks to a safe speed, in much of the continental EU, the Netherlands and Germany included, this is 80 km/h on motorways, in some countries it's 90, so the truck will pack somewhat less of a punch.

    Buses are identified in Sustainable Safety too, and are pointed out for their large mass differences. When possible, they build separate bus lanes and bus only roads and physically separated lanes so as to keep the mass differences as apart as possible, as they also have a mass of about 12 metric tonnes, about 10 times that of a car, with 100 times the energy. Even amber lights can be tailor made for buses this way, so that they have more time to stop when needed.