Memorandum by The Institute of Road Transport
Engineers (IT 126)
A NEW DEAL FOR TRANSPORT: BETTER FOR EVERYONE
The Institute of Road Transport Engineers (IRTE)
is a professional institute representing over 18,000 individual
members mainly in the maintenance and operational sectors of the
road transport industry. It also represents 26 major industry
organisations who are industrial affiliates of the Institute.
Its objectives are concerned with the education and training of
engineers and technicians and the promotion of good engineering
practice in the interests of safety and efficiency.
Through its associated trading company it also
runs two major annual exhibitions and the concurrent conferences
that at Telford being the largest of its kind in the U.K. Although
it is not a trade association or a trade union the Institute is
active in making an input to the standards making and regulatory
processes on behalf of its members.
We welcome the theme of integration and the
intermodal approach which recognises that each transport mode
should be used where it is most efficient and appropriate to do
so. Cost, delay and inconvenience is most likely to occur at the
transfer point from one mode to another and journeys, whether
for people or goods, should be as seamless as possible. Any transport
system relies on engineering assets for operation, whether it
be a railway signalling system, an airliner, a container handling
crane, an escalator, a minibus or a hovercraft. For the transport
system to function effectively these engineering assets must be
designed exactly for their application and be safe, reliable and
durable when used in that application. The design and maintenance
of road vehicles, from motor cycles to heavy haulage equipment,
is at the heart of our interest in a coherent long term national
and international transport policy which hitherto has not existed.
Much of the White Paper consists of broad statements
of policy or intent, some of these potentially conflicting, but
without detail of the means and time-scale to achievement. For
this reason we see the main opportunity for comment arising with
the publication of the further documents referred to in Annex
A and through the normal process of public consultation for any
new legislation which may be drafted arising from the White Paper's
Notwithstanding the above approach we would
like to comment on some of the issues raised by specific paragraphs
or sections of the paper as follows:
2.57 Whilst we support the use of lighter and
more fuel efficient vehicles, whether they be cars, buses or goods
vehicles, and also any efforts to cut down running losses, we
would suggest that:
1. The biggest potential fuel consumption
savings arise from change in driving style almost irrespective
of the type of vehicles concerned, (cf also paragraph 3.158);
2. An increase in the occupancy of cars as
suggested in the car sharing proposals of paragraph 5.38 will
have a far more profound effect on fuel consumed per passenger-mile
or kilometre which is the best test of efficiency.
3.107 and 3.155 We are very interested in the
proposals for city logistics and "sustainable distribution"
and look forward to further details on these.
3.143 We note the reference to accreditation
of recovery vehicles and wonder whether this refers to the firm
running the vehicle, the operator, the vehicle itself or all three.
Quite apart from the safety issues of running on the hard shoulder
recovery vehicles need to be professionally designed and operated
and there is a strong case for special treatment in respect of
permissible axle weights while engaged on recovery work.
3.157 High load factors are desirable from both
commercial and fuel efficiency viewpoints but some industries
involved in transporting bulky but low density products where
load volume is the prime limitation may nevertheless for good
reasons use vehicles whose designed gross weights will not be
reached in practice. This does not necessarily mean that such
a vehicle is less fuel efficient or more polluting than one of
a lower gross weight.
3.160 to 3.167 The issues involved here in the
change of axle and gross weights for goods vehicles are well known
and have been thoroughly publicised by the trade associations
and others. We do not propose to restate the arguments here. In
particular from a transport efficiency and environmental point
of view the case for 44 tonnes on six axles is unassailable and,
as is pointed out in paragraph 3.164, this conclusion was reached
nearly twenty years ago in a very thorough and wide ranging inquiry
chaired by Sir Arthur Armitage.
3.258 and 3.259 We note the proposal to review
the regulation of transport safety and the investigation of accidents
and would query to what extent, if at all, the existing arrangements
in the road transport sector might be affected.
4.5 The brief and composition of the proposed
Commission for Integrated Transport is noted as is the statement
that the members will be chosen for their expertise, and impartiality.
May we express the hope that in view of strong dependence of the
transport industry on engineering products and disciplines at
least one of the members of the Commission should have an engineering
background and qualification.
4.124 At the time of writing the practical interpretation
of the proposed V.E.D. concessions for "low emission"
vehicles is still awaited. Until these are defined relevant decisions
on the specification of new vehicles cannot be made with confidence.
4.139 Fleet engineers and managers constantly
strive to specify the most efficient vehicles for their particular
operating circumstances. We therefore applaud the support of research
programmes with this objective and the tacit assumption that more
efficient usually means more environmentally acceptable.
In particular we would like to be advised of
the details of the programmes and would welcome any involvement
within our capacity.
We wonder also whether the government is considering
financial incentives to encourage good practice, or in recognition
of existing good practice?
29 September 1998