The London Lorry Ban - FTA

23
The London Lorry Ban Exempt Route Network Study Introduction The London Lorry Control Scheme (LLCS) or London Lorry Ban (LLB) as it is known, has been in existence since 1986. Set up to protect Londoners against the disturbance caused by heavy lorries at night and at weekends, its objective is to reduce noise nuisance at antisocial times by eliminating through traffic and minimising the environmental effects of heavy lorries. It is enforced and administered by the Association of London Government (ALG). Lorries are banned during, what were considered at the time, the most environmentally sensitive times, from 9pm-7am Monday-Saturday and from 1pm Saturday to 7am Monday. The LLB applies to the whole of the Greater London area. However, there is an Exempt Route Network (ERN) which is outside of the ban, consisting of the North and South Circular Roads and major radials leading to the above and some continuing further towards Central London. The lorry weight limit for the LLB is set at over 18 tonnes. Exemptions are provided for lorries with essential business in London during the controlled hours. However, Condition 5 of the Traffic Order requires operators to maximise their use of the ERN during the hours of the ban and minimise the use of the restricted routes. This requirement can add 20 or 30 miles to individual journeys. Several issues of the LLB need to be addressed. The developments in transport technology, especially with respect to noise and emission levels since the outset of the LLB in 1986. The redefining of the ERN in the light of the introduction of the London Congestion Charging Scheme and the possible introduction of Low Emission Zones. Transport operators work on relatively small profit margins. Condition 5 can significantly increase costs when a lorry is forced to travel an extra 20 or 30 miles to avoid the restricted network. Yet the vast majority of journeys are essential to the commercial well being of the capital. Methodology The required information was gathered by visiting FTA member companies to discuss, with transport staff, the routes that were causing the greatest problems – a subjective exercise which reflected the views of the individual companies. The intention was to genuinely assess the extra costs and emissions which ensue from a company’s compliance with the LLB and to seek views on how it could be made more flexible, not to universally criticise. A questionnaire gathered: the size and age of the company fleet; which delivery routes and locations gave particular problems and why?; does using the ERN increase mileage and travelling time?; are problems made worse by using agency and inexperienced drivers?; if the ERN was extended which routes would most benefit the company?; would the company use an extended ERN as a London through route to the M25?; should adopting best practice, such as using lower emission vehicles, result in the company being able to use a wider network of roads?; ideas for improvements that could be made to the LLB given that it will continue?; additional information relevant to the company. A map was taken on each site visit and ‘problem routes’ marked. More direct routes were also marked to give an indication of how many extra miles the LLB routes were causing drivers to undertake. From the questionnaires and maps completed the company costs were calculated in terms of expendi- ture incurred and the excess CO2 emissions given off due to the extra mileage driven. To ensure accuracy and consistency the financial costs were calculated using FTA Manager’s Guide to Distribution Costs. An aggregated cost table provides an overall cost for all the companies involved in the study. £30,000,000- THE COST OF LONDON LORRY BAN DIVERSIONS This study details 31 vehicles on 31 routes, travelling once a day Monday-Friday. The annual extra costs of the LLB to the companies operating these vehicles is over £190,000. Given that many companies operate large fleets of vehicles and 55,000 permits are given out annually, even at a conservative estimate, the cost to industry is £30 million. There is also a cost to residents from emissions given out by vehicles having to endure long diversions through the outer London boroughs.

Transcript of The London Lorry Ban - FTA

Page 1: The London Lorry Ban - FTA

The London Lorry Ban

Exempt Route Network Study

Introduction

The London Lorry Control Scheme (LLCS) or London

Lorry Ban (LLB) as it is known, has been in existence

since 1986. Set up to protect Londoners against the

disturbance caused by heavy lorries at night and at

weekends, its objective is to reduce noise nuisance at

antisocial times by eliminating through traffic and

minimising the environmental effects of heavy lorries.

It is enforced and administered by the Association of

London Government (ALG).

Lorries are banned during, what were considered at

the time, the most environmentally sensitive times,

from 9pm-7am Monday-Saturday and from 1pm

Saturday to 7am Monday. The LLB applies to the

whole of the Greater London area. However, there is

an Exempt Route Network (ERN) which is outside of

the ban, consisting of the North and South Circular

Roads and major radials leading to the above and

some continuing further towards Central London. The

lorry weight limit for the LLB is set at over 18 tonnes.

Exemptions are provided for lorries with essential

business in London during the controlled hours.

H o w e v e r, Condition 5 of the Traffic Order requires

operators to maximise their use of the ERN during

the hours of the ban and minimise the use of the

restricted routes. This requirement can add 20 or 30

miles to individual journeys.

Several issues of the LLB need to be addressed.

• The developments in transport technology,especially with respect to noise and emissionlevels since the outset of the LLB in 1986.

• The redefining of the ERN in the light of theintroduction of the London Congestion ChargingScheme and the possible introduction of LowEmission Zones.

• Transport operators work on relatively small profitmargins. Condition 5 can significantly increasecosts when a lorry is forced to travel an extra 20or 30 miles to avoid the restricted network. Ye tthe vast majority of journeys are essential to thecommercial well being of the capital.

Methodology

The required information was gathered by visiting

FTA member companies to discuss, with transport

s t a f f, the routes that were causing the greatest

problems – a subjective exercise which reflected the

views of the individual companies. The intention was

to genuinely assess the extra costs and emissions

which ensue from a company’s compliance with the

LLB and to seek views on how it could be made more

flexible, not to universally criticise.

A questionnaire gathered:

• the size and age of the company fleet;

• which delivery routes and locations gave particularproblems and why?;

• does using the ERN increase mileage and travellingtime?;

• are problems made worse by using agency andinexperienced drivers?;

• if the ERN was extended which routes wouldmost benefit the company?;

• would the company use an extended ERN as aLondon through route to the M25?;

• should adopting best practice, such as usinglower emission vehicles, result in the companybeing able to use a wider network of roads?;

• ideas for improvements that could be made tothe LLB given that it will continue?;

• additional information relevant to the company.

A map was taken on each site visit and ‘problem

routes’ marked. More direct routes were also marked

to give an indication of how many extra miles the LLB

routes were causing drivers to undertake.

From the questionnaires and maps completed the

company costs were calculated in terms of expendi-

ture incurred and the excess CO2 emissions given off

due to the extra mileage driven. To ensure accuracy

and consistency the financial costs were calculated

using FTA Manager’s Guide to Distribution Costs. An

aggregated cost table provides an overall cost for all

the companies involved in the study.

£30,000,000- THE COST OF LONDON LORRY BAN DIVERSIONSThis study details 31 vehicles on 31 routes, travelling once a day Monday-Fr i d a y. The annual extra

costs of the LLB to the companies operating these vehicles is over £190,000. Given that many

companies operate large fleets of vehicles and 55,000 permits are given out annually, even at

a conservative estimate, the cost to industry is £30 million. There is also a cost to residents from

emissions given out by vehicles having to endure long diversions through the outer London boroughs.

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ALG route

Preferredroute

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This national company is based in Kent and delivers to its own retail otulets on a 24/7 basis. The company

operates over 40 commercial vehicles plated at over 18 tonnes. It is an essential requirement of their business

to deliver very early in the morning. Vehicles will usually start their journeys at 4am and deliver to all parts of

London.

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A106>A1206> A13>A1211>30 £29.00 7,800 £7,540 10,217kg

A406>A41>A5205 A1>A501>A41

Case study 1

Route 1 – Depot to Maida Vale

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A106>A1206 A13>A1211>34 £33.00 8,840 £8,580 11,606kg

A406>A1 A1

Route 2 – Depot to Islington

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A106>A1206> A13>A1014 £13.60 3,640 £3,536 4,780kg

A406>A1055>A504

Route 3 – Depot to Hornsey

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A205>A316> A2>A202>A414 £13.60 3,640 £3,536 4,780kg

A4>A3220

Route 4 – Depot to Kensington/Chelsea

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A205>A316> A2>A20226 £25.30 6,760 £6,758 8,879kg

A4>A302

Route 5 – Depot to Victoria

30,680 £29,770 40,262kgTOTALS

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ALG routes

Preferredroutes

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This national company is based in Croydon and operates 40 vehicles. They supply their own retails outlets on a

24/7 basis. The company needs to deliver at night/early morning to cater for outlets where staffing is limited.

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

TootingA23(S)>A2022>

A236>A24>22 £21.50 5,720 £5,590 7,517kg

A217>A297>A24

A205BatterseaA24>A205

BrixtonA205>A23(N)

Case study 2

Route 1 – Depot to a) Tooting, b) Battersea and c) Brixton

28,600 £27,899 37,571kgTOTALS

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

Shepherds BushA23(N)>A205>

A205>A3220> 30 £29.30 7,800 £7,619 10,245kgA406>A40(M)>

A4020A3220

ActonA3220>A40(M)>

A40>A406>A4020

Route 2 – Depot to a) Shepherds Bush and b) Acton

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

DalstonA23(N)>A205>A12>

A119>A1> 22 £21.50 5,720 £5,590 7,517kgB113>A1207

Burnt OakA1207>B113>A12

A406>A1>A5109

Route 3 – Depot to a) Dalston and b) Burnt Oak

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

KilburnA23(N)>A205>

A205>A24>

36 £35.00 9,360 £9,100 12,292kgA406>A5

A3>A202>A5>Camden A501>A4201A5>A406>A1>

A503

Route 4 – Depot to a) Kilburn and b) Camden

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ALG route

Preferredroute

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This national company is involved primarily in the supply of food produce to supermarkets and distribution

centres. The company operates several hundred vehicles on a contracted and own account basis from regional

distribution centres in Kent and Middlesex. The vehicles operated are less than three years old and are clearly in

the vanguard for emissions and noise technology.

The normal operation of the company is a 24/7 one and several deliveries take place at night time and early

morning. At some outlets there will be more than one delivery made during the night and during peak times

there will be several drops.

Night time deliveries are considered essential for the efficient operations of this company’s business. The loading

and unloading of goods during the day is restricted by capacity and staffing constraints.

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

M20>A20>A205> A102>A13>28 £27.00 7,280 £7,020 9,563kgA406>A40/M40> A1211>A1>

A501 A501>A5

Case study 3

Route 1 – Depot to Edgeware Road

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

M20>A2>A406> A13>A1211>36 £35.00 9,360 £9,100 12,292kg

A1>A501 A1

Route 2 – Depot to Barbican

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

M20>A20>A205> A13>A1211>20 £19.50 5,200 £5,070 6,829kg

A406>A40>M41 A501>A1>A40

Route 3 – Depot to Shepherds Bush

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

M20>A20>A205> A205>A3220>14 £13.60 3,640 £3,536 4,780kg

A316>A4 A308

Route 4 – Depot to Fulham

25,480 £24,726 33,464kgTOTALS

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ALG route

Preferredroute

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This national company is a major player in the field of third party ligistics, performing a full storage and distribu-

tion service for several blue chip companies. The needs of the customer dictates that several deliveries need to

be made during the night and early morning.

The company operates several hundred commercial vehicles, mainly articulated units and trailers. The vast

majority of the vehicles are less that five years old indicating that, in terms of noise and emissions, their vehicles

are efficient.

The fact that this company services several customers means that it will need to deliver during the core times of

the LLB on more occasions than the majority of single operators.

Case study 4

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A232>A224>A20>A232>A21 12 £11.70 3,120 £3,042 4,097kg

A205>A2212

Route 2 – Orpington to Bromley

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A406>A1>A501> A406>A13>28 £27.00 7,280 £7,020 9,563kg

A1209 A3>A1209

Route 3 – Ilford to Shoreditch

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A232>A224>A20> A232>A21>10 £9.75 2,600 £2,535 3,415kg

A205>A2015 A222

Route 4 – Orpington to Beckenham

19,760 £19,175 25,954kgTOTALS

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A24>A297>A232>A24>A205 26 £25.30 6,760 £6,578 8,879kg

A240>A3

Route 1 – Tooting to Clapham

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ALG route

Preferredroute

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This organisation is a market leader in the field of food, clothing and household goods distribution. Most of the

operations are performed on a contracted out basis but there is also an own account operation. The number of

outlets serviced by the distribution sector is significant and the operational requirements of the business means

that early morning deliveries are essential.

The company operates several hundred vehicles and the majority are under three years old. The organisation is also

proactive in its views on green transport issues and is aware of its responsibilities to protect the environment and

the public from excessive emissions and noise.

Case study 5

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A406>A41>A501>A1203>A3211 22 £21.50 5,720 £5,590 7,517kg

A400

Route 2 – Depot to Covent Garden

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A406>A41>A501>A2>A202 24 £23.40 6,240 £6,084 8,194kg

A4202>A302

Route 3 – Depot to Victoria

15,600 £15,210 20,491kgTOTALS

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A406>A1>A501>A13 14 £13.60 3,640 £3,536 4,780kg

A10

Route 1 – Depot to Bishopsgate

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ALG route

Preferredroute

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This company is a national name in food and household goods provision. Much of its business in terms of logistics

is contracted out to third party operators. The nature of the business inevitably leads to deliveries within the core

time of the LLB.

Most of the vehicles used are less than five years old and many are under three years old. The company is also

aware of the need to meet with customer environmental aspirations.

Case study 6

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A102>A106> A102>A13>34 £33.00 8,840 £8,580 11,606kg

A1206>A406>A41 A501>A400

Route 2 – Depot to Tottenham Court Road

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A205>A4A102>A205>

18 £17.50 4,680 £4,550 6,146kgA3220>A4

Route 3 – Depot to Cromwell Road

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A102>A106> A102>A13>34 £33.00 8,840 £8,580 11,606kg

A1206>A406>A1 A501>A1

Route 4 – Depot to Islington

26,000 £25,246 34,138kgTOTALS

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A2>A205>A40A102>A205>

14 £13.60 3,640 £3,536 4,780kgA3220>A40(M)

Route 1 – Depot to Ladbroke grove

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ALG route

Preferredroute

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This company is a national high street retailer servicing several hundred outlets. Much of the logistics operation is

contracted out. The company operates several hundred vehicles, the majority of which are under five years old.

The needs of a national retail based business have led to a requirement to deliver to outlets outside of the core

daytime slots. Night time deliveries can have the effect of reducing congestion during the day and this company

sees operational benefits to delivering outside of normal hours.

Case study 7

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A200>A201>A501> A201>A3204>16 £15.59 4,160 £4,053 5,463kg

A40>A406>M4 A3212>A4>M4

Route 3 – Depot to Heathrow

8,320 £8,106 10,926kgTOTALS

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A200>A201>A501> A200>A201>4 £3.89 1,040 £1,013 1,366kg

A41>A40 A40

Route 1 – Depot to Oxford Street

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A200>A201>A201>A3204 12 £11.69 3,120 £3,040 4,097kgA501>A40(M)>A202>A315>

A3220>A315

Route 2 – Depot to Kensington High Street

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ALG route

Preferredroute

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The core business of this company is construction and aggregates. The demands of the customer and the tight

time scales common within the industry results in the need to deliver outside of daytime hours at regular intervals,

especially during the early morning hours before 6am.

The normal day to day operation of sometimes specialist vehicles means that they are highly maintained and

usually not more than five years old.

Case study 8

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A12>A102>A205A11>B132>

18 £25.27 4,680 £6,570 6,914kgA300>A3205

Route 2 – Bow to Battersea

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A12>A406>A41> A11>A501>34 £47.75 8,840 £12,415 13,060kg

A404 A404

Route 3 – Bow to Paddington

28,600 £40,191 42,254kgTOTALS

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

A406>A1>A400> A11>A13>36 £50.55 9,360 £13,143 13,829kg

A5200 A501

Route 1 – Bow to Kings Cross

Designated route Direct routeExtra miles Extra cost Extra miles Extra cost Extra CO 2

per trip per trip per annum per annum per annum

B224>A3>A205>A3216>A315> 22 £30.90 5,720 £8,043 8,451kgA4>A406>A40>A404

A404

Route 4 – Battersea to Paddington

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Summary table

The following table summarises the extra miles, costs and emissions of the stated individual LLB routes.

The extra miles covered due to travelling on the ERN

has led to additional emissions being given off. In

the case of the routes highlighted in the study, an

extra 245 tonnes of CO2 will be emitted annually.

There will also be additional nitrous oxides and

particulate matter.

The above figures represent the totals from the

selected routes in the study. This is by no means an

exhaustive study of all the routes or all the problems

– it is indicative. Clearly, due to the nature and size

of the companies surveyed, the total costs for each

company are considerably higher when all the

night-time deliveries are taken into account. Actual

annual total costs calculated by two of the compa-

nies in the survey have extended beyond £500,000

and £350,000 respectively.

Company Extra miles per annum Extra cost per annum £ Extra CO 2 per annum kgs

1 30,680 29,770 40,262

2 28,600 27,899 37,571

3 25,480 24,726 33,464

4 19,760 19,175 25,954

5 15,600 15,210 20,491

6 26,000 25,246 34,138

7 8,320 8,106 10,926

8 28,600 40,191 42,254

Total 183,040 £190,323 245,060kga

Comparison of hgv emissions 1990-2001

The table below highlights the progress made by the commercial vehicle industry with respect to reducing emissions.

0 10 20 30 40 50 60 70 80 90 100

1990

1993

1996

2001

Key

CO

THC

NOX

PM

Emissions indices

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All categories of emissions have fallen significantly,

especially nitrous oxides and particulate matter. The

majority of vehicles in this survey are less than five

years old and are significantly cleaner than those

used in 1986 when the ban came into being. In

terms of heavy smoke, it would take 16 new heavy

trucks to put out the same amount of particulates

as one heavy truck only 10 years ago. If exhaust

treatment is fitted as well, this figure goes up to

100 heavy trucks.

It is still the case that cars give out a greater

percentage of emissions within Greater London

than commercial vehicles. Although there are more

cars than hgvs it is important to stress that commer-

cial vehicles – in terms of work done, for example

carrying 20 tonnes of freight – are performing an

essential service to London.

The extra miles covered due to the compliance with

the ban will invariably lead to more CO2, nitrous

oxides and particulate matter being discharged into

the London area.

0

10

20

30

40

50

60

70

80

90

1972

Method of measurement as in Council Directive 92/97/EEC

Comparison of vehicle noise levels 1972-1996

The following table gives an indication of how modern day vehicles are considerably less noisy than those of 20

and 30 years ago.

199619901982

The above noise level comparisons confirm that four

of today’s engines are no noisier than one engine

made in 1990. Eight modern engines are no noisier

than one engine 20 years ago based on noise per

horsepower produced.

It should be noted that increases in decibels are

measured on a logarithmic scale (as opposed to a

linear one), ie a +3 increase in decibels leads to a

doubling of sound intensity.

It is clear to see that considerable progress has been

made in the fields of noise and emissions. Much of

the progress made has been as a result of EU

directives. This has led to ongoing co-operation

between the vehic le manufacturers and the

commercial vehicle operators, clearly demonstrating

that companies do give a great deal of thought to

the importance of the environmental impacts of

their businesses.

What cannot be in doubt is the fact that since the

ban started in 1986, the technological gains in

terms of reduced noise and emissions have been

very significant.

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Responses from the survey

Size and age of the company fleet

The companies involved in the survey were large,

mainly national ones with fleet sizes ranging from

35 at individual depot level to several hundred at

national level. The vast majority of the fleets were

less than five years old with many vehicles being

less than three years old.

Which delivery routes and locations giveparticular problems?

Most companies faced the same problems in that

they needed to deliver to their outlets in Central,

West, North and South London outside of normal

hours, to maintain the efficiency of their businesses

and to provide the highest levels of customer service.

The complexity of their businesses, as well as the

limitations due to daytime congestion and opera-

tional constraints, makes night-time deliveries essential.

Does using the ERN increase mileage andtravelling time?

All said that they had to use several routes that

entailed extra mileage being driven and additional

time being taken. This is obviously dependent upon

areas where the deliveries took place.

Are problems made worse by using agency andinexperienced drivers?

There was a general agreement that agency drivers

could cause problems. Some companies need to use

agency drivers because of the large scale nature of

their operations, in order to cover for sickness and

holidays. There are problems of low morale due to

experienced drivers being given the London deliveries

while agency drivers get the easier routes. Agency

drivers are more likely to inadvertently go off the

permitted route and incur fines.

If the ERN was to be extended which routeswould most benefit the company?

Below is a selection of the roads/routes for inclusion

in the ERN.

• A2 from Shooters Hill

• A202 accessed from Woolwich Road

• A13 from Limehouse on the Commercial Road

• A3 from Clapham Common to Elephant & Castle

• A501/A1202 from the Angel to Limehouse

• A5 from the A406 to A501 to Paddington

• A24

• A232 to Bromley

• A21 from M25 to Bromley

• A10

Would the companies use an extended ERN as athrough route to the M25?

None said that they would use the ERN as an easy

way to drive through London to get to the M25.

Should adopting best practice, such as using lowemission vehicles, result in the company beingable to use a wider network of roads?

Many believed that this concept had considerable

merit. It was important to define the criteria on

which such schemes could be operated, monitored

and controlled. Many were of the belief that they

already operated vehicles at the forefront of

technology and were already playing a major part in

reducing the environmental impact of commercial

vehicles.

What improvements could be made to the LLBgiven that it will remain?

There were a wide variety of responses to this ques-

tion as individual companies clearly have different

ideas on how the ban could be improved to benefit

their own firms.

The most common answer was a request for more

flexibility of Condition 5 in order to help reduce costs

and travelling time. Others were:

• changing the core time of the ban hours as the

operational hours are too long – especially sowhen working hours in London now start earlierand finish later;

• more personal contact with ALG officials;

• a greater appreciation by ALG of the role and

importance of the freight industry to the eco-nomic well being of London and its consumers;

• a quicker way of having routes agreed, such asproducing a cd-rom, reducing administration

and increasing consistency. It could also help toplan routes at short notice and in times of emer-gency;

• removal of the need for each vehicle to have a

permit. If a route is agreed then any vehicle withinthe company should be able to use it.

Additional information supplied by respondents

Many of the deliveries are planned for between

6-7am to meet customer requirements. These are

sti ll within the core t ime of the ban but are

effectively morning and not night-time deliveries.

Some companies are using vehicles plated at less

than 18 tonnes to avoid compliance with the upper

weight limit of the ban. In effect this leads to more

journeys, more cost and hence more emissions. This

is clearly contrary to the aims of the ban.

Questions were asked as to the exact criteria of the

ban. Is it in force for noise or emissions? If both are

relevant why are there no agreed limits below which

an operator can operate his vehicles inside the ban

hours? One company suggested that, in their opin-

ion, the most important criteria that has been adopt-

ed was the number of dwellings passed on a route,

emissions and noise were of secondary importance.

Some trailers used are actually smaller than many

17 tonne rigids (which are not included in the ban).

Page 21: The London Lorry Ban - FTA

The LLB: one of many issues

Set up in 1986 to protect Londoners against exces-

sive noise and pollution from heavy commercial

vehicles during the night and at weekends, the ban

also sought to eliminate through traffic accessing

major roads such as the M1 and M25.

Operators who have essential business in London

during the controlled hours are given exemptions,

although Condition 5 of the Traffic Order requires

them to maximise the use of the ERN. This can lead

to lengthy detours, which in turn will lead to higher

operator costs and more emissions.

The opening of the M25 has considerably reduced

the number of commercial vehicles coming into

London at night. This is no bad thing and FTA wholly

concurs with the principle that freight operators who

have no commercial business in London should not

send vehicles into the city, and most certainly should

not use it as a through route to the M25.

Congestion

Operators are faced with many obstacles impacting

on operational efficiency and costs. Congestion dur-

ing the day is a major headache, seriously increasing

journey time unreliability. This leads to reductions in

customer service levels and increased costs. Larger

operators are keen to deliver their goods outside of

normal hours. The Sustainable Distribution White

Paper daughter document called for local authorities

to shift the balance towards out of hours operation.

The very nature of large retail orientated companies

necessitates the delivery of goods during night time

hours. Economically and logistically it makes sense to

do so, maximising customer service and reducing

costs. Also, delivering outside of the daytime hours

allows more road space during the day, reducing

congestion and emissions.

Congestion charging

The London Congestion Charge Scheme (LCCS )

commences on 17 February 2003. The core times

will be 7am-6.30pm. Commercial vehicles as yet are

not exempt from the charge. However, it is clear

that deliveries will still have to be made. Given the

principle behind the LCCS is that of reducing day

time congestion, then the obvious response is

to deliver outside of the LCCS period. With the

current core times of the LLB running from 9pm,

this leaves only a two and a half hour window to

deliver within the LCCS area, ie from 6.30-9pm

before having to comply with the LLB.

Parking and red routes

Commercial operators are currently faced with a

punitive parking regime in London which shows no

sign of abating. Recent research by FTA has

highlighted that millions of pounds (£18m at

present charging levels) are being levied against

companies in parking fines – companies who are

legitimately trying to carry out their day to day

business in serving the commercial sectors and

consumers of London. It is not unusual for the same

vehicle to be given several parking tickets on the same

day due to the need to deliver to several outlets.

The expansion of bus lanes and clearways in particular

are restricting the amount of road space available for

commercial vehicles. The policy of creating more bus

lanes will only exacerbate the problem in the future.

Low emission zones (LEZ)

The ALG, the Mayor’s Office, the London Boroughs,

TfL and the Government have recently commissioned

work to investigate how a LEZ might improve air

quality in London. Although commercial vehicles are

not the prime contributors to poor air quality in

London (they contribute less than 14 per cent) the

initial response from the consultants is to recom-

mend that commercial vehicles attain minimum emis-

sions standards, possibly Euro II or Euro III.

The possible area to be covered by the LEZ is all of

London and possibly all of the area within the M25.

This initiative has a long way to go before inception

but the point to be made is that one of the reasons

the LLB was set up was to protect Londoners against

commercial vehicle emissions. The possibility of intro-

ducing a LEZ would in itself help to protect all of

London against excessive amounts of CO2 and partic-

ulate matter, thus reducing the impact of the ban.

Special routeing

From January 2001 the ALG Transport and

Environment Committee (TEC) was empowered to

agree specific routes as a variant to the ‘normal’

routes that would have been agreed under

Condition 5. Although this is agreeable in principle,

the scheme is not as transparent as it appears.

• It is incumbent on the operator to take the lead inproposing an alternative route and to demon-strate that there are environmental benefits. Thiscould entail counting the number of dwellings onthe proposed route as against the ‘normal’ route.

• The presumption is against a routing agreementand only to be agreed where there is a clear benefit.

• The decision as to whether to agree a proposedalternative rests with the TEC.

• The process involved is administratively timeconsuming and bureaucratic, and having gonethrough the process there is no guarantee thatan operator will be given a routing agreement.

• Where the routing condition would allow anoperator to use residential roads TEC will takeinto account the total number of permits withrouting agreements on that section of road.

• The proposed alternative should be at least 50 per cent better than the existing route inenvironmental terms.

Not everybody was aware of the option to request

special routes. It would be a benefit to all operators

to be made aware of the option to request a special

routeing facility and for it to be an open and

transparent process.

Page 22: The London Lorry Ban - FTA

Summary

The London Lorry Ban has been in operation since

1986. Since that date there have been considerable

advances made by the commercial vehicle industry in

the fields of noise and emissions reductions. Noise

and emissions from commercial vehicles were both

important factors in the decision to set up the ban.

All operators accept that they have a role to play in

helping to reduce the environmental impacts of

running commercial vehicles. Also, it is right that

commercial vehicles not having legitimate business

in London should not be there.

The majority of the delivery vehicles used by the

companies in this study are modern and in relation

to vehicles used in 1986 are considerably less noisy

and polluting. The most common request from oper-

ators was for more flexibility in Condition 5. An

exempt route from east to west via the A13, linking

to the A10 and the A1 would save operators several

hundred thousands of pounds in extra costs and

would also reduce the miles driven and hence

pollution. Vehicles would also spend less time in

London, because they could deliver their goods

quicker and return to their depots quicker.

Many companies deliver their goods early in the

morning, between 6-7am.They regard this as a morn-

ing delivery and not night-time. The ban starts at 9pm

which again is regarded as being too early by many

companies. This is especially relevant when one

considers that the London Congestion Charge does

not finish until 6.30pm. Serious thought should be

given to reviewing the core hours of the ban’s opera-

tion, perhaps starting at 11pm and finishing at 6am.

The companies in the study need to deliver outside

of normal hours in order to operate their businesses

efficiently and provide high levels of customer service.

They also face increasingly difficult problems in

London during the daytime hours because of

congestion. The increasing use of red routes and bus

lanes only compound the difficulties faced.

The way in which freight operators carry out their

day to business in London is clearly influenced by a

variety of factors which has led to increased costs

and delays in deliveries. The LLB needs to take into

account the technological developments that have

taken place since 1986 and also to understand that

delivery patterns are changing and they are likely to

continue to do so in London. The gross domestic

product (GDP) of London is £130 billion per annum

(Mayor’s draft London Plan, Paragraph, 1B.4). This is

bigger than the GDP of Belgium and Sweden.

The importance of deliveries should not be underes-

timated when it comes to the contribution they

make to the continuing economic prosperity of

London. Retail and wholesale alone contribute more

than £15 billion to London’s GDP. When other

sectors are taken into account, such as the service

and manufacturing ones, this figure will increase

significantly.

Delivery into London – what is needed

• A review of the core hours of the ban, midnight to 6am, would better reflect the needs of industry.

• A review of the Exempt Route Network.

• Better communication with ALG on a face-to-face basis.

• More flexibility on Condition 5.

• More transparency and availability on routeing conditions.

• A cd-rom to be produced for a quicker response to routeing queries.

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