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.
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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.
ALG route
Preferredroute
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
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.
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).
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.
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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