Memorandum by the Transport Committee
for London (RH 42)
1. The Transport Committee for London is
a committee of the 33 London local authorities and acts as the
statutory joint committee under s72 of the Road Traffic Act 1991.
Its mission is to improve London's transport system with particular
reference to:
— The operation of London's traffic
lights, traffic control systems and traffic control camera systems
(this function is transferred to the Mayor on 3 July 2000).
— The setting of parking penalties
and other additional parking charges as well as the operation
of the Parking Appeals Service.
— The agreement of the London-wide
concessionary fares scheme for older and disabled people and the
operation of the London Taxicard scheme.
— The operation and enforcement of
London's night-time and weekend lorry ban.
2. In response to the Transport Sub-Committee's
call for written evidence TCfL would like to address particularly
the terms of reference of the Sub-committee's inquiry which refer
to its examination of the road haulage industry's impact on the
environment and what changes to Government policies are needed.
BACKGROUND
3. The London Lorry Control Scheme—the
Lorry Ban—is administered and enforced by the Transport
Committee for London (TCfL), a joint committee of the 33 London
local authorities.
4. The Lorry Ban is an environmental measure
to protect Londoners against the disturbance caused by very large
lorries at night and at weekends. As well as minimising the environmental
impact of lorries, especially on residential areas, the Ban aims
to minimise through traffic whilst ensuring that London's economic
activity continues.
HISTORY
5. In 1983, as a result of complaints by
Londoners about excessive disturbances from heavy lorries, especially
at night-time, the then GLC set up an independent inquiry into
the Effects of Bans on Heavy Lorries in London. The inquiry was
chaired by Derek Wood QC and its report—the Wood Report—concluded:
— London was exceptionally exposed
to traffic noise (with heaviest lorries being the noisiest).
— Most night-time and weekend lorry
movements were by the heaviest and noisiest vehicles.
— Lorries should be made quieter.
— Existing local bans were difficult
to enforce and, if effective, simply threw traffic problems into
adjoining areas.
— A ban would be more likely to succeed
if controlled by some form of exemption system.
6. The GLC acted on the Wood report and
in 1985 the Greater London (Restriction of Goods Vehicles) Traffic
Order was made and implemented as of 1986.
OPERATION
7. Hours of operation—lorries
are banned during at the most environmentally sensitive times.
The "controlled hours" run from 9pm to 7am from Monday
to Saturday and from 1pm Saturday to 7am Monday.
8. Ban area—the Ban applies
to the whole of the Greater London area so that all non-London
traffic is diverted onto the M25. However, certain roads are excluded
from the Ban ie operators can use trunk roads and certain other
roads including some accessing industrial estates. The criteria
for defining an exempt route are that it is a trunk road or a
non-residential, not environmentally sensitive road; it is not
just based on Strategic Routes but also on roads of a non-strategic
(residential) nature, facilitating lorry movement to and around
industrial and commercial areas; such routes must be physically
and environmentally suitable for HGV's of 18 tonnes or over. This
Exempt/Excluded Route Network is currently being reviewed in order
to take account of changes since 1985 eg new roads and developments
as well as to take account of the GLA Act 1999 which will have
the effect of detrunking all trunk roads in London.
9. Weight limits—the lorry
weight limit for the ban is now set at over 18 tonnes (though
originally 16.5 tonnes) and is intended to cover the heaviest
and noisiest lorries whilst taking into account recent legislation.
This change is also due to enforcement practicality: 18 tonnes
is the maximum weight for 2-axle lorries, therefore they are not
covered, but all 3-plus axle lorries are.
10. Exemptions—exemptions are
provided for those lorries which have essential business in London
during the controlled hours. Lorry operators have to apply for
a permit setting out the circumstances for the exemption (see
Appendix A for the policy statement setting out when exemptions
will be considered and the conditions which will apply). Some
55,000 permits are issued annually for those with regular, proven
essential business in London. Some 5,000 lorries with infrequent
business in London are granted a permit on a single journey basis.
11. Enforcement—the Traffic
Order is administered and enforced in all 33 London local authorities.
This is carried out by the TCfL's Traffic Enforcement Unit. London-wide
enforcement is carried out by a small team of mobile enforcement
officers who carry out roadside monitoring on a peripatetic basis.
Unlike the local area bans police assistance is not required.
In addition there is currently a pilot scheme which is evaluating
the use of CCTV cameras for enforcement purposes. An average of
2,500 prosecutions are brought annually of which between 90-95
per cent result in successful convictions.
FUNDING
12. The operating costs for 2000/1 will
amount to £757,000 and will be charged to the 33 London local
authorities on a per capita basis. There is no cost to the haulage
industry although proposals have been mooted for the introduction
of charging for permits. Whilst some of the local authorities'
costs are met from fines and costs from successful convictions
there is still a net cost to London local authorities and their
taxpayers.
ISSUES
13. Environment implications—the
TCfL night and weekend lorry controls are in accord with the Government's
transport and environmental policies. Despite vast improvements
in design which have reduced vehicle noise and emissions, London's
residents are still concerned about noise from lorry vibrations,
loading and unloading and pollution. Local authorities recognise
the importance of freight to London's economy but equally have
to balance these concerns with the need to address residents'
concerns. The benefit to operators of night-time travel on urban
roads must be traded off with the environmental disbenefits which
are most keenly felt by local residents, whose perceptions of
unacceptable noise and pollution levels can be vigorously voiced.
The increasing use of brownfield sites for housing means that
there are increasing numbers of residents who could be affected
by night-time travel. Successive traffic monitoring reports from
the DETR have shown that HGV traffic in London has declined rapidly
since the 1980's and this suggests that the Lorry Ban has been
one of the factors influencing this. This is in the face of the
national trend.
14. Night-time deliveries—the
Lorry Ban does not prevent night-time deliveries. Those operators
wishing to deliver to premises in London during the hours of the
ban may obtain permits to allow this. It is only planning regulations
that prohibit or restrict night-time deliveries.
15. Congestion—many operators
argue that the Lorry Ban contributes to London's congestion problems
and that despite the vast improvements in vehicle noise and emissions
operators are still prevented from making deliveries outside the
hours of the Ban. It is argued that encouraging night-time travel
on urban roads will not have a significant impact on daytime congestion.
The number of additional deliveries that those businesses which
already have overnight staff can take is limited. Many large retailers
operate Just-in-Time methods in order to minimise stock requirements
and these often average four or five deliveries a day. Not all
of these could be taken at night even if the retailers wanted
to. As for those businesses which currently do not operate at
night if they were required to do so then this would lead to increased
costs. This is more likely to fall disproportionately on small
and medium-sized businesses.
16. Lengthy diversions—operators
argue that the Lorry Ban can encourage adverse environmental impacts.
The bulk of London's strategic road network is, and will remain,
exempt from the Ban. Operators can use this network to make deliveries.
However the roads on which the Lorry Ban operates is to ensure
that through traffic is prevented from crossing London at weekends
and at night and is required to use the M25. This is what the
M25 orbital motorway was designed for. In some cases permit conditions
oblige operators to take longer routes than necessary in order
to minimise their travel away from the Exempt Route Network. This
issue is being addressed by the introduction of a variation to
permit conditions where an agreement can be reached on a routing
option which both benefits the operator and does not breach the
environmental principles of the Ban (see Appendix B).
FUTURE DEVELOPMENTS
17. Decriminalisation of London Lorry
Ban offences—the Transport Committee for London is investigating
the issue and is looking a:
— the possibility of treating these
offences as parking offences are (ie fines rather than criminal
prosecutions);
— whether there should be different
levels of fines for operators and businesses and at what level;
— what appeals procedure should operate
eg similar to the way parking appeals are currently dealt with.
18. A number of benefits could arise from
decriminalisation for both operators eg lessens the possibility
of operators losing their licences as well as for other eg the
pressure on Magistrates Courts could be relieved, resources expended
by local authorities on pursuing criminal prosecutions for Lorry
Ban offences could be reduced, synergy with work around moving
vehicle traffic offences using camera enforcement could be brought
about.
19. GLA/Mayor's freight strategy—the
Mayor will be reviewing freight issues comprehensively as part
of the development of his transport strategy. TCfL looks forward
to working with the Mayor to set out a sustainable distribution
policy which will strike a balance between minimising the adverse
environmental effects of delivery vehicles whilst improving London's
competitiveness and reducing social exclusion.
February 2000
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