SUMMARY STAKEHOLDER RESPONSES - TRANSPORT FOR LONDON DVS CONSULTATION 2A - TFL ...
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TRANSPORT FOR LONDON DVS CONSULTATION 2A
Summary Stakeholder Responses
www.wsp.comLIST OF SUMMARY RESPONSES GROUPED BY STAKEHOLDER GROUP
Ref Page
Name Organisation Stakeholder Category
No. No
1 Maria Curro Better Bankside BID Business 4
2 Paul Clarke CEMEX Business 5
3 Jerry. Ward John Lewis Business 6
4 Neil Dangolitis Royal Mail Group Business 7
5 Steve Carter Sir Robert McAlpine Ltd Business 8
6 Tim Cowling Tarmac Business 9
7 Gordon Sutherland Thames Tideway Business 10
8 Steve Bell Thames Water Business 11
9 Graham Bellman Travis Perkins Business 12
Caroline Pidgeon
10 AM Greater London Assembly Elected Representative 13
11 Grace Eminton London Borough of Brent Local Authority 14
12 Maxim Lyne London Borough of Camden Local Authority 16
13 Tobias Newland London Borough of Hackney Local Authority 17
14 Stephen Burke London Borough of Enfield Local Authority 18
15 Caroline Dubarbier Royal Borough of Kensington and Chelsea Local Authority 19
16 No name given Westminster City Council Local Authority 20
Association of International Courier and Express
17 Anne de Courcy Services Trade Association 21
18 M Bracey Brewery Logistics Group Trade Association 22
19 Patrick Cusworth British Vehicle Rental and Leasing Association Trade Association 23
20 Natalie Chapman Freight Transport Association Trade Association 24
21 James Sloan Institution of Civil Engineers Trade Association 25
22 Jerry McLaughlin Mineral Products Association Trade Association 26
23 Tom Cottton Road Haulage Association Ltd Trade Association 28
24 David Francis Society of Motor Manufacturers and Traders Trade Association 29
25 Phil Moon DAF Trucks Vehicle Manufacturer 30
26 Andy Graves Dennis Eagle Vehicle Manufacturer 31
27 Bob Gowans Mercedes-Benz Trucks UK Limited Vehicle Manufacturer 32
28 Phil Rootham Scania GB Ltd Vehicle Manufacturer 33
29 John Comer Volvo Vehicle Manufacturer 34
Vulnerable Road User
30 Dr Susie Morrow Action on Lorry Danger Grp 36
Vulnerable Road User
31 Anna Zee British Motorcyclists Federation Grp 37
Vulnerable Road User
32 Duncan Dollimore Cycling UK Grp 38
Vulnerable Road User
33 Tom Bogdanowicz London Cycling Campaign Grp 39
Vulnerable Road User
34 Jeremy Leach London Living Streets Grp 40
Amy Aeron- Vulnerable Road User
35 Thomas Roadpeace Grp 41
Vulnerable Road User
36 Kevin Clinton Royal Society for the Prevention of Accidents Grp 42
Nicholas Vulnerable Road User
37 Sanderson Sustrans Grp 43
Abbreviations
Page 2London Lorry Control Scheme (LLCS) Direct Vision Standard (DVS)
Safety Permit Scheme (SPS) Transport for London (TfL)
Heavy Goods Vehicle (HGV) Driver and Vehicles Standards Agency (DVSA)
Department for Transport (DfT) Automatic Number Plate Recognition (ANPR)
Fleet Operator’s Recognition Scheme (FORS) London Freight Enforcement Partnership (LFEP)
Construction Logistics and Community Safety (CLOCS) European Commission (EC)
Vulnerable Road User (VRU) European Union (EU)
Ultra-Low Emission Zone (ULEZ) United Nations Economic Commission for Europe (UNECE)
Toxicity Charge (T-charge) Traffic Regulation Order (TRO)
Safer Lorry Scheme (SLS)
Page 31. Better Bankside Summary Stakeholder Response
Stakeholder Group: Business
RESPONSE SUMMARY – PORTAL SUBMISSION
Better Bankside welcomes this consultation on HGV safety standard permits, as they believe a permit system is
needed to improve the safety of VRUs. They strongly agree that the amount HGV drivers can directly see through the
cab’s windows plays a role in collisions with VRUs and should be improved to reduce HGV road risk. They note,
however, that additional information is needed from TfL on how the DVS requirements and rating system will be
communicated to national and international freight operators.
Better Bankside agree with the proposed rating system with both a DVS rating of one star being set in 2020 as the
minimum acceptable standard for HGVs without further safety measures and a DVS rating of three stars being set in
2024. However, additional clarity is needed whether the proposed rating system will take into consideration other
elements which result in HGV collisions, such as left warning indicators, etc. Without including these additional
elements, the rating system is not holistic and misses fundamental elements which can increase the safety of VRUs.
Additional clarity is needed on whether the proposed rating system will encompass the scoring criteria as set out in
other freight safety programmes, such as the Safer Lorry Scheme. It is also unclear how ULEZ will impact the
proposed rating system. Additional information would be welcomed.
Better Bankside strongly agrees that HGVs not meeting the above minimum star requirements should be required to
operate further safety measures to increase their safety however they disagree that such HGVs should be banned
from operating in London if unable or unwilling to do so. They strongly agree with the principles and way TfL proposes
to approach setting this ‘safe system’, along with the proposed measures being considered within the safe system.
They highlight that the proposed safe system should ensure that unless a vehicle is fully compliant, a permit should
not be provided. This will ensure that HGVs operating are safe, and will remove a compliancy ‘grey zone’ (i.e. where a
vehicle is working towards compliancy). To ensure that the programme is streamlined and can be understood by
freight operators, the DVS and safe system should be combined.
Better Bankside feels that Business Improvement Districts would best represent their views in identifying which
measures would meet the ‘safe system’, and they also agree that the DVS Scheme would be best enforced through a
camera system that will read number plates and check against a list of permits that have been issued.
Direct Vision should be considered as part of a wider package of measures to reduce HGV road danger and Better
Bankside agrees with the proposed method of implementation through the LLCS and enforcement through issuing
PCNs.
Regarding setting up of a network of national testing centres for certifying vehicles, Better Bankside feels the most
important factor for TfL to consider is to ensure that the testing is available across UK and Europe. They also agree
with the approach of TfL producing an online ‘look up’ tool.
Page 42. CEMEX Summary Stakeholder Response
Stakeholder Group: Business
RESPONSE SUMMARY – PORTAL SUBMISSION
CEMEX agrees that the amount HGV drivers can directly see through the cab’s windows plays a role in collisions with
VRUs and should be improved to reduce HGV road risk. They strongly disagree with the proposed star rating
boundaries for vehicles under the DVS scheme and feel there needs to be more analysis on how these guidelines and
assessments are implemented to allow operators to replace fleet with the optimum standard vehicle through their
standard fleet replacement cycles. CEMEX has recently added a large number of N3 vehicles to their fleet which may
now not be in line with previously advised guidelines. They feel that the proposals don’t allow for the ongoing
developments in new autonomous technology ie, AEBS4 and sideguard assist, and there are no incentives being
offered to mitigate increased cost.
While CEMEX agrees with the proposals to introduce the proposed SPS, they are strongly against this making it more
expensive for businesses to operate HGVs in London.
CEMEX strongly disagrees with both a DVS rating of one star being set in 2020 as the minimum acceptable standard
for HGVs to operate in London without further safety measures and a DVS rating of three stars being set in 2024.
They feel that the DVS star ratings should be combined with the ‘safe system’ so that there is an overall safety rating
for the vehicle.
CEMEX strongly agrees that HGVs not meeting the above minimum star requirements should be required to operate
further safety measures and that such HGVs should be banned from operating if unable or unwilling to do so. They
disagree with the principles and way TfL proposes to approach setting this ‘safe system’, although they do agree with
the proposed measures being considered within the safe system and feel the emerging autonomous systems should
be included as a component.
CEMEX feels that trade associations would best represent their views in identifying which measures would meet the
‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera system to check
against a list of permits that have been issued.
CEMEX feels that Direct Vision should be considered as part of a wider package of measures to reduce HGV road
danger, but they feel that there is no criteria currently being made available to allow replacement fleet procurement
decisions to be made. They also agree with the proposed method of implementation through the LLCS and
enforcement through issuing PCNs.
Regarding setting up of a network of national testing centres for certifying vehicles, CEMEX feels the most important
factors for TfL to consider include the cost to operator, simplicity of the test, time taken to complete the test, ensuring
that the standards being tested are consistent with other tests, ensuring the tester is independent of TfL and
additionally that self-certification is required. They do not agree with the approach of TfL producing an online ‘look up’
tool which produces DVS ratings once the height of the vehicle has been accurately measured.
Page 53. John Lewis Summary Stakeholder Response
Stakeholder Group: Business
RESPONSE SUMMARY – EMAIL SUBMISSION
John Lewis supports efforts to make roads safer for all users, particularly VRUs and welcome the HGV Safety
Standard. They believe that businesses must be provided with appropriate lead-in time before implementation. The
implementation of the DVS needs to be reviewed in order that it is introduced alongside the central London ULEZ,
providing businesses time to make changes.
John Lewis’ freight vehicles are fitted with forward facing, nearside/offside, and rear-view cameras. Their drivers
receive regular training on how to interact with VRUs. Use of cameras and mirrors provide a level of visibility to drivers
which no amount of direct vision will be able to match or replace. They expect that as on board camera technology
improves these systems will become increasingly developed and deliver even greater benefits.
The field of vision for the safe system should not exceed what is required on the DVS. Class V and VI mirrors are
suggested as an example measure. These are already required under the Safer HGVs Scheme. If they are included
as a measure, then it should be recognised that some trucks are fitted with indirect vision devices instead of those
mirrors which cover the same area. If camera systems are included, then they should be required to cover the front
and nearside areas of the vehicle and cover the same field of vision as the DVS.
The HGV Safety Standard is seen as being a vehicle-based scheme, therefore training for drivers should be
considered separately.
TfL should, from John Lewis’s perspective, set out what systems and measures will be approved for use. Businesses
require a period of preparation in order to integrate changes to processes. A roadmap for future transport policy
related to safety and environmental regulations would be useful, including certainly as to what vehicles will still be
allowed on London’s roads in 2020 and 2024.
The John Lewis Partnership opposes the LLCS being used as the basis of the HGV Safety Standard. The standard
could be aligned with the requirements set out in the Congestion Charge Zone. The LLCS heavily restricts routes that
can be used out-of-hours which increases the level of HGV traffic during peak times, adding risk for VRUs.
When looking to develop future transport policy or regulations, John Lewis believe it is important that there is a joined-
up approach across government departments and from national to local government. They have some concerns with
TfL’s proposal to introduce a DVS in London only. Regulations related to vehicle design should be decided and
implemented at national rather than local level.
It is proposed that vehicles which meet the one-star rating in 2020 will automatically be entitled to a permit. However,
John Lewis view that membership of FORS must not form part of the regulatory requirement. There should be other
approved routes to accreditation, including self-certification. John Lewis strongly favours a self-certification approach.
John Lewis agree with the use of Automatic Number Recognition Scheme (ANPR) as a cost effective means of
enforcing the scheme. There would be a continued need for roadside enforcement, as ANPR would only be able to
verify if the user has a permit and not able check the measures.
John Lewis supports a constructive dialogue between all road users aimed at improving road safety.
Page 64. Royal Mail Group (RMG) Summary Stakeholder
Response
Stakeholder Group: Business
RESPONSE SUMMARY – PORTAL SUBMISSION
The Royal Mail Group Ltd (RMG) agrees that the amount HGV drivers can directly see through the cab’s windows
plays a role in collisions with VRUs and should be improved to reduce HGV road risk. However, they strongly disagree
with the proposed star rating boundaries for vehicles under the DVS scheme. While they believe the standards set are
good, the timescales are unrealistic and the manufacturers are a long way behind producing vehicles with the DVS
required for the London Scheme such as DAF which is the majority of RMG’s fleet. They also disagree with the
proposals to introduce the proposed SPS, especially if it may make it more expensive for businesses to operate HGVs
in London.
RMG disagrees with both a DVS rating of one star being set in 2020 as the minimum acceptable standard for HGVs to
operate in London without further safety measures and a DVS rating of three stars being set in 2024. They feel that
the DVS star ratings should be combined with the ‘safe system’ so that there is an overall safety rating for the vehicle.
RMG agrees that HGVs not meeting the above minimum star requirements should be required to operate further
safety measures to increase their safety however they disagree that such HGVs should be banned from operating in
London if unable or unwilling to do so. They are unsure about the principles and way TfL proposes to approach setting
this ‘safe system’ however they agree with the proposed measures being considered within the safe system. The
RMG suggests that vehicles and cycles are kept separate on the busy roads in London and cycles must use the cycle
paths and not the main roads. This will reduce and potentially eradicate cyclist deaths by LGVs.
RMG feels that HGV manufacturers would best represent their views in identifying which measures would meet the
‘safe system’. They strongly disagree that the DVS Scheme would be best enforced through a camera system that will
read number plates and check against a list of permits that have been issued.
Direct Vision should be considered as part of a wider package of measures to reduce HGV road danger however the
RMG feels that to implement the permit scheme in such small timescales is too unrealistic and unfair to operators to
be able to change their fleet or adapt. The cost would be high and manufacturers do not have DVS as a priority. They
disagree with the proposed method of implementation through the LLCS and enforcement through issuing PCNs to
operators/ hauliers (£550) and drivers (£130).
Regarding setting up of a network of national testing centres for certifying vehicles, the RMG feels the most important
factors for TfL to consider include the cost to operator, simplicity of the test, time taken to complete the test, ensuring
that the testing is available across UK and Europe, ensuring that the standards being tested are consistent with other
tests and ensuring that the tester is independent of TfL. They highlighted that the time taken to complete the test
should be done at the same time as the MOT, not an extra test. They do not have an opinion regarding the approach
of TfL producing an online ‘look up’ tool which produces DVS ratings, however they feel the tool should be linked to
the manufacturer’s specification and link to operators vehicle serial numbers to show if compliant or not.
Page 75. Sir Robert McAlpine Summary Stakeholder Response
Stakeholder Group: Business
RESPONSE SUMMARY – PORTAL SUBMISSION
Sir Robert McAlpine strongly agrees that the amount HGV drivers can directly see through the cab’s windows plays a
role in collisions with VRUs and should be improved to reduce HGV road risk. They also agree with the proposed star
rating boundaries for vehicles under the DVS scheme. However, while they agree with the proposals to introduce the
proposed SPS, they don’t think it should make it more expensive for businesses to operate HGVs in London.
Sir Robert McAlpine agrees with a DVS rating of one star being set in 2020 as the minimum acceptable standard for
HGVs to operate in London without further safety measures however are unsure about the DVS rating of three stars
being set in 2024. They feel that the DVS star ratings should be combined with the ‘safe system’ so that there is an
overall safety rating for the vehicle.
Sir Robert McAlpine agrees that HGVs not meeting the above minimum star requirements should be required to
operate further safety measures to increase their safety and that such HGVs should be banned from operating in
London if unable or unwilling to do so. They also agree with the principles and way TfL proposes to approach setting
this ‘safe system’, along with the proposed measures being considered within the safe system.
Sir Robert McAlpine feels that VRU campaign groups would best represent their views in identifying which measures
would meet the ‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera
system that will read number plates and check against a list of permits that have been issued.
Sir Robert McAlpine feels that Direct Vision alone suffices and does not need to be considered as part of a wider
package of measures to reduce HGV road danger. They have no opinion regarding the proposed method of
implementation through the LLCS and enforcement through issuing PCNs to operators.
Regarding setting up of a network of national testing centres for certifying vehicles, Sir Robert McAlpine feels the most
important factors for TfL to consider include the cost to operator, simplicity of the test, time taken to complete the test,
ensuring that the testing is available across UK and Europe, ensuring that the standards being tested are consistent
with other tests and ensuring that the tester is independent of TfL. They also agree with the approach of TfL producing
an online ‘look up’ tool which produces DVS ratings once the height of the vehicle has been accurately measured.
Page 86. Tarmac Summary Stakeholder Response
Stakeholder Group: Business
RESPONSE SUMMARY – EMISSION SUBMISSION
Tarmac strongly agrees that a HGV driver being able to directly see through the cab’s windows plays a role in
collisions with VRUs and that this should be improved. The introduction of the SPS is positive, but the effects of such
a measure need to be reflected in pricing of transport and products to enable SME’s, in particular, to fully comply.
Tarmac disagrees with the proposed star rating boundaries for vehicles under the scheme. They believe there are too
many variables associated with the academic study, for example the ‘standardisation’ of pedestrian heights which
makes no allowance for children. The process needs to be much simpler and clearer.
There should be a clearly defined minimum standard e.g., definition of star ratings, with appropriate consultation with
stakeholders to ensure these are suitable and robust. Vehicles are being bought now that may not be compliant for
when this standard is introduced, so there is a need to confirm the standard early.
TfL have taken on board feedback from previous consultations, however, some of the detail in this consultation (the
level of fines and the national testing scheme, for example) has come as a surprise.
The standard and ratings need to have the flexibility to include emerging technologies that will improve safety e.g.
assisted braking, cameras etc. New technology must be recognised by the standard. Whilst not perfect, ‘Option 5 -
HGV Safety Standard Permit Scheme’ appears to be the most favourable of the options suggested. The option
recognises the safety benefits of additional indirect safety systems and direct vision.
If the technology moves on to operate in a different manner but achieve improved outcomes, then the system would
need to be regularly improved. For example, the FORS standard has historically required mirrors to be in place with a
camera system that had actually replaced the mirrors so both were needed for compliance, but this was actually
unnecessary. One option could be that any haulier who already has FORS silver would meet the standard. Their
FORS certification could be used as evidence of meeting the ‘safe system’ requirements.
Being ‘unwilling’ to improve safety standards is a different issue to being ‘unable’ to improve. ‘Unwilling’ hauliers who
have no inclination to improve safety standards should be banned from operating. There would need to be
understanding of a situation where a haulier is ‘unable’ to meet minimum star requirements. There should be
appropriate support to help them comply.
DVS alone is not enough. The wider package should include better information for other road users including cyclists
and pedestrians, driver training and road infrastructure work to include segregation for more VRUs.
Due to previous issues with LLCS Tarmac would be concerned about implementation of the DVS scheme by
amending the LLCS.
To avoid complications and unnecessary expense, the ULEZ fine and DVS fines all need to operate through the same
process. As part of the permitting system, there needs to be an audit/follow up. There needs to be a strong penalty
system in place for false or misleading information supplied in the application.
Tarmac have used the online look up tool for ULEZ compliance and found inaccuracies. This system should be
delayed until it has been fully tested to ensure it is fit for purpose.
Page 97. Thames Tideway Summary Stakeholder Response
Stakeholder Group: Business
RESPONSE SUMMARY – EMAIL SUBMISSION
Tideway believe that the creation of the DVS remains relevant and should be progressed. They recognise that
addressing the risk to VRUs associated with the driver's blind spot is more effective through direct vision, as opposed
to indirect visual aids.
Tideway support the development of a DVS that is able to be applied in practical terms to high risk vehicles those
vehicles, as well as in general terms. Tideway believe DVS would work better as part of the proposed SPS
requirements (via a new TRO and operated by the London Councils), as opposed to a standalone defined criteria; in
particular links with FORS and CLOCS. The SPS should apply in the same geographical area as the ULEZ and within
the same timescales.
Tideway agree with the overall methodology, however work remains to be done on the technical measurements, and
the practical implementation of the DVS will depend on an agreed individual star rating system. Tideway is actively
encouraging its supply chain to use 5 star rated N3 Class HGVs but they do not support options 1-4 described in
section 5 of the consultation document. Option 5 however, Tideway say is reasonable and practical.
Tideway believe that all of the measures listed in Table 1 in section 6 should apply but that the verification of
compliance, needs to be explained and should be subject to further study by TfL, working with the industry. The
operator penalty for non-compliance should be on a par with, or higher than, the average cost involved in fitting the
appropriate safety equipment, making it more cost effective to comply than to take a fine instead. The driver fine is
reasonable.
Tideway conclude that companies and major projects in London have a role to play in encouraging development of the
DVS and the SPS. CLOCS and FORS members could help through working with TfL and the industry in aligning their
respective standards with the SPS.
Page 108. THAMES WATER SUMMARY STAKEHOLDER
RESPONSE
Stakeholder Group: Business
RESPONSE SUMMARY – PORTAL SUBMISSION
Thames Water agrees that the amount HGV drivers can directly see through the cab’s windows plays a role in
collisions with VRUs and should be improved to reduce HGV road risk. They also agree with the proposed star rating
boundaries for vehicles under the DVS scheme. While they agree with the proposals to introduce the proposed SPS,
they don’t feel it should make it more expensive for businesses to operate HGVs in London.
Thames Water is unsure about a DVS rating of one star being set in 2020 as the minimum acceptable standard for
HGVs to operate in London without further safety measures and disagree with a DVS rating of three stars being set in
2024. They feel that the DVS star ratings should be combined with the ‘safe system’ so that there is an overall safety
rating for the vehicle.
Thames Water agrees that HGVs not meeting the above minimum star requirements should be required to operate
further safety measures to increase their safety and that such HGVs should be banned from operating in London if
unable or unwilling to do so. They agree with the principles and way TfL proposes to approach setting this ‘safe
system’, along with the proposed measures being considered within the safe system.
Thames Water feels that the Department for Transport best represents their views in identifying which measures
would meet the ‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera
system that will read number plates and check against a list of permits that have been issued.
Direct Vision should be considered as part of a wider package of measures to reduce HGV road danger and Thames
Water agrees with the proposed method of implementation through the LLCS and enforcement through issuing PCNs.
Regarding setting up of a network of national testing centres for certifying vehicles, Thames Water feels the most
important factors for TfL to consider include the simplicity of the test, ensuring that the testing is available across UK
and Europe and ensuring that the standards being tested are consistent with other tests. They also agree with the
approach of TfL producing an online ‘look up’ tool which produces DVS ratings once the height of the vehicle has
been accurately measured.
Page 119. TRAVIS PERKINS SUMMARY STAKEHOLDER
RESPONSE
Stakeholder Group: Business
RESPONSE SUMMARY – PORTAL SUBMISSION
Travis Perkins agrees that the amount HGV drivers can directly see through the cab’s windows plays a role in
collisions with VRUs and should be improved to reduce HGV road risk. However, they disagree with the proposed star
rating boundaries for vehicles under the DVS scheme. They feel that the star rating is dependant of the seating
position, height of driver, and takes no account of any systems fitted to a vehicle to enhance the driver’s vision or
ability to sense when a VRU is in close proximity to a vehicle. They also feel that the timescales are unrealistic in the
life cycle of vehicles within fleets.
Travis Perkins agrees with the proposals to introduce the proposed SPS scheme but were not sure whether that
should make it more expensive for businesses to operate HGVs in London. They disagree that a DVS rating of one
star should be set in 2020 as the minimum acceptable standard for HGVs to operate in London without further safety
measures and that a DVS rating of three stars should be set in 2024. They feel that the DVS star ratings should be
combined with the ‘safe system’ so that there is an overall safety rating for the vehicle.
Travis Perkins agrees that HGVs not meeting the above minimum star requirements should be required to operate
further safety measures to increase their safety and that such HGVs should be banned from operating in London if
unable or unwilling to do so. They also strongly agree with the principles and way TfL proposes to approach setting
this ‘safe system’, along with the proposed measures being considered within the safe system. Additionally, they feel
that consideration should be given to the range of systems able to be fitted and also the training elements of what fleet
operators sign up. The systems covered need to be a more generic standard, and not specific, leaving operators to
use the many systems available, such as warning systems, camera systems, retrofit vision enhancements, training
and so on.
Travis Perkins feels that trade associations would best represent their views in identifying which measures would meet
the ‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera system that
will read number plates and check against a list of permits that have been issued.
Direct Vision should be considered as part of a wider package of measures to reduce HGV road danger and Travis
Perkins emphasises that whichever scheme is agreed needs sufficient time to be implemented and clarity on what
systems can be used – this should be left until the last few months to agree what these are. They disagree with the
proposed method of implementation through the LLCS and enforcement through issuing PCNs..
Regarding setting up of a network of national testing centres for certifying vehicles, Travis Perkins feels that this will
put additional pressure on an already overloaded system. They feel it will need better planning and the use of
independent standards and audits or self-certification using FORS. They don’t see the need to check compliant
operators once TfL have agreed the standards.
Travis Perkins agrees with the approach of TfL producing an online ‘look up’ tool which produces DVS ratings once
the height of the vehicle has been accurately measured – they highlight the tool should be clear and simple to use.
Page 1210. Caroline Pidgeon Summary Stakeholder Response
Stakeholder Group: Elected Representative
RESPONSE SUMMARY – EMAIL SUBMISSION
Caroline strongly supports effective action to make our roads safer for both pedestrians and cyclists, by the
introduction of a new DVS, together with a permit scheme for HGVs. At present collisions with HGVs are the single
biggest source of cyclist deaths in London and a major factor in pedestrian deaths.
In relation to how the ratings boundaries have been set, Caroline believes there is a case for vehicles below 1 star
being reviewed to identify those that pose the greatest danger to VRUs. Caroline would strongly support HGVs not
meeting the minimum star requirement for DVS being required to operate further safety measures to increase their
safety and where they don’t comply should be banned.
Whilst Caroline recognises that this scheme may make it more expensive for businesses to operate in London, she
believes the benefits significantly outweigh any costs.
Caroline supports the DVS star ratings remaining separate. Use of technologies and training are important, DVS are
specific and integrating DVS with other measures in a single rating could prove confusing.
In relation to whether there are more components that should be included within a safe system Caroline would
suggest consideration of internal visual alerts and automatic emergency braking (when commercially viable).
While it is not formally the consultation Caroline highlights that TfL should revisit the possibility of restricting HGV
movements at certain times of day, perhaps for one or two hours before 9.00am. Such a policy could be combined
with a sensitively managed relaxing of some night-time restrictions on HGVs as successfully occurred during the
Olympic and Paralympic Games in 2012. The combination of this policy and the implementation of safer HGVs on
London roads could see a transformation in road safety standards for both cyclists and pedestrians.
Page 1311. London Borough of Brent (LB Brent) Summary
Stakeholder Response
Stakeholder Group: Local Authority
RESPONSE SUMMARY – EMAIL SUBMISSION
The London Borough of Brent (LB Brent) is supportive of TfL’s efforts to improve safety for VRUs and suggests that
consideration is given to the inclusion of other vehicles that are smaller than 12 tonnes in the scheme and private
passenger transport vehicles such as coaches to avoid a switch to smaller than 12 tonnes rather than modifying or
replacing their non-compliant HGVs. Whilst this could provide drivers with better visibility, this could result in an
increase congestion.
Whilst supportive of DVS, increased visibility is only part of the solution and emphasis should not only be on action by
HGV operators. VRUs have a responsibility to behave in a safe manner and to be aware of their surroundings. TfL
need to continue to promote increased awareness of road safety.
LB Brent commented on the lack clarity on the actual height thresholds and commented on the diverse nature of
London where over 18.5 per cent of the population are of Asian ethnicity but that no consideration has been given to
including this group particularly given that those of Asian ethnicity are generally shorter in height than Caucasians.
The minimum acceptable standard up to 2024 will permit vehicles that provide a low level of vision to be used. This
excludes the direct vision of young children and so it is questionable whether this is acceptable. LB Brent hopes to see
increased funding to boroughs to support road safety in schools to compensate.
LB Brent agrees with the principle of introducing the SPS as it includes other safety components in addition to the
DVS and strongly agrees with combining the DVS and the SPS.
Under the plans outlined, measures can be taken to allow a ‘zero star’ rated HGV to operate after 2020. This vehicle
would continue to be rated as ‘zero star’ but would be granted a permit if it can demonstrate operation of a safe
system. Therefore, what motivation is there for the operator to ensure that their vehicle meets a certain star rating and
has improved direct vision from the cab?
No illustrations are provided regarding visibility to the front or offside although two metres and 0.6 metres respectively
are given as ‘acceptable distances’ to meet a ‘one star’ rating. LB Brent would like to see more explicit information
given regarding the distances, until then they cannot comment if a “three star” rating would be acceptable.
LB Brent is concerned about the impacts of the scheme on SME’s who lease their vehicles. Lease contract periods
are fixed with replacement cycles meaning that businesses may not be able to react to changes. LB Brent would like
to see more information on options considered to support SMEs such as a ‘sunset period’, financial support to modify
non-compliant vehicles or presentation of a forward fleet replacement plan as evidence that vehicles will become
compliant.
Refuse collection vehicles (who are likely to be most impacted by DVS) often have a lengthy procurement cycles and
the phased timeframe proposed by TfL, although welcome, is likely to be too short for these vehicles to comply. New
vehicle designs take considerable time to develop and so for manufacturers, the timescales presented by the scheme
are likely to be too ambitious. They also do not allow the vehicle operators sufficient time to plan ahead.
Continued overleaf
Page 14LB Brent agrees that there is a need for the scheme to be flexible to respond to technological developments.
However, the freight industry is already contending with the T-Charge, ULEZ as well as proposals to extend LEZ from
2020. Large scale changes, require time to be implemented and a co-ordinated approach would ensure that freight
and fleet operators have more opportunity to comply.
LB Brent recognises that one of the Scheme’s greatest assets is its ability to influence HGV cab design. With sufficient
demand, vehicle manufacturers can respond to produce designs that have higher star ratings. The aim should be for a
single common DVS standard across the EU. Manufacturers have a minimum two year lead-time to change designs
so this could result in a shortage compliant models in the immediate term and the need for a greater number of HGVs
to be adapted to comply. Consideration needs to be given to the potential for this to result in higher prices for new
vehicles and retrofit equipment. No evidence has been provided as to whether there is sufficient retrofit equipment on
the market.
Table 1 of the document outlines examples of specific measures that could address safety issues with HGVs that are
ineligible to receive a permit: more detail is needed on levels of improvement. Could this mean that these “ineligible”
vehicles are actually ‘safer’ all round than ones that have a higher star rating as the latter solely focuses on driver
visibility whereas the former covers a broader remit?.
LB Brent questions whether urban driving skills should be included as one of these specific measures. Whilst driver
training is of vital importance to improving road safety, it is not a vehicle standard and so should potentially be
considered separate to the scheme.
LB Brent welcomes the proposal to ensure that the scheme covers all vehicles regardless of where they are
domiciled. It is vital that TfL puts in place a communication programme to ensure widespread dissemination of the
scheme to all relevant stakeholders.
It is key that enforcement is undertaken. It is vital that there is a consistent system for operators to find out their star
rating, specific actions they need to take to meet requirements and receive permits. LB Brent is supportive of a
method of enforcement that is stronger than used for the LLCS. LB Brent would like further details to be provided
regarding enforcement.
A DVS and the SPS will go some way to improving road safety in London. However, HGV safety is not only a London
issue and therefore TfL should lobby Central Government to consider a national scheme.
Page 1512. London Borough of Camden (LB Camden)
Summary Stakeholder Response
Stakeholder Group: Local Authority
RESPONSE SUMMARY – EMAIL SUBMISSION
The London Borough of Camden (LB Camden) strongly supports TfL’s proposed introduction of an SPS as part of the
DVS and acknowledges the significant body of work that underpins the second round of the consultation. The
applicability of the scheme to N3 category vehicles only is a particular concern as it results in a misalignment with
other initiatives such as the Safer Lorry Scheme (SLS) and CLOCs and the potential industry wide confusion
regarding the distinction between CLOCs and FORs.
LB Camden considers the approach being taken by TfL to establish the DVS is thorough and robust, however it
believes that further developments have raised a number of questions as to how the scheme will operate. The main
concerns relate to the very significant number of vehicle derivatives available and the limited way in which all of the
derivatives are then recorded by the DVSA. As a result they believe it makes it also almost impossible to identify an
existing vehicle using ANPR, making enforcement very challenging. In LB Camden’s view, this raises serious
questions over the viability and enforcement of a complex 5 tier system.
Whilst LB Camden recognises the rationale not to impose an outright ban, it feels there is a need for considerable
work into aftermarket safety equipment, particularly given the concerns around driver cognitive overload that can
result from too many in-cab systems.
The proposal to limit the scope of the standard to vehicles of greater than 12tonnes is not supported by Camden, as it
causes misalignment with the SLS and CLOCs. Camden’s own data analysis suggests that there are safety concerns
with vehicles in the N2 category (vehicles exceeding 3.5ton) as well, not just N3.
LB Camden supports the proposal for an SPS, however it raises concerns surrounding the complexities in establishing
which vehicles will be required to demonstrate the safety system approach, and the challenges with assigning each of
these with a star rating. They have concerns over the proposal to automatically issue safety permits to all vehicles with
1 star and above.
LB Camden believe that due to the relatively low cost to operators of complying with the safer systems approach, the
deadline to ban vehicles of 0 to 2 stars should be brought forward from 2024.
LB Camden agrees in principle with the conclusion of the TRL report in which option 5 – HGV Safety System scheme
is recommended, however they question the proposal to automatically issue a permit to all vehicles rated 1 star or
better from 2020 and vehicles rated 3 stars or better from 2024.
LB Camden does not support the proposal to enforce the scheme through the LLCS, at least initially, due to the lack of
data held by the DVLA relating to vehicle model type. They acknowledge that the LLCS is currently under review, and
amending the LLCS order to include the DVS could efficiently align timescales in a way that is beneficial for freight
operators. Acquiring powers jointly for both schemes has timescale risks. It raises an additional risk in that the
purposes of the LLCS and DVS have different purposes and could cause confusion as a result.
LB Camden’s response finished by including their response to the first consultation as an appendix.
Page 1613. London Borough of Hackney (LB Hackney)
Summary Stakeholder Response
Stakeholder Group: Local Authority
RESPONSE SUMMARY – EMAIL SUBMISSION
The London Borough of Hackney (LB Hackney) supports the introduction of a DVS that is fully consistent with existing
schemes such as FORS and CLOCS citing the example that CLOCS require recordable cameras even for low cab
vehicles.
They support the introduction of a safety standard permit but that is free of charge to operators and does not require
an annual renewal.
They support the timing of the DVS introduction in 2020, but raise concerns about the impact of not clearly defining
the standard in advance to allow operators to purchase vehicles to comply with the ULEZ and DVS at the same time.
LB Hackney initially expressed concerns about the phased introduction of a tighter standard in 2024, but they later
confirm they would welcome it.
Whilst they have no objection to the idea of combing the DVS and SPS to assess the overall vehicle safety, they
believe the standards in relation to driver training need to be kept separate from vehicle safety measures.
LB Hackney are concerned about the risks of implementing the scheme through the LLCS, due to a worry that
different standards will emerge in different regions.
LB Hackney likes the idea of enforcing the scheme through an ANPR camera system.
LB Hackney is concerned about the current premium (£25,000) on the newly designed low cabs, both for themselves
and their subcontractors.
LB Hackney would like financial assistance from TfL in order to help it invest in new vehicles to meet the DVS
standard, for example they have only recently invested in new mirrors and sensors and it feels this investment could
be wasted.
Their recommendation would be to see the introduction of the DVS standard to be introduced in line with the ULEZ.
Page 1714. London Borough of Enfield (LB Enfield) Summary
Stakeholder Response
Stakeholder Group: Local Authority
RESPONSE SUMMARY – PORTAL SUBMISSION
The London Borough of Enfield (LB Enfield) strongly agrees that the amount HGV drivers can directly see through the
cab’s windows plays a role in collisions with VRUs and should be improved to reduce HGV road risk. They agree with
the proposed star rating boundaries for vehicles under the DVS scheme. They also agree with the proposals to
introduce the proposed SPS, even if it may make it more expensive for businesses to operate HGVs in London.
LB Enfield agrees with a DVS rating of one star being set in 2020 as the minimum acceptable standard for HGVs to
operate in London without further safety measures and a DVS rating of three stars being set in 2024. They feel that
the DVS star ratings should be combined with the ‘safe system’ so that there is an overall safety rating for the vehicle.
LB Enfield strongly agrees that HGVs not meeting the above minimum star requirements should be required to
operate further safety measures to increase their safety and that such HGVs should be banned from operating in
London if unable or unwilling to do so. They also agree with the principles and way TfL proposes to approach setting
this ‘safe system’, along with the proposed measures being considered within the safe system.
LB Enfield feels that Local Authorities and Boroughs would best represent their views in identifying which measures
would meet the ‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera
system that will read number plates and check against a list of permits that have been issued.
Direct Vision should be considered as part of a wider package of measures to reduce HGV road danger and LB
Enfield agrees with the proposed method of implementation through the LLCS and enforcement through issuing
PCNs. to
Regarding setting up of a network of national testing centres for certifying vehicles, LB Enfield feels the most important
factors for TfL to consider include the cost to operator, simplicity of the test, time taken to complete the test, ensuring
that the testing is available across UK and Europe and ensuring that the standards being tested are consistent with
other tests. They also agree with the approach of TfL producing an online ‘look up’ tool which produces DVS ratings
once the height of the vehicle has been accurately measured.
Page 1815. Royal Borough of Kensington & Chelsea (RBKC)
Summary Stakeholder Response
Stakeholder Group: Local Authority
RESPONSE SUMMARY – EMAIL SUBMISSION
The Royal Borough of Kensington and Chelsea (RBKC) supports the concept of a ‘Vision Zero’ approach to road
casualties and the reduction of collisions involving VRUs. However, they express concern about the lack of clarity in
the proposal documents and feels that the scheme is no longer ambitious enough to reduce collisions, in particular the
fact that change to the scheme is no longer compatible with a Vision Zero approach as fewer lives will be saved
compared to the previously proposed outright ban.
RBKC highlights the experience they already have regarding driver training and other measures for mitigating risk as
outlined in the proposals and the fact that these have not decreased VRU collisions. They also note that there will be
enforceability challenges with less progressive hauliers and small business on the scale that the scheme would
require and while they recognise the cost implications of a more effective solution, they feel that the current proposals
do not strike the balance correctly. They feel that TfL could capitalise better on the proposed expanded ULEZ
proposals which will likely generate a large turn-over of vehicles.
RBKC suggests that TfL consider their original response regarding new lorry registration and the fact that new HGVs
registered from 2019 onwards should meet at least the 1-star standard in readiness for 2020, and new HGVs
registered after 2022 should be required to meet the 3-star rating
Page 1916. Westminster City Council Summary Stakeholder
Response
RESPONSE SUMMARY – PORTAL SUBMISSION
Westminster City Council (WCC) strongly agrees that the amount HGV drivers can directly see through the cab’s
windows plays a role in collisions with vulnerable road users and should be improved to reduce HGV road risk. They
agree with the proposed star rating boundaries for vehicles under the DVS scheme. They also agree with the
proposals to introduce the proposed HGV safety standard permit (SSP) scheme, however are unsure as to whether
that should make it more expensive for businesses to operate HGVs in London.
WCC, however, strongly disagrees with both a DVS rating of one star being set in 2020 as the minimum acceptable
standard for HGVs to operate in London without further safety measures and a DVS rating of three stars being set in
2024. They feel that the DVS star ratings should be combined with the ‘safe system’ so that there is an overall safety
rating for the vehicle.
WCC agrees that HGVs not meeting the above minimum star requirements should be required to operate further
safety measures to increase their safety and that such HGVs should be banned from operating in London if unable or
unwilling to do so. They also agree with the principles and way TfL proposes to approach setting this ‘safe system’ but
they disagree with the proposed measures being considered within the safe system: WCC agrees with all the
technical systems but strongly disagree with driver training. They feel this is a separate issue to vehicle safety and will
not be possible to manage vehicle compliance via CCTV.
WCC feels that independent operators would best represent their views in identifying which measures would meet the
‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera system that will
read number plates and check against a list of permits that have been issued.
WCC feel that DVS does not need to be considered as part of a wider package of measures to reduce HGV road
danger. WCC understands that the Safe System is being encouraged as a deliverable approach: they feel its
effectiveness will largely be determined by officers enforcing the London Lorry Control Scheme (LLCS) and therefore
agree with the proposed method of implementation through the LLCC and enforcement through issuing PCNs to
operators.
Regarding setting up of a network of national testing centres for certifying vehicles, WCC feels the most important
factors for TfL to consider include the cost to operator, ensuring that the standards being tested are consistent with
other tests and ensuring that no specific safety system manufacturer is specified but rather just the nature of the
system. They also feel that TfL should take cab design into account as the height of the cab alone is not enough. They
disagree with the approach of TfL producing an online ‘look up’ tool which produces DVS ratings once the height of
the vehicle has been accurately measured.
Page 2017. Association of International Couriers Summary
Stakeholder Response
Stakeholder Group: Trade Association
RESPONSE SUMMARY – EMAIL SUBMISSION
The Association of International Couriers (AICES) supports the Mayor’s objective to improve safety on London’s
roads, focusing particularly on pedestrians and cyclists.
AICES believes that the DVS, should be set at a national level rather than by individual cities as vehicle manufacturers
are not able to cater for the London Market alone. Instead, it would be better for the Mayor to work with the UK
government to agree on a national approach. It is extremely onerous for nationwide fleet operators to have to
potentially deal with a range of different solutions across the UK and internationally. AICES feels that the most
effective approach to achieve genuine improvements in road safety would be develop a pan-European approach,
working with the manufacturers and ensuring an international assessment of the respective benefits of the new
technologies being developed.
AICES supports the move to SPS but there needs to be greater clarity around the scheme components and certain
issues still remain to be addressed satisfactorily to ensure that the scheme is both as simplified and workable as
possible, including greater information on standards and the scope of the scheme.
The delay in publishing the standard for the star ratings is real cause for concern. Although there is now a route to
compliance via the SPS scheme, operators already procuring for 2020 and 2024 need full visibility of the ratings to
calculate business cases for vehicles.
AICES conclude that as responsible operators, their member’s take driving safety extremely seriously, investing in
measures such as driver training, new safety features on vehicles and improved operating practices.
Page 2118. Brewery Logistics Group (BLG) Summary
Stakeholder Response
Stakeholder Group: Trade Association
RESPONSE SUMMARY – PORTAL SUBMISSION
The Brewery Logistics Group (BLG) agrees that the amount HGV drivers can directly see through the cab’s windows
plays a role in collisions with VRUs and should be improved to reduce HGV road risk. They agree with the proposed
star rating boundaries for vehicles under the DVS scheme. While they agree with the proposals to introduce the
proposed SPS, they are unsure as to whether that should make it more expensive for businesses to operate HGVs in
London.
BLG agrees with a DVS rating of one star being set in 2020 as the minimum acceptable standard for HGVs to operate
in London without further safety measures but are unsure about a DVS rating of three stars being set in 2024. They
feel that the DVS star ratings should remain separate and focus on vision only and not combined with the ‘safe
system’ of the overall vehicle safety.
BLG agrees that HGVs not meeting the above minimum star requirements should be required to operate further safety
measures to increase their safety and that such HGVs should be banned from operating in London if unable or
unwilling to do so. They are unsure about the principles and way TfL proposes to approach setting this ‘safe system’,
as with the proposed measures being considered within the safe system.
BLG feels that HGV Manufacturers would best represent their views in identifying which measures would meet the
‘safe system’, and they also agree that the DVS Scheme would be best enforced through a camera system that will
read number plates and check against a list of permits that have been issued.
BLG feels that Direct Vision should be considered as part of a wider package of measures to reduce HGV road
danger but they do not agree with the proposed method of implementation through the LLCS and enforcement
through issuing PCNs to operators.
Regarding setting up of a network of national testing centres for certifying vehicles, BLG feels the most important
factors for TfL to consider include the cost to operator, simplicity of the test and ensuring that the tester should be
independent of TfL. They also agree with the approach of TfL producing an online ‘look up’ tool which produces DVS
ratings once the height of the vehicle has been accurately measured.
Page 2219. British Vehicle & Leasing Association (BVRLA)
Stakeholder Group: Trade Association
RESPONSE SUMMARY – PORTAL SUBMISSION
The British Vehicle Renting and Leasing Association (BVRLA) agrees that the amount HGV drivers can directly see
through the cab’s windows plays a role in collisions with VRUs and should be improved to reduce HGV road risk. They
strongly agree with the proposed star rating boundaries for vehicles under the DVS scheme and highlighted that they
do not believe that this is something which should be introduced only on a city-wide basis but the scheme should be a
national one, in order to ensure for consistency across cities and to avoid goods having to be re-loaded in different
HGVs due to inconsistent standards between cities. This is vital to the haulage sector. They also agree with the
proposals to introduce the proposed SPS, even if it may make it more expensive for businesses to operate HGVs in
London.
The BVRLA strongly agrees with a DVS rating of one star being set in 2020 as the minimum acceptable standard for
HGVs to operate in London without further safety measures and a DVS rating of three stars being set in 2024. They
feel that the DVS star ratings should remain separate and focus on vision only and not combined with the ‘safe
system’ of the overall vehicle safety.
The BVRLA strongly agrees that HGVs not meeting the above minimum star requirements should be required to
operate further safety measures to increase their safety and that such HGVs should be banned from operating in
London if unable or unwilling to do so. They also agree with the principles and way TfL proposes to approach setting
this ‘safe system’, along with the proposed measures being considered within the safe system.
The BVRLA feels that the DfT would best represent their views in identifying which measures would meet the ‘safe
system’, and they also agree that the DVS Scheme would be best enforced through a camera system that will read
number plates and check against a list of permits that have been issued.
The BVRLA agree that Direct Vision should be considered as part of a wider package of measures to reduce HGV
road danger. They do not have an opinion about proposed method of implementation through the LLCS and
enforcement through issuing PCNs to operators. While the BVRLA supports the proposals as part of making HGVs
safer in cities, they believe that the DVS system should be introduced as a national scheme, implemented and
enforced by the Department for Transport, not just a London-wide scheme.
Regarding setting up of a network of national testing centres for certifying vehicles, BVRLA feels the most important
factor for TfL to consider is consistency with other cities throughout the UK. They also agree with the approach of TfL
producing an online ‘look up’ tool which produces DVS ratings once the height of the vehicle has been accurately
measured.
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