Consultations on maximum speeds and weights for agricultural vehicles on public highways

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Daniella Nicholson
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1 Consultations on maximum speeds and weights for agricultural vehicles on public highways Summary In November 2013 the Department for Transport announced two consultations to be run in parallel, examining maximum speeds and weights of agricultural vehicles on public highways in the United Kingdom. The two consultations were launched as part of the Government s intention to address the Independent Farming Regulation (MacDonald) Taskforce published in The Farming Taskforce report concluded that the current limits on speeds and weights do not reflect the capabilities of modern farm machinery, preventing farmers from using particular machinery on public roads and causing unnecessary time delays and added burdens to their businesses. The first consultation examines a number of policies relating to agricultural vehicle weights on roads. The proposals include: Increasing the maximum weight of a trailer from tonnes to 21 tonnes Increasing the maximum train (combination) weight from tonnes to 31 tonnes. Increasing weight of train but keeping the same maximum trailer weight. Permitting maximum train weights set at 33 tonnes and 37 tonnes under certain conditions (advocated by industry). Having a voluntary annual test in place in order to qualify for the increased trailer or train weight loads. The second consultation examines the speed limit of agricultural vehicles on public roads and proposes increasing the speed limit from 20 mph to 25mph. Bringing this proposal forward would align the UK with other countries in the EU where the limit is set at 40kmh (24.85mph). A speed restriction higher than 25mph would mean having to bring in other regulations that would be subject to all relevant agricultural vehicles on the road. The CLA expressed strong support for the direction set out in both consultations, as well as the intention showed by the Department for Transport (DfT) to cut red tape in agriculture. However, the proposals could go further in order to remove burdens on agricultural businesses whilst ensuring that they do not represent a risk to road safety. Committee members are asked to consider some of the key questions to arise from the two consultations.

2 Introduction As part of its 2011 report, the Independent Farming Regulation (MacDonald) Taskforce stated that the regulations relating to the use machinery did not meet the demands of modern agriculture, and represented a burden on the industry. Legislation relating to maximum permitted weights and speed restrictions on agricultural machinery, set out under the Road Vehicles (Construction and Use) Regulations, were drawn up in In this time, agricultural machinery has changed significantly, and is not only safer, but also capable of much quicker speeds and weight loads. After many years of lobbying from the industry, the Department for Transport announced in November 2013 that it would be readdressing both the maximum permitted weights and speeds for agricultural vehicles, citing the MacDonald report. Such proposals are long overdue, and the CLA will continue to lobby the DfT on easing further burdens arising from machinery legislation. This paper provides key questions arising from both consultations, with the draft CLA interim view. Members are asked to consider these questions. Maximum Speed Limit for Tractors on Public Roads - Consultation The maximum speed limit for most tractors with or without a trailer is currently 20mph, as set out in the Road Traffic Regulation Act. However under the Road Vehicles (Construction and Use) Regulations 1986, the maximum speed permitted on the road is set at 40mph, though this is only permissible where tractors meet certain technical requirements - including the fitment of brakes meeting standards such as Anti-lock Braking System (ABS) and full wheel suspension. Most tractors do not comply with these requirements so legally can only be used at speeds up to and including 20mph. The MacDonald report noted that many stakeholders feel the current restrictions imposed by these are outdated and that an alteration to the speed restriction, raising it above 20mph, would maintain or improve road safety. The report also stated that the restriction does not reflect the capabilities of modern farm machinery, forcing farmers to drive unnecessarily slowly on public roads. This is said to cause unnecessary delay for farmers and is a nuisance to other road users. In other European Union (EU) member states conventional tractors can operate at 25mph (40km/h), and this suggests there might be a competitiveness issue where drivers in the rest of the EU can drive faster than UK tractor drivers.

3 Figure 1. Comparison of current weight and speed limits in European countries. Country Speed Weight (GTW of tractor and airbraked tri-axle trailer with load) Portugal 40km/h - Sweden 40km/h 60,950kg Belgium 40km/h 44,704kg Netherlands 25km/h 44,000kg Germany 80km/h 40,640kg Poland 40km/h 40,640kg Switzerland 40km/h 40,640kg Luxembourg 50km/h 40,000kg France 40km/h 38,000kg UK 32km/h 24,390kg Denmark 30km/h 24,000kg 1. Policy option 1: Do nothing this means not changing the law and the speed specified in the C&U Regulations remaining at 20mph. Is this your preferred policy option? This is not the preferred position of the CLA. The regulations relating to maximum speeds for agricultural vehicles on the road have not changed for 27 years, and are not fit for purpose. The regulations do not reflect the significant changes that have taken place in agricultural machinery in this time, and it would be counterproductive for the efficiency for agricultural businesses if the speed limit is not raised. In this time, Governments of different composition have continually stated that farms should find ways to run their businesses more efficiently and cut running costs; however it would be entirely contradictory if antiquated legislation such as the C&U Regulations is not readdressed. The current restriction of 20 mph has meant that farm businesses have had to operate machinery at unnecessarily slow speeds on the roads. This has not only added to congestion on roads 1, but it also represents a safety risk as the difference in relative speed between agricultural vehicles and other vehicles is greater. 2. Policy option 2: Increase the speed specified in the restriction to 25mph (40km/h). This is currently the speed limit in some other EU countries. Is this your preferred policy option? 1 The number of licensed vehicles in the UK has increased by around 10 million between 1986 and 2010 (Transport Statistics Great Britain: 2011, Department for Transport).

4 This is the CLA s preferred policy option. Raising the speed limit to 25 mph would bring the United Kingdom s speed limit into line with the majority of other EU member states, making British farming businesses more competitive. This proposal would have a beneficial impact on British farming businesses by allowing them to undertake their farming operations quicker and cutting hours off their time on public roads. As stated in the response to Question 1, this move would make roads safer by reducing unnecessary congestion and reducing the risk of accidents associated with overtaking. 3. Would you suggest the speed specified be different? Ideally, the CLA would prefer to have this speed limit raised further for all tractors. The majority of new agricultural vehicles are capable of speeds higher than 25 mph and have the necessary safety features such as braking and suspension requirements. However the CLA understands that opting for a higher speed limit for conventional (T1) tractors would bring with it further regulation under European legislation. Whilst this is out of the scope and aim of this consultation, the CLA would strongly urge the DfT to continue to work with other EU Member States in reviewing speed limits above 25 mph at a future date. With the ongoing innovation and evolution of agricultural machinery, it is very likely that speed capabilities and safety features will increase, and the CLA would not want to be in a repeat position where legislation fails to keep up with such innovation. 4. Please provide any evidence on what effects if any the policy will have on road wear and tear and road maintenance requirements. The CLA does not have any first hand evidence however it would strongly doubt that the maintenance of roads would be adversely affected by increasing the speed limit of agricultural vehicles by 5 mph. Much heavier loads are transported by other vehicles types, and the net effect from agriculture to road maintenance would be minimal. The CLA would state that Local Authorities would see a net benefit from this revised speed limit as road congestion and accidents would be more likely to decrease. 5. Please provide any evidence on the impact of this proposal on fuel consumption. The CLA would state that the effect on fuel consumption would be minimal. The added 5 mph in speed makes next to no difference to fuel consumption for the majority of new vehicles. The CLA would again point to a possible reduction in fuel consumption due to less congestion on roads. 6. How do you think the proposals will impact on small firms? This would depend on the nature of the small firm. For small agricultural businesses or small farms, there would an immediate benefit from this proposal as they would be able to undertake their farming operations more quickly. Those small farms that use contractors as part of their farming businesses (either in part or exclusively) would also benefit from the costs saved by the contractor which would subsequently be passed down to them.

5 For non-agricultural small firms, it is difficult to fully quantify the effects of this proposal, though it is difficult to envisage how it would bring any negative impacts. 7. Do you think that an increased speed limit would lead to a shift from other modes of haulage into agricultural haulage? The CLA believes that the proposed increase of 5mph is very unlikely to encourage existing haulage businesses to fall under the description of agricultural haulage businesses. Existing haulage businesses would not see any benefit from being able to travel at a maximum speed of 25 mph for the type of work that they currently undertake. Most haulage businesses would expect to travel at greater speeds to cover greater distances than farm businesses, and the benefits associated with being defined as agricultural not be worth having to travel at this speed. The CLA would state that the most significant factor in encouraging haulage firms to come under the definition of agricultural businesses would be legislation surrounding being a licensed haulier. The Goods Vehicles (Licensing of Operators) Regulations 1995 state clearly which vehicles and businesses must be licensed good operators, outlining maximum distances permitted to haul produce. Even if haulage firms were attracted by the increased speed limit for tractors, they would still have to be compliant will all relevant goods vehicles regulations, if they intend on hauling produce over 15 miles. As the majority would expect to haul produce over this distance, the CLA can see no incentive for them to use tractors. The only significant incentive for hauliers to be classified as agricultural businesses is fuel. Haulage activity in question has to be classed for agricultural purposes, in order to qualify for rebated (red) fuel. Most hauliers will not be undertaking agricultural activity and therefore would not be permitted to use rebated fuel. 8. Do you think there is any need to review the speeds that agricultural motor vehicles other than tractors (e.g. combine harvesters) are subject to? If so, please provide your suggestions or comments. The CLA agrees that there should be a review held by the DfT to take account of all agricultural vehicles types used on the road. There are many differing types of machinery, and many CLA members are unsure what category certain vehicles fall under. For example, members have encountered conflicting guidance from local authorities, VOSA, local police and the DVLA on whether certain vehicles are classed as tractors, Road Rollers (category G) or tracked vehicles (category H). The CLA believes that the DfT needs to undertake such a review so that it is clear what types of agricultural vehicle are used on public roads, and what their capabilities are (speed, safety etc). In addition the review should take into account the views of as many farmers and farming businesses as possible, to understand how the current legislation in place continues to hamper the rural economy. In the meantime, the CLA believes that much clearer guidance must be issued by the DfT on agricultural vehicles, as it is often unclear or insufficient. CLA members have frequently expressed that when advice is sought from public bodies, it is either unclear or conflicts with advice given from another body.

6 Maximum Weights of Agricultural Trailers and Combinations - Consultation The Road Vehicles (Construction and Use) Regulations 1986 specify maximum weights for agricultural vehicles. Currently, the maximum weight of agricultural trailers and combinations is 18.29t and 24.39t. The Farming Taskforce report concluded that the current limits do not reflect the capabilities of modern farm machinery, preventing farmers from using particular trailers on public roads. In other EU countries, tractors can often tow higher weights, and this underlines a competitiveness issue between UK farmers and those in the rest of the EU. The MacDonald report recommended to Government that the maximum weights of trailers and combinations are increased from tonnes and tonnes to 21 tonnes and 31 tonnes respectively. It recommended that machinery of this weight would be required to be registered with an appropriate scheme to ensure roadworthiness, and that industry would develop such a scheme in partnership with the DfT. The DfT are also considering an additional option of increased weight of combination permitted (while keeping the same maximum trailer weight). They are consulting on options shown below.

7 Figure 2. Options proposed by the DfT

8 1. Do nothing this means not changing the law and the weight limits remaining as they are. Is this your preferred policy option? The CLA believes that maintaining the current weight limits is not acceptable. Failure to change this legislation would still leave the UK at a competitive disadvantage compared to other European countries where weights are often considerably higher. The legislation surrounding this is now over 27 years old and needs to reflect the workloads of and business needs of farms in Policy option 1: Agricultural vehicle operators would volunteer for an annual test, outlined in the law, in order to qualify for increased maximum trailer and maximum combination weights. The maximum weight of agricultural trailers would increase to 21t (from 18.29t) and the maximum weight of combinations would increase to 31t (from 24.39). Is this your preferred policy option? The CLA believes that the proposed train weight of 31t (and maximum trailer weight of 21t) is still too low. Increasing the maximum trailer weight by 2.7 tonnes will not provide any significant improvement to farm businesses, and will do little economically. To have any kind of test for this small increase would not be acceptable, and many operators would not see it as worthwhile. Tractor and trailer technology has improved significantly enough over the past 27 years to justify the need for an increase in weight allowance, without the need for any accompanying test. A test was not required when the legislation changed in 1986 and the CLA would question why this is required now. This policy option also does little to address the competitiveness issue as the UK s weight allowance would still be much lower than other European countries. 3. Policy option 2: Agricultural vehicle operators would volunteer for an annual test, outlined in the law, in order to qualify for increased weight of combination permitted (while keeping the same maximum trailer weight). The maximum weight of agricultural trailers would stay the same at and the maximum weight of combinations would be 31t. Is this your preferred policy option? As previously stated, maintaining the weight limit for trailers at 18.29t would not be acceptable and would do little do improve the current situation farmers find themselves in. The CLA would state that although allowing a heavier tractor to be used would improve safety on the road, the key concern for farm businesses is to be able carry greater amounts of produce, and reduce the number of necessary journeys. This proposal does nothing to address this, and once again it would be highly unlikely that operators would see any benefit in doing a test for this purpose. It should be stated that braking efficiency standards already exist for trailers on the road, and this measure would only add unnecessary duplication to those standards.

9 4. The industry has proposed weight limits of up to 33t maximum train weight for a tandem axle trailer with an axle spacing of greater than or equal to 1.8 metres, and 37 tonnes train weight for a tri axle trailer with road friendly suspension. What are your views on these limits? The CLA believes that these weight limits are far more appropriate for trailers with the correct axle spacing and are in accordance the maximum axle loadings contained with the Road Vehicles (Construction and Use) Regulations 1986 and the Authorised Weight Regulations There is nothing to suggest that this would represent a risk to road safety as tractors will still have to operate at a relatively low speed. Additionally, the brake specification for trailers would have to have an efficiency of at least 45%. 5. Do you think that a test requirement is necessary as part of any of the options above? I.e. should the limits be changed keeping existing enforcement provisions? If so, what are your views on this test, for example, where should a test occur, who should it be undertaken by, what should be tested? As outlined in the previous answers the CLA believe that a voluntary test would not be required for the proposed weight increases under the DfT policy options. If weight limits were increased in line with the industry proposals (outlined in question 4) a voluntary test for relevant vehicles and trailers that would be travelling at these higher weights could be appropriate. Any test considered should not add unnecessary or disproportionate costs onto operators especially as these vehicles and trailers will be used predominantly off road. Any annual test should be focussed on the machinery only, avoiding any additional licence classifications of trailers or vehicles for operators to take. For the vehicle and the trailer, the CLA would state that the requirements should only have to extend to their construction and visual examination. Construction requirements for the vehicle could include braking equipment and front suspension whilst a trailer should include braking efficiency of more than 45% and load sensors. Visual examination requirements for both vehicles and trailers could include the condition of lights, wheels, tyres, hitch and superstructure. The CLA would state that any proposed test should take into account the location of farming businesses, such as farm machinery dealerships with approved brake testing equipment. Braking efficiency tests should be permitted on rolling roads at ATF and VOSA testing stations in order to accommodate this. 6. Do you agree that agricultural vehicle operators should incur the costs of testing? The CLA would state that it would be appropriate for operators to meet the costs of testing in order to make use of the increased weight limits proposed by the industry. However it is vital that the cost is proportionate, reflecting the frequency of its use on the road. The test should certainly be no more than an HGV test, which is around 150.

10 7. Do you have any evidence on what effects if any the policy will have on road wear and tear and road maintenance requirements? Similar to increasing the maximum speed of agricultural vehicles to 25 mph, the CLA would again doubt that the maintenance of roads would be adversely affected by increasing the train weight. Modern tri-axle and tandem axle trailers have wheel, hitch and suspension specifications that ensure the road is not damaged in transport which would all be tested upon annually. 8. Do you have any evidence on the impact of this proposal on fuel consumption? The CLA would state that whilst fuel consumption would change little if the weight limits is set at 31 tonnes (because of the minimal change in trailer weight), it could be greater for loads up to 33 and 37 tonnes. However, the overall use of fuel would not increase, as this measure would ensure fewer total trips would have to be made by farm businesses. 9. Do you think that increased weight limits would lead to a shift from other modes of haulage into agricultural haulage? The CLA strongly doubts this, for the same reasons mentioned in the maximum speed consultation. Whilst the increase in train weight may appear attractive, other haulage businesses would still have to comply with a relatively low speed limit, register as a goods vehicle, whilst remaining ineligible for rebated fuel in most cases. 10. Do you believe that current enforcement practices will need to change if the weight limits are increased? The CLA does not envisage any need for enforcement practices that go over and beyond current procedures. If vehicles and trailers are tested in order to qualify for the increased train weight loads, this could be recorded on the VOSA national computer using a tractor registration number and the trailer serial number for reference. This will assist enforcement agencies and clarify to them whether or not an operator is compliant with any new legislation. However, the uptake of tests by operators is only likely to happen if they feel that the increase in maximum permitted train loads will bring significant benefits to their business. Edward Barker Agricultural Adviser January 2014 A

Consultation on the Maximum Weight limit of Agricultural Trailers and Combinations on Public Roads

Consultation on the Maximum Weight limit of Agricultural Trailers and Combinations on Public Roads IOSH response to the Department for Transport consultation Submission 27.01.14 Introduction IOSH welcomes