Consultation outcome

Temporary increases to weight limits for fuel tankers during periods of fuel supply disruption: government response

Updated 2 April 2024

Background

Following disruption to fuel supplies in autumn 2021, the Department for Transport (DfT) and the Department for Business and Trade (DBT) set out a proposal to allow road fuel tankers to temporarily operate at weights higher than usually permitted to enable more fuel to be transported.

The proposal would only permit fuel tankers to operate at increased weights of up to 48 or 50 tonnes (not exceeding maximum permitted GB axle weights or the design train weight of the vehicle) during periods of potential or acute fuel supply disruption, with certain route approval and vehicle equipment conditions applying.

A total of 47 responses were received during the consultation period – 15 were from individuals and 32 were on behalf of organisations. The following table shows the breakdown of the types of organisations that responded to this consultation. Figures are based on organisations that provided a response to the question about organisation type.

Response	Number of responses	% of number of responses
Fuel haulier or operator	2	4.26
Government body	1	2.13
Local authority	14	29.79
Private company	1	2.13
Trade association	4	8.51
Trade union	0	0
Infrastructure owner	3	6.38
A small business (10 to 49 full-time equivalent employees) or micro business (fewer than 10 full-time equivalent employees)	0	0
Another type of organisation	2	4.26

The consultation document presented the proposed change, including conditions associated with the change, and invited responses on the suitability of the proposals. Many respondents provided direct questionnaire responses submitted to DfT, either through the online survey platform or by email. Outside of direct questionnaire responses, position papers were also received. These data sources have been analysed to provide the quantitative summary tables within this document. DfT also carried out detailed analysis of the qualitative responses to assess the suitability of the proposals.

Following the consultation period, DfT obtained, in one-to-one discussions, further views from fuel tanker operators and hauliers, due to the low response rate for this group to the consultation. The questions posed, and views expressed, during this further engagement cannot be accurately ‘mapped’ onto the consultation questionnaire. However, the feedback received has been considered as part of the wider analysis and appraisal of the proposals. DfT thanks all respondents for their contribution.

Respondents were generally supportive of the key policy proposal when asked in terms of an agree/disagree question. Forty-two per cent of respondents agreed with the proposal, 28% did not and 23% were unsure.

Among fuel tanker operators, the post-consultation engagement was met with support for the proposal in principle. However, there was reluctance from most to make use of the permitted weight increase if it became available. The reasons offered for this were:

• a lack of vehicles with a design weight of 48 or 50 tonnes within existing fleets
• the outlay associated with increased maintenance and insurance costs
• the possibility that the vehicles are unlikely to be used in times of no shortage or would be used with reduced payloads

Regarding the technical aspects of the proposals, such as the proposed mechanism by which road movements at higher weights would be permitted and vehicle conditions, responses were varied.

There was general acceptance of all mitigation measures suggested for the vehicles themselves, including decreases in operating speeds and vehicles being equipped with specific braking and stability systems. These were deemed appropriate by a majority of respondents. 

However, there were mixed views regarding the use of:

• the Electronic Service Delivery of Abnormal Loads (ESDAL) system to approve routes
• Vehicle Special Orders (VSOs) to approve vehicles

Forty per cent felt the proposals to use ESDAL and VSOs were suitable, while 37% thought they were not. However, when specifically asked if the suggested 4-week time frame for permitting higher weights through VSOs was acceptable, 52% agreed while 17% did not.  

In light of these conclusions, the government intends to progress this policy proposal for use in times of fuel supply shortage. This would be in addition to measures already available, such as:

• relaxing limitations on fuel tanker drivers’ hours
• deploying the UK reserve tanker fleet
• deploying military tanker drivers to supplement civilian drivers

The exemption will be temporary, lasting no longer than 4 to 5 weeks at a time, as proposed. At this time, no plans exist to make the exemption to the maximum permissible weight limit a permanent change.

Implementing the proposal requires changes to legislation, therefore, government will seek legal powers to make the necessary changes when Parliamentary time allows. As this policy has an impact on local authorities (LAs), in due course, the relevant departments within government will make further assessments of the funding required as part of the new burdens doctrine to ensure net additional cost of the measure is properly funded.  

Consultation outcome

Views on the temporary increase in fuel tanker weights

We will focus on the responses to the main proposal of temporarily permitting the maximum train weight for 6-axle articulated road fuel tankers of 44 tonnes to be exceeded to allow a maximum of up to 50 tonnes when fuel supply is threatened. The questions targeted at specific respondents are covered later.

Response	Number of responses	% number of responses
Agree	20	47%
Disagree	12	28%
Don’t know	10	23%

In response to questions 36 and 37 of the consultation, which asked whether respondents agreed with the proposal to increase tanker weights and why, 20 respondents agreed with the proposal, 12 did not and 10 did not know if they agreed with the proposals. There was, therefore, no unanimity among respondents on whether they supported this proposal. Of these responses, the 2 organisations defining themselves as fuel tanker operators answered ‘disagree’. A third organisation, which defined itself as a private company but was involved in follow-up discussions held with fuel tanker operators, responded ‘don’t know’.

The views expressed by those disagreeing noted concerns over infrastructure, increased road damage and detrimental effects on road safety. The potential inability of fuel garage infrastructure to host larger vehicles and take larger fuel deliveries was another commonly noted theme. Other issues included:

• increased administrative burden on hauliers
• time and cost to train drivers sufficiently
• insurance complications
• the complexity of understanding authorised combinations
• the time to approve routes
• drivers taking wrong routes or diversions
• the concerns around exceeding maximum axle weights, accelerated wear and tear on vehicles

Some respondents suggested it would be more beneficial to improve heavy goods vehicle (HGV) wages and welfare provisions or to look at driver hour derogations to reduce the strain on supply chains. Some also expressed concern that the exemption would be elongated or expanded to other sectors of the industry, for example, food deliveries. This is not within the scope of the current consultation. 

Fuel tanker hauliers and operators

Following the consultation, DfT held one-to-one discussions with 5 fuel tanker operators to better understand their opinions on the proposed policy. This was due to the low turnout of fuel tanker operators during the consultation.

During the consultation, the 2 responses from fuel tanker operators were negative, citing issues with speed limits. However, in the one-to-one discussions, overall, the operators did not express disagreement with the policy being implemented. There was an overarching theme across the operators regarding the lack of vehicle combinations having a design capability for operation above 44 tonnes.

To take full advantage of the provision, operators would need to invest in tractor units having a design train weight above this limit, but this would result in tractor units having a higher weight, reducing their payload during normal operation at 44 tonnes. Some said there may be a possibility to procure these units. However, they indicated it would be a commercial decision and would, in some cases, be dependent on benefits seen from other operators using the provision, suggesting that an immediate switch to higher-rated vehicles is unlikely.

There was also concern that using the provision would mean:

• increased maintenance and insurance costs
• that the vehicles may struggle to operate at more than 44 tonnes due to engine power issues
• that it may be unsafe to exceed design weights
• that there may be issues surrounding driver compliance with reduced speeds
• that forecourts may not be able to accept the increased load
• increased administrative burden from the notification requirements for route approvals

Barriers

When asked whether there were fundamental barriers to road fuel tankers being permitted to operate at a maximum of 50 tonnes during periods of fuel supply disruption and what these were, the breakdown of responses was as follows.

Response	Number of responses
Yes	14
No	16
Don’t know	2

Respondents who selected ‘yes’ were then asked to select as many barriers as they felt existed from the provided options. The other reasons given, of which there were 6, are covered under Question 21. The most commonly selected barrier was ‘infrastructure concerns’, for example, the ability of bridges to take the additional loads being placed upon them. This was followed by ‘concerns over safety’, for example, the effect on braking distances as it impacts safety.

Response	Number of responses
Concerns over safety	6
It would not make a significant difference to fuel supply	4
Advantage over other fuels or industry	2
Concerns over impact on infrastructure	11
Process to complex	3
Concerns over enforcement	6

Views on conditions associated with increased tanker weights

Route approvals

The proposal was that operators wishing to make use of the ability to run tankers weighing over 44 tonnes during periods of fuel supply disruption would be required to have routes approved in advance, using either the ESDAL system or other methods such as email, in the same way as abnormal indivisible load movements currently do.

LAs and infrastructure owners were specifically asked for their views on the ESDAL system. Questions revolved around resource implications if a large number of approvals were submitted at short notice. When asked whether LAs and infrastructure owners had the capacity to process 100 extra ESDAL notifications within the current 2-day time period afforded to abnormal indivisible load movements, 3 respondents stated they would need additional staff, compared to 5 who currently said they had enough staff. Furthermore, if a route was rejected, 6 respondents said they would advise applicants on alternative routes while 6 would not.

The responses provide a mixed view of ESDAL and its impact on LAs and infrastructure owners. Some organisations said they would need new full-time staff, indicating this would be between 0.5 to 3 full-time employees, on the basis of 100 extra ESDAL approvals per month. However, the possibly low take-up of the intervention by operators (as covered above), suggests 100 extra ESDAL approvals could be more than actually required in practice.

Vehicle conditions and speed limits

The proposals included a requirement for fuel tankers seeking to use the exemption to be fitted with certain systems and to travel at lower speeds. These systems included being fitted with specific braking systems and stability functions as well as not being permitted to travel in excess of 40 mph on single carriageways and 50 mph on dual carriageways.

On the question of the suitability of vehicle systems suggested, excluding those who did not know (possibly because they were unfamiliar with the system in question), the majority of respondents felt the measures were suitable, with only 2 safety features receiving 2 ‘unsuitable’ responses.

Safety feature	Suitable	Unsuitable	Don’t know
Advanced emergency braking systems for road fuel tankers	11	2	19
Anti-lock braking systems for road fuel tankers	14	0	17
Vehicle stability functions for road fuel tankers	12	2	18

With regards to the new speed limitations suggested, ‘appropriate’ was the most selected single response for the proposed 40 mph limit on single carriageways. Additionally, ‘appropriate’ was also the most selected single response to the proposed 50 mph limit on dual carriageways.

Summary of responses

This section of the report gives a summary of the consultation questionnaire responses. Where applicable, the question numbering from the consultation document has been used here. The ordering of questions is different to that within the consultation document so as to group questions dealing with similar matters together.

Information on respondents

How are you responding?

Response	Number of responses	% number of responses
As an individual	15	31.91
On behalf of an organisation	32	68.09
Grand total	47	100

Organisational details

Your organisation is best described as:

Response	Number of responses	% of number of responses
Fuel haulier or operator	2	4.26
Government body	1	2.13
Local authority	14	29.79
Private company	1	2.13
Trade association	4	8.51
Trade union	0	0
Infrastructure owner	3	6.38
A small business (10 to 49 full-time equivalent employees) or micro business (fewer than 10 full-time equivalent employees)	0	0
Another type of organisation	2	4.26

How many employees are there in your organisation?

Response	Number of responses
1 to 9	1
10 to 49	0
50 to 249	2
More than 250	19

How many companies do you represent?

Response	Number of responses
0	3
1 to 9	15
10 to 49	2
50 to 249	0
More than 250	2

Questions on ESDAL for LAs and infrastructure owners only

The consultation explained the process of route approvals through the ESDAL system, administered by National Highways. Hauliers would register on this system and submit their intended routes and vehicle information (including axle weights and spacings). This information would be passed to affected road and bridge authorities. For vehicles weighing up to 50 tonnes, affected authorities would have a 2 working day window to object or suggest an alternative route. The consultation asked specific questions related to processing times for route approvals.

Q1. Do you currently process ESDAL notifications?

Response	Number of responses
Yes	12
No	3
Don’t know	1

Q2. How do you currently process ESDAL notifications?

Response	Number of responses
Manually	5
Automatically (computerised process, no staff involvement)	0
Via third party	6
Combination of manually and automated	2
Don’t know	1

Q3. On average, how many minutes does it take you to process one of these notifications submitted via ESDAL?

Response	Number of responses
2 minutes	2
5 minutes	5
Under 5 minutes	1
20 minutes	1
10 minutes for special types general orders (STGO) vehicles, 45 mins for special orders (SO) vehicles	1
Response removed as illegible (% value was only provided)	1
Don’t know	3

Q4. If an ESDAL notification is rejected, are you involved in advising applicants on alternative routes?

Response	Number of responses
Yes	6
No	6
Don’t know	2

Q5. On average, how long does it take to process an ESDAL notification if a route has to be altered from the original request (for example, the original route was not suitable)?

Response	Number of responses
2 minutes	1
5 minutes	3
8 minutes	1
10 minutes	2
10 to 45 minutes	1
60 minutes	1
Don’t know	1

Q6. In your opinion, would you currently have the capacity to be able to process up to 100 of these types of extra ESDAL notifications within 48 hours?

Response	Number of responses
We currently have the capacity within existing staff and time	5
We would need additional staff	3
We would need additional time to process notifications	2
We would need additional staff and time to process notifications	1
Don’t know	2

Q7. How many additional staff, in full-time staff amounts, would you require?

Response	Number of responses
1	2
0.5 or overtime for existing staff	1
2 to 3 full-time employees or staff diverted from other work	1

Q8. How many extra hours would you require?

Response	Number of responses
4 hours	1
40 hours	1
25 to 40 hours	1

Q9. On average, how many staff are involved in processing ESDAL notifications?

Response	Number of responses
1 person	9
2 people	1
4 people	1
More than 4 people	1
Don’t know	1

Q10. On average, how many notifications submitted via ESDAL do you currently process per week?

Response	Number of responses
1	1
2	1
128	1
136	1
190	1
550	1
1,300	1
Don’t know	1
Over 1,000 from 4 areas of the country	1
137	1
80	1
71	1
118	1

As can be seen, of the responses received, answers varied significantly between 1 and 1,300 in regard to how many ESDAL notifications were currently processed each week. The 4 email responses received expressed that the majority of their notifications (between 66.89% and 78.3%) were submitted via AbHaulier (an alternative system to ESDAL) and a small proportion were processed manually (between 1.54% and 20.7%).

Questions on costs and exemption take-up for fuel tanker hauliers and operators only

Q11. In your view, is it reasonable or unreasonable to assume that the average journey per fuel tanker trip is 56 miles?

Response	Number of responses
Reasonable	0
Unreasonable	2
Don’t know	0

Q12. What, in your view is the average length of a fuel tanker journey in miles?

Response	Number of responses
Less than 30 miles	0
30 to 60 miles	0
60 to 100 miles	2
100 to 150 miles	0
More than 150 miles	0

Q13. What, if any, contextual information can you provide for us to develop a better estimate?

No response was provided for this question.

Q14. What do you charge to transport fuel using a fuel tanker?

One response was received to this question and the answer was £4.50.

Q15. DfT anticipated that the cost of one administrative officer to send a single route submission to a single LA to be between £1.50 to £3 based on the time cost associated with submitting routes for approval. In your view, is this a reasonable or unreasonable figure?

Response	Number of responses
Reasonable	0
Unreasonable	1
Don’t know	1

Q16. What do you suggest is a likely cost figure?

Response	Number of responses
Less than £1.50	0
More than £1.50 but less than £3	0
£3 to £4.50	0
More than £4.50	1

Q17. Why do you suggest this is a likely cost figure?

The one reason provided was in relation to a sum of £4.50 and was based on paying an external transport planner to make the submissions.

Q18. Do you charge companies on a: pence per mile value, pence per litre value or a combination of both?

Response	Number of responses
Pence per mile	1
Pence per litre	0
A combination of both pence per mile and pence per litre value	0

Q19. What amount or amounts do you charge?

The one respondent to Q18 did not provide the amount they charged. However, one fuel tanker haulier noted that they charged set rates to customers in advance based on how long an established route would take, accounting for historic route speeds. They went on to state that it is not easy to change rates on an ad-hoc basis once agreed.

Q20. Do you currently own tankers which could operate at a higher than 44 tonne weight, if this proposal is implemented?

Response	Number of responses
Yes	1
No	0
Don’t know	1

Q21. Would you utilise this exemption in periods of fuel supply disruption?

Response	Number of responses
Yes	0
No	1
Don’t know	0

Q22. Why would you not use this exemption in periods of fuel supply disruption?

Of direct responses to the questionnaire, the one response received was negative towards the proposals noting issues with insurance complications, the design weight of axles, additional wear and tear on the vehicle and driver training considerations.

Q23. Do you expect the use of this exemption to impact your insurance cover?

Response	Number of responses
Yes	1
No	0
Don’t know	0

Q24. How do you expect the use of this exemption to impact your insurance cover?

The reason the respondent provided was that their current policy was based on operating at 44 tonnes. 

Outside of direct responses to the questionnaire, the issue of insurance was also covered by a prominent insurance provider in a position paper supplied to DfT. It recognised the rationale behind the policy but noted that before its customers could make use of the exemption with adequate insurance cover, it would have to amend its policy offering. This may include reducing the limit of indemnity and/or charging an additional premium to reflect increased exposure. The respondent stated that the proposals would also require amendments to internal processes and reinsurance contracts, which would require a reasonable notice period before implementation.

Q25. If you were to use this exemption, would you operate tankers at their maximum capacity?

Response	Number of responses
Yes	0
No	1
Don’t know	0

Q26. What is the reasoning behind your answer to Q25?

The one respondent who provided a ‘No’ response to Q25 said they would not load to maximum capacity as this may result in a gross weight excess of proposed limits subject to the product density.

Q27. As you currently have no tankers with a design weight greater than 44 tonnes, would you expect to renew your fleet in the future with higher design weights to make use of this exemption?

No responses were recorded to this question.

Q28. What is the reasoning behind your answer to Q27?

No responses were recorded to this question.

Q29. At what rate will you change your fleet and to what design train weight?

No responses were recorded to this question.

Q30. We are assuming that tankers complete only one trip, without additional drop-offs, to load and unload the total contents of their tank. In your view, is this a reasonable or unreasonable assumption?

Response	Number of responses
Reasonable	1
Unreasonable	1
Don’t know	0

Q31. What is the reasoning behind your answer to Q30?

The respondent to Q30 who noted the assumption was unreasonable stated that they frequently deliver split loads to 2 or 3 locations.

Q32. How long, in minutes, does it take to fully load and unload a fuel tanker?

 To load:

Response	Number of responses
About 20 minutes	1
30 minutes	1

 To unload:

Response	Number of responses
About 45 minutes	1
60 minutes	1

Q33. In your view, if a speed restriction is introduced for fuel tankers, operating at weights of up to 50 tonnes, would you be likely or unlikely to use the exemption?

Response	Number of responses
Likely	0
Unlikely	1
Don’t know	1

Q34. What is the reasoning behind your answer to Q33?

The respondent to Q33 who would be unlikely to utilise the exemption stated that the speed limits would not counteract the increased road safety concerns they believe the weight increase would create.

Q35. What, if any, sources of reference material can you provide that can help monetise particular costs or benefits associated with the weight limit increase of fuel tankers?

From the 2 responses to this question, one respondent suggested using bridge records and structural assessment inspections. The other suggested that if the exemption were to be used it would cause:

• increased cost to the haulier due to increased administration
• risk assessments
• time to train and brief drivers
• reduced miles per gallon
• diversionary mileage

Follow-up engagement: Fuel tanker operators

Following the consultation, DfT chose to hold one-to-one discussions with 5 fuel tanker operators to better understand their opinions on the proposed policy given the low response rate recorded as part of the consultation period.

These fuel operators had around 1,500 vehicle combinations in operation. Only one of these operators said they would make use of the exemption if implemented.

Overall, the operators spoken to did not express any objections to the measure being introduced. However, only 1 out of the 5 would potentially make use of it with the other 4 not taking it up even if it was legal to do so. The following reasons were given for this.

The lack of current vehicles able to operate at the increased weights. Additionally, in some cases, operators advised they may not look to make the investment into vehicles with a higher design weight because they would incur weight penalties when the short-term exemptions ceased, making everyday operations less efficient due to reduced payload.

The concern is that the efficiencies made by the exemption would be minimal for fuel supply in general and incur potentially greater cost to them.

While most operators accepted the need for conditions, such as speed limits to ensure safety, one operator highlighted that the speed restrictions would outweigh any efficiencies gained by running at higher weights.

A number of operators also expressed the view that higher weights would mean more maintenance being required, with one highlighting the potential need to recalibrate loading gantries to ensure any revised weight limits were not exceeded. 

The ability of infrastructure to handle increased weights – for example, the ability of forecourts to accommodate higher-weighted vehicles – was a point raised, with one operator suggesting that if they did make use of the exemption, it would only be to service motorway fuel stations due to concerns over local roads.

An inability to deliver fuel was another worry. Two operators were concerned that vehicles in their current fleet with a design weight of 44 tonnes would struggle to operate at more than 44 tonnes even if permitted to do so due to a potential lack of engine power.

Questions for all on the key proposal

The consultation set out the specifics of the proposal to temporarily permit exemptions from the current maximum train weight for 6-axle articulated road fuel tankers of 44 tonnes, in order to allow a maximum of up to 48 or 50 tonnes when fuel supply is threatened for periods of around 4 to 5 weeks. Maximum axle weight limits would remain unchanged and vehicles would not be allowed to operate at weights above their maximum design train weight. This would only be applicable to road fuel tanker vehicles equipped with specified safety features carrying petrol and diesel to fuel distribution centres, retail forecourts and operator depots that make use of fuel bunkers. Domestic fuel deliveries would not be in scope. The following questions asked for views on this.

Q36. Do you agree or disagree with the proposal?

Response	Number of responses	% Number of responses
Agree	20	42.55
Disagree	12	25.53
Don’t know	10	21.28

Among total responses to the questionnaire (not accounting for views expressed in the one-to-one meetings), 20 respondents agreed with the proposal, compared to 12 respondents who disagreed. Furthermore, when these responses were broken down into respondent type, no fuel tanker operator/haulier agreed with the proposals.

Q37. What is the reasoning behind your answer to Q36?

When asked to explain their viewpoint, of those who agreed, one respondent said they believed the proposal had the potential to make the UK downstream sector more resilient. Two respondents caveated their agreements, stating they would be supportive subject to the reimbursement of costs, that the benefits to the economy outweigh the risks and that the administrative burden was minimal. Other responses included noting general support and one respondent confirmed support but noted concern over infrastructure.

Alternatively, where respondents disagreed, the most noted issues with the proposal included concerns over infrastructure, increased road damage and road safety. The potential inability of fuel garage infrastructure to host larger vehicles and take larger fuel deliveries was another commonly noted theme. Other issues included:

• increased administrative burden to hauliers
• time and cost to train drivers sufficiently
• insurance complications
• the complexity of understanding authorised combinations
• the time to approve routes
• problems around exceeding maximum axle weight
• accelerated wear and tear on vehicles
• drivers taking wrong routes or diversions

Some respondents said it would be more beneficial to improve driver wages and welfare provisions or to look at driver hour derogations to reduce the strain on supply chains. Some also expressed concern the exemption would be elongated or expanded to other sectors of the industry, for example, food deliveries.

Q38 dealt with signposting respondents to relevant parts of the consultation and, therefore, does not provide views on the proposals. Questions 39 to 45 are dealt with later in this report under cost analysis.

Q46. In your view are there any fundamental barriers to road fuel tankers being permitted to operate at a maximum of 50 tonnes during periods of fuel supply disruption?

Response	Number of responses	% Number of responses
Yes	14	29.79
No	16	34.04
Don’t know	2	4.26

Q47. Your assumed barriers are:

Reasons provided for barriers	Yes
Concerns over safety	6
It would not make a significant difference to fuel supply	4
Advantage over other fuels or industry	2
Concerns over impact on infrastructure	11
Process too complex	3
Concerns over enforcement	6

Of the 14 respondents who stated there were fundamental barriers, the most selected reason was concerns over the impact on infrastructure, followed by concerns over safety.

The consultation received 5 responses outlining further barriers to the use of vehicles permitted to operate up to 50 tonnes. These included:

• available resources to approve routes
• the introduction of risk through relying on one-off approvals
• increased wear and tear to vehicles
• concern over minimal benefit from implementing the exemption
• the benefit would be too small given the transition to alternative fuels

Questions for all on the conditions associated with the use of the exemption

Q48. Respondents were asked to advise whether the following proposed safety features would be suitable or unsuitable for operating at weights exceeding 44 tonnes?

Safety feature	Suitable	Unsuitable	Don’t know
Advanced emergency braking systems for road fuel tankers	11	2	19
Anti-lock braking systems for road fuel tankers	14	0	17
Vehicle stability functions for road fuel tankers	12	2	18

If unsuitable, respondents were asked to state why. There were 7 responses to this question, which included responses from people who felt the safety features were suitable or didn’t know. The reasons given are shown in the following table:

Response	Number of responses
Features haven’t been tested by drivers in real time	2
Features would make vehicle too heavy	1
Insufficient information to evaluate	1
Insufficient expertise to evaluate	1
Features not unsuitable but not needed	1
Features should be introduced to all fuel tankers on the road	1

Q49. Should fuel tanker operators clear their movements in advance with LAs using the ESDAL system, email or another method?

DfT proposed that fuel tanker operators wishing to operate vehicles weighing over 44 tonnes during periods of fuel supply disruption are required to clear movements in advance using the ESDAL system or other methods such as email.

Of 29 respondents, the majority (16) expressed ESDAL to be their preferred method. The second preferred method was via AbHaulier. One respondent suggested email and one expressed a preference for multiple systems to be adopted simultaneously.

Q50. In your view, would it be appropriate or inappropriate for the heavier fuel tankers to be subject to speed limits of 40 mph on single carriageways?

Response	Number of responses
Appropriate	16
Inappropriate	10
Don’t know	7

Q51. What speed limit, in your view, should the heavier fuel tankers be subject to on single carriageways?

Response	Number of responses
No change	8
Below 40 mph	2

Q52. In your view, would it be appropriate or inappropriate for the heavier fuel tankers to be subject to speed limits of 50 mph on dual carriageways?

Response	Number of responses
Appropriate	20
Inappropriate	5
Don’t know	8

Q53. What speed limit, in your view, should the heavier fuel tankers be subject to dual carriageways?

Response	Number of responses
No change	4
Below 50 mph	1

Questions for all on the process of permitting heavier fuel tankers on road

The proposal suggested the use of VSOs as the mechanism to approve the use of increased-weight fuel tankers at times of fuel supply disruption. The proposed timeframe for the validity of VSOs would be 4 to 5 weeks.

DfT proposed that the issue of VSOs would involve ministers confirming that there was a fuel supply issue. Following this, officials would write to hauliers to let them know they could start to submit routes to ESDAL. In the meantime, upon receipt of ministerial approval, VSOs would be prepared and issued. Heavier fuel tankers would not be permitted to operate until the VSOs were issued.

Q54. Is this, in your view, a suitable or unsuitable method for approving the use of increased-weight fuel tankers?

Responses	Number of responses
Suitable	14
Unsuitable	13
Don’t know	8

Q55. What is the reasoning behind your answer to Q54?

There were 14 responses to this question. The most common reasons for the process being unsuitable included concern over hauliers being mandated to use ESDAL, increased administrative burden and availability of staff to approve routes during a crisis. Other comments included the approval time being too long, meaning routes would not be approved fast enough to react to crises.

Q56. In your view, is the suggested timeframe of 4 weeks for the validity of VSOs permitting increased-weight fuel tankers appropriate or inappropriate?

Response	Number of responses
Appropriate	18
Inappropriate	6
Don’t know	10

Q57. What is the reasoning behind your answer to Q56?

Of the 7 responses to this question, 6 replied ‘inappropriate’ to the 4-week period in Q56. Two of these 6 suggested that 6 weeks would be a more suitable timeframe. Others suggested:

• the timeframe was too long
• the timeframe would not allow enough time for businesses to brief drivers
• that the use of VSOs was inappropriate
• it could put small hauliers at risk

Q58. In your view, is the suggested activation process for issuing VSOs appropriate or inappropriate?

Response	Number of responses
Appropriate	14
Inappropriate	11
Don’t know	9

Q59. What is the reasoning behind your answer to Q58?

Of the 10 responses received, most said that hauliers should not be mandated to use ESDAL. Some responses commented that the intervention should not go ahead and that VSOs were inappropriate. A further response suggested VSOs were inappropriate unless routes were agreed ahead of time. Other responses included concerns over burdens on LA staff and insufficient time to brief drivers.

Questions for all on DfT’s vehicle safety assessment

DfT’s vehicle safety assessment identified possible effects on vehicle braking distances, energy of impacts and vehicle roll-over as a result of the exemption. The mitigations proposed for the identified risks were to decrease the operational speed permitted and require vehicles to be fitted with advanced emergency braking systems, anti-lock braking systems and vehicle stability functions.

The ‘infrastructure safety assessment’ considered the effects of heavier fuel tankers on structures carrying traffic (such as bridges). It specifically considered:

• vertical bending and sheer load effects
• braking and acceleration with centrifugal load effects
• general wear and tear

The risk element of the study investigated the additional risk to the affected population and the risk to infrastructure on the strategic road network (SRN) of accidents involving heavier fuel tankers.

Q62. In your view, has the vehicle safety assessment accurately or inaccurately identified the risks that may arise?

Responses	Number of responses
Accurately	19
Inaccurately	4
Don’t know	9

Q63. If your response to Q62 is ‘inaccurately’, why is it inaccurate and what additional risks, if any, do you think should be considered?

There were 4 responses to this question. Suggestions included consideration of the:

• local roads network, driver training, axle weights and how to avoid errors in vehicle combinations
• impact on utility assets such as iron works, chambers and ducts

Q64. Respondents were asked to decide whether the following mitigation measures were appropriate or inappropriate.

Mitigation reason	Appropriate	Inappropriate	Don’t know
Decreasing operation speed	19	5	7
Advanced emergency breaking	16	2	13
Anti-locking braking systems	19	1	11
Vehicle stability functions	19	1	11

Q65. If you answered ‘inappropriate’ to Q64, give your reasons why.

The 6 respondents provided reasons for the inappropriateness of mitigation measures in general, rather than specific to a particular measure. Of those who previously answered inappropriate to Q64, 2 respondents suggested the mitigation measures were not necessary as drivers would have the necessary skills and experience. One respondent said the policy should not be introduced and another noted decreasing road speeds for heavier fuel tankers could cause road safety issues if other drivers took greater risks – for example, overtaking – or greater congestion and tailbacks.

Q66. In your view, does the infrastructure safety assessment correctly or incorrectly identify the additional infrastructure safety risks of increased-weight road fuel tankers?

Response	Number of reasons
Correctly	13
Incorrectly	8
Don’t know	11

Q67. What is the reasoning behind your answer to Q66 and what other infrastructure safety risks should be included or removed?

The 8 respondents proposed that the assessment should additionally include:

• the experience of sites taking delivery
• whether drains and bridges could take the additional weights
• considerations around enhanced vehicle restraint systems
• the impact on the local roads network and road damage affecting other road users

Questions for all on cost analysis

The consultation provided the list below giving a summary of the costs and benefits associated with the increase in the permitted weight of fuel tankers:

Costs

To businesses:

• familiarisation costs of recovery and route submission schemes
• additional fuel costs of running heavier tankers
• increased tanker loading and unloading times
• increased road wear and tear
• potentially changed insurance premiums

Other costs:

• possible increase in greenhouse emissions (per tanker)
• costs associated with approving routes for local authority roads and highways

Benefits

To businesses:

• increase in fuel tanker efficiency
• decreased cost of fuel transportation

Other benefits:

• the possible reduction of the impact associated with fuel supply disruption

Q39. In your view, does the list above correctly or incorrectly identify all costs and benefits of the use of increased-weight road fuel tankers?

Response	Number of responses
Correctly	15
Incorrectly	7
Don’t know	11

Q40. What do you think is incorrect and why?

The most common reasons the 6 respondents gave for the assumptions being incorrect related to insufficient evaluation of road damage costs and the impact on the local roads network. Other respondents felt additional haulage costs, additional driver training, road safety impacts, drivers leaving the sector, impact of rejected routes to businesses and risk of accidental diversion should be included and had not been analysed sufficiently.

Q41. In your view, does the analytical information section of the consultation document, correctly or incorrectly identify all the benefits of the use of increased-weight road fuel tankers?

Response	Number of responses
Correctly	18
Incorrectly	5
Don’t know	10

Q42. What do you think is incorrect and why?

Of the 5 respondents who thought the section had incorrectly identified all benefits, 4 provided a reason for this view. Responses noted the cost to the public and environment had been overestimated, as well as the increased capacity per truck. Other respondents noted the weight increase could reduce the number of ‘normal’ vehicle movements.

Q43. DfT estimated that it costs around £0.10 per mile (when loaded) for the additional road wear and tear associated with increasing the weight of a fuel tanker, compared to the wear and tear associated with a 44-tonne limit. This figure references the average extra wear and tear cost associated with the additional weight allowance under consideration. Is this a reasonable or unreasonable assumption?    

Responses	Number of responses
Reasonable	6
Unreasonable	7
Don’t know	19

Q44. What is the reasoning behind your answer to Q43?

The most common theme noted by the 8 respondents was that the figure was too low. One response stated that the figure was too high. Another respondent stated, in the case of bridges, wear and tear costs should be derived from formal assessments. A further respondent submitted concern over worker shortages, such as road workers, which would impact the ability to repair road damage.

Q45. In your view, what would be a reasonable estimate for the additional road wear and tear cost?

Response	Number of responses
Less than and up to £0.10 per mile	1
£0.10 to £0.20 per mile	0
£0.21 to £0.30 per mile	1
£0.31 to £0.40 per mile	1
Over £0.40 per mile	2
Bridge specific amount needed	1
Don’t know	2

Questions for all on funding

The consultation document explained a process where the level of payment for LAs would be based on modelling by DfT using established processes, which quantifies the additional road wear caused by heavier fuel tankers. Use of the modelling would allow for payments to LAs to be made in a timelier way, as it would avoid the need to verify LAs’ claims for funding. The proposal anticipated that payments would be made to LAs using an existing capital funding mechanism, such as the settlement for highways maintenance for English LAs.

Payments would be calculated formulaically for Scotland and Wales, and it would be down to the relevant devolved administration to determine how additional payments should be split. The consultation asked for views on this.

Q60. In your view, is the suggested approach to calculating extra costs suitable or unsuitable?

Response	Number of responses
Suitable	10
Unsuitable	6
Don’t know	16

Q61. Why is this unsuitable and what alternative approach do you suggest?

Of the 8 responses, 2 were from respondents who had answered ‘don’t know’ to the previous question. The most common answers included concern over the impact on infrastructure and the current calculated costs not being sufficient to cover road damage costs. Furthermore, respondents noted concerns that the funding would not be ringfenced for road repairs. Other responses indicated the complexity may lead to a risk of improper assessment.

Final comments

Q68. What, if any, other comments do you have about these proposals?

The consultation received 20 responses to this question. Comments included concern over road safety, road damage and infrastructure, specifically bridges. Respondents noted many bridges across British roads would be unable to take increased weight and would, therefore, result in rejected routes. Some respondents advised building a set of approved strategic routes for heavier tanker movements, which could help manage demand in times of crisis.

Other comments included concerns that:

• the ban on convoying (a driving practice where vehicles move together, often in a line, in close proximity to one another) would mean each vehicle would have to be individually escorted (leading to a greater impact on police resources)
• the proposal does not consider assets not on the strategic road network
• heavier fuel tankers would only be able to deliver to motorway service stations
• forecourts would not withstand heavier vehicles
• potential containment systems would be unable to cope with increased volume, which could have environmental implications should fuel be lost to general drainage systems and aquifers
• vehicles risk being diverted
• the exemption appears hard to use for short periods of time, negating benefits to businesses
• does not investigate the cause of supply chain issues

Q69. Any other comments?

The consultation received 15 responses to this question. Comments covered areas such as:

• concern for the administrative burden to business and LA staff
• the benefits brought by the exemption being marginal
• road damage and impact on road safety
• a need for pre-approved routes as part of an ‘abnormal loads group’ to improve response in times of crisis
• the importance of considering the local roads network
• whether consideration had been given to the possibility of overfilling receiving tanks
• not allowing vehicles to convoy could lead to bottlenecks

One respondent noted their response was based on lots of assumptions given many factors were hard to quantify.

Others expressed a view that a further consultation should be conducted if this exemption were to become a permanent feature and more analysis carried out to better understand the wear and tear caused.