Consultation Report
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Introduction of a Heavy Goods Vehicles Safety Standard as part of the Direct Vision Standard Consultation results June 2018 Contents 1 Introduction ...................................................................................................................... 1 2 Consultation methodology ............................................................................................... 2 3 Methodology for analysis of consultation responses ....................................................... 3 4 Analysis of responses to closed questions ...................................................................... 3 5. Analysis of responses to open question ........................................................................ 24 6 Responses from stakeholders ....................................................................................... 30 7 Next steps ..................................................................................................................... 31 Appendix A - Press advertisement ........................................................................................... 32 Appendix B – List of stakeholders consulted ............................................................................ 33 Appendix C – Stakeholder email .............................................................................................. 40 1 1 Introduction Between16 November 2017 and 24 January 2018, we consulted on proposals to introduce a Heavy Goods Vehicles (HGVs) Safety Standard Permit as part of the Direct Vision Standard (DVS) to reduce road danger. This forms part of the Mayor’s commitment to the adoption of a ‘Vision Zero’ approach. This document summarises the results of the consultation. About the proposals In 2016, HGVs were involved in disproportionately high numbers of fatal collisions with cyclists (50 per cent) and pedestrians (23 per cent) on London’s streets, despite only making up four per cent of road miles driven in London. HGV blind spots have been identified as a major contributory factor in these collisions. The DVS is intended to help address HGV driver blind spots. Using a star system, the standard rates HGVs from 0 (lowest) to 5 (highest), based on how much a HGV driver can see directly through their cab windows, as opposed to indirectly through cameras or mirrors. We previously consulted in early 2017 on the principles of a standard for Direct Vision. Listening to the feedback from this consultation, and working closely with industry and stakeholders we further developed the scheme. During the last phase of consultation, we sought views on proposals to introduce a Safety Standard Permit Scheme as part of DVS. This proposal widens our approach beyond direct vision and includes a safe system to allow a broader range of road danger risks to be addressed. The proposals in the latest consultation set out that: • All HGVs over 12 tonnes will be required to hold a Safety Permit to operate in Greater London from 2020. • HGVs will be given a rating between ‘zero-star’ (lowest) and ‘five-star’ (highest). • Only those vehicles rated ‘one star’ and above would be allowed to enter of operate in London from 2020. • Zero rated vehicles would only be allowed if they can prove compliance through safe system measures. • By 2024 only ‘three-star’ rated HGVs would meet the DVS star rating requirement for a Safety Permit. HGVs rated two star and below would need to demonstrate increased safety through progressive safe system measures to be granted permit. The safe system includes specific industry recognised measures such as camera monitoring systems, class V and VI mirrors, sensor systems with driver alerts, audible and visual warnings of intended manoeuvre and side under-run protection. The HGV Safety Standard Permit scheme would evolve over time, taking into account advances in technology. 1 About the consultation Questions were asked about the star rating system and boundaries between one to five stars. Further questions were asked about the HGV Safety Standard Permit and the proposals to set a one star standard in 2020 and three star standard in 2024. The consultation also asked for views on the principles of direct vision and associated impact on road risk. We also asked detailed questions relating to the development and operation of the scheme, including a number of open questions. The consultation ran from 16 November 2017 to 24 January 2018. Details of the proposals are available at www.tfl.gov.uk/direct-vision-standard About the results We received 2,498 responses to the consultation from the general public and 37 stakeholder responses. The responses were received either through the consultation portal, by email or by letter. Of the responses received, 91% agreed or strongly agreed that the amount a HGV driver can see directly through the cab’s windows plays a role in collisions with vulnerable road users and 92% of respondents either agreed or strongly agreed that the amount that drivers could see should be improved to reduce road risk. 79% of respondents either agreed or strongly agreed with the proposed star ratings boundaries and 88% of respondents either agreed or strongly agreed with the proposal to introduce a permit scheme. A more detailed analysis of the results is shown in the following chapters of this report. 2 Consultation methodology Who was consulted The consultation was open to all. Details of the scheme were available to view on the TfL consultation portal. TfL also wrote to a number of key stakeholders directly to seek their views. This included stakeholders such as London Boroughs and freight organisations. Please refer to Appendix B for a full stakeholder list and Appendix C for a copy of the stakeholder email. Consultation material, distribution and publicity To raise awareness of the consultation, we issued a press release which was also featured on the TfL website. 2 We also advertised in a number of pan-London and trade titles. Please refer to Appendix A. 3 Methodology for analysis of consultation responses We appointed an independent consultancy to undertake much of the analysis work on our behalf. This included all of the analysis for the general public including closed and open questions. They also reviewed all of the stakeholder responses and provided summaries of these. This analysis can be reviewed later on in this report. Analysis of closed questions The consultation questions were tailored in order to ascertain feedback on specific policy areas and proposals. All of the questions were open to anyone to respond. Analysis of open questions Code frames were developed to structure the analysis of responses to the open questions (questions 4, 14, 18 and 22). A code frame was developed to analyse comments broken down into themes. 4 Analysis of responses to closed questions This analysis includes 2,498 responses, consisting of responses received from the general public. Closed questions fell into two categories: • Questions which allowed only one response and were answered on a scale e.g. from strongly agree through to strongly disagree • Questions which allowed more than one option to be selected The responses were assessed against a percentage of responses. Note however, that the questions allowed multiple options to be selected, and do not therefore necessarily add up to 100%, as the options are not mutually exclusive. Question 1: To what extent do you agree or disagree that the amount a HGV driver can see directly through the cab’s windows plays a role in collisions with vulnerable road users? Respondents were asked whether they agreed that the amount a HGVdriver can see through the cab windows plays a role in collisions with vulnerable road users. Table/figure 1 shows that 91% agreed or strongly agreed with this concept. 4% of respondents stated that they neither agree or disagree. 3 Table 1: Vision impacts on collisions with vulnerable road users Opinion Number of responses % Strongly agree 1,883 75% Agree 401 16% Neither agree or disagree 90 4% Disagree 74 3% Strongly disagree 44 2% Not answered 7 0% Total 2,498 100% Figure 1: Vision impacts on collisions with vulnerable road users To what extent do you agree or disagree that the amount a HGV driver can directly see through the cab’s windows plays a role in collisions with vulnerable road users? 2000 1800 1600 1400 1200 responses 1000 of 800 600 Number 400 200 0 Strongly agree Agree Neither agree or Disagree Strongly disagree Not Answered disagree Opinions Question 2: To what extent do you agree or disagree that the amount a HGV driver can directly see should be improved to reduce HGV road risk? Respondents were asked if they agree whether the amount a HGV driver can see directly should be improved to reduce HGV risk. Table/figure 2 shows that 92% of respondents either agreed or strongly agreed with this this idea. 4% of respondents either disagreed or strongly disagreed. 4 Table 2: Improve amount that can be seen by HGV driver to reduce HGV risk Opinion Number of responses % Strongly agree 1,987 80% Agree 311 12% Neither agree or disagree 96 4% Disagree 64 3% Strongly disagree 35 1% Not answered 5 0% Total 2,498 100% Figure 2: Improve amount that can be seen by HGV driver to reduce HGV risk To what extent do you agree or disagree that the amount a driver can directly see should be improved to reduce HGV road risk? 2000 1800 1600 1400 1200 responses 1000 of 800 600 Number 400 200 0 Strongly agree Agree Neither agree or Disagree Strongly disagree Not Answered disagree Opinions Question 3: To what extent do