The Freight Transport Association of Ireland, FTAI, thanks the committee for its invitation to present to it on this important matter. The FTAI is a not-for-profit membership trade association for the Irish freight and logistics industry and covers all aspects of private and public freight transport, passenger transport and logistics supply chain including road, rail, sea and air.
Directive 96/53/EC governs the weights and dimensions of commercial vehicles in circulation throughout the EU.
Current proposals amending the directive would affect the maximum authorised dimensions in national and international traffic, as well as the maximum authorised weights in international traffic. The FTAI supports the proposed amendments to Directive 96/53/EC in so far as they encourage the use of hybrid and multi-fuel vehicles, encourage the manufacture of more aerodynamic and fuel-efficient vehicles and encourage the manufacture of vehicles that are safer from a pedestrian, cyclist and driver perspective and which improve overall road safety. The FTAI opposes any amendment to Article 4 that would prohibit the free circulation across borders between two consenting states of vehicles outside the dimensions laid down in Annex I to Directive 96/53/EC.
As members are aware, in Ireland SI 366 of 2008 was signed into effect on 1 November 2008. It specified that a maximum vehicle height of 4.65 m would apply to all vehicles from 1 November 2013, thereby allowing existing vehicles in excess of that height to wash out of the system. Companies using what are known as high cube vehicles are mostly, but not solely, involved in the inter-depot movement of laundry, medical supplies, hanging garments, white goods, car transport, pre-packed fresh and frozen meals, horticulture, furniture, DIY, electrical, information technology and electronic goods, toys and paper products. The removal of vehicles in excess of 4.65 m from the roads will increase the total number of vehicle movements, in some cases very substantially, and this increase will adversely affect those urban areas through which HGVs already circulate. The beneficiaries of the removal of these high vehicles are those in three small areas around the Dublin Port tunnel, Limerick and Jack Lynch tunnels, though the latter two are not residential areas. However, those who will suffer even more following the removal of high vehicles are everywhere on the motorway network and in the regional towns. In the case of car transport, vehicle movements will increase by approximately 35%, while in the case of laundry, the effect will be up to 68% in increased movements.
However, the FTAI acknowledges the requirement to legislate for maximum vehicle heights and dimensions and supports a maximum standard vehicle height of 4.65 m. We consider the most logical way to accommodate these two positions is to legislate for a controlled permit regime for operators of high vehicles on fixed routes, similar to the abnormal loads regime that currently exists among local authorities. As the abnormal loads regime is highly variable between local authorities, this requires standardisation. The FTAI recommends consideration of the electronic service delivery for abnormal loads, ESDAL, system currently used in the UK.
In consideration of the current proposals included in Directive 96/53/EC, the potential exists to mitigate the effect of reducing vehicle height by adopting longer heavier vehicles under the European modular system. However, this will not provide an adequate solution for the loss of cubic capacity resulting from the removal of trailers over 4.65 m. Based on National Road Authority, NRA, traffic count statistics that are publically available on its website, the busiest junctions on the M50 are between Finglas and Parkwest southbound between 7 a.m. and 10 a.m., and this is reversed in the evenings northbound between 4 p.m. and 7 p.m. Based on current HGV volumes, there typically are between 350 and 500 movements per hour during those periods. On the basis that approximately 20% of current movements take place using HGVs in excess of 4.65 m and assuming displacement of these will result in an additional 40% of vehicle movements - both these estimates are conservative - this will increase peak hourly volumes on the north-west section of the M50 to between 374 and 540 movements per hour. The FTAI recommends that the Department of Transport, Tourism and Sport should facilitate the introduction of a controlled and limited permit regime to allow the use of vehicles in excess of 4.65 m in height on a defined route and use basis.
As for the proposed amendment to Directive 96/53/EC, the FTAI wishes to make the following points. The most serious proposed amendment to the directive is that to Article 4, which would prohibit cross-border transport between member states of vehicles which deviated from the dimensions laid down in Annex I. Specifically, this would prohibit the cross-border movement of vehicles in excess of 4 m in height. The 4 m vehicle height is standard among European cross-border road transport operations, where access to tunnels with a standard 4 m height restriction is required. Depending on the fleet of the specific operator, this measure would affect up to 90% of the semi-trailers in use in the Irish fleet and would have major cost implications for cross-border operations and for seaborne freight across the Irish Sea. The increase in articulated vehicle movements through the Dublin Port tunnel, DPT, and onto the M50 would be substantial and would seriously congest the M50 southbound following inbound ferry dockings. Different EU geographies require differing logistical solutions. Central European networks will require a different modal mix to Ireland. The original proposed amendments to the directive permitted cross-border movements of vehicles outside the dimensions laid down in Annex I. However, the Leichtfried proposal is most unwelcome, is highly damaging from both an import and export viewpoint and must be robustly opposed. The FTAI has suggested a more appropriate text for this amendment.
The FTAI is broadly satisfied with proposals which accommodate the use of alternative fuels. It is in favour of the unrestricted circulation of 45 ft. containers throughout the Union and therefore, this proposal should be clarified in that respect. We accept the reduction in dimensions of maximum permitted rearward aerodynamic extensions to 500 mm; this reflects the reality of current vehicle design and construction limitations. This matter is rightly one for the consideration of the EC technical group. We strongly support the certification of aerodynamic extensions within the type approval process. Certification would mean that devices would need to actually work and so would prevent manufacturers flooding the market place with devices which may not. We strongly support such modifications to vehicles that improve visibility for drivers. We support the manufacturing of such modifications to vehicles that improve vehicle safety. The FTAI also gives a qualified welcome to the introduction of on-board weighing devices to vehicles of categories N2 and N3. However, we would need to see the details of such proposals and to consult our members on them. The proposal to apply the increase in maximum authorised mass generally to all multi-fuel vehicles, rather than to particular sectors, is welcomed.
I thank members and will be happy to take questions.