Fax to : ����������� LTSA Rules Team
Fax no:����������� 04- 494 8601
Date: 3 September 2001
Submission on Rule 41001: Vehicle Dimensions and Mass (yellow draft)
About CAN
The Cycling Advocates' Network of NZ (CAN) is this country's national network of cycling advocates. It is a voice for all cyclists - recreational, commuter and touring. We work with central government and local authorities, on behalf of cyclists, for a better cycling environment. We have affiliated groups and individual members throughout the country, and links with overseas cycling organisations.
Summary
Cyclists make extensive use of the State Highway network as well as other roads which might be used by the proposed larger vehicles. In urban areas, cyclists use such roads for activities such as commuting, shopping, travelling to school or visiting friends. In open road areas, cyclists tend to use the roads for sporting activities and cycle touring as well as commuting.
CAN is opposed to the introduction of any legislation which allows either the length or width of vehicles to be increased, unless significant improvements are made to the roading network with particular consideration to the safety of cyclists. We note that the LTSA Overview document (page 11, 2nd paragraph) states that:
"The LTSA, however, does not propose any increases in maximum overall allowable dimensions through this rule because:
_ the physical state of the network (in general) has not improved significantly to cater for longer vehicles;
_ there have been no changes in heavy vehicle technology that would allow dimension increases, given the general state of the road network and safety performance limitations."
We are disappointed that there is no mention in either the proposed Rule or the Transit NZ 'Issues Paper' of the effect of bigger trucks on cyclists. We do not believe the size of trucks should be increased at all until there are sufficient and consistent hard shoulders to ensure the safety of cyclists.
We also ask that a serious study is made into the safety benefits that would come from reducing the speed limit for trucks to 70 or 80 km/hr, as happens in Europe. We also ask that the LTSA legislate for improvements to heavy vehicle standards relating to side guards (to stop smaller road users being caught between sets of wheels) and improved left rear visibility (so truck drivers are less likely to pull in too early after passing a smaller vehicle).
We support the general move to clarify the mass & dimension requirements for heavy vehicles by removing any anomalies and introducing greater consistency. We also support the move to introduce higher standards for new heavy vehicles (e.g. in terms of stability) that replace older, less safe vehicles.
CAN is disappointed that we were not included in earlier consultations on this matter. Following discussions with LTSA staff, we trust we will be included at an early stage in the development of future Land Transport Rules.
Increased lengths
We are concerned that the 'standardisation' of figures all seems to be upwards. For example, the overall length is proposed to rise from 19 metres (17 in the case of a 'semi') to 20 metres (and 18 for a 'semi'). While we accept that some means of allowing existing vehicles to legally stay on the road is pragmatic, some reductions in maximum dimensions could have been specified for new vehicles, with a 'grandfather' clause allowing older vehicles maybe 5 years to comply or be removed.
Any increase in truck length increases the risk of the body of that vehicle encroaching on the road edge at left hand bends. Since that is where the cyclists are supposed to be, we view this as an increased risk to the safety of cyclists. In addition, the proposed rear overhang extension would increase the risk of right-turning trucks (either at an intersection or around a curve) striking a cyclist that they had just overtaken.
There should also be an analysis done of the risks associated with the extra time taken for a longer truck to pass a cyclist.
We have seen no evidence in the proposal that these issues have been considered.�
Psychological effects
The public perception of longer or heavier vehicles is an issue which should be addressed. Vehicles should not be so big that they scare other road users, and we have a right to expect that the issue of size and its psychological impact on other human beings will be taken seriously. In the absence of NZ based research, we quote from the USA report 'Comprehensive Truck Size and Weight Study - Summary report for Phase 1', Federal Highway Administration, March 1995:��
"Public perception about large trucks.� While the perception issue is not one which can be readily dealt with, it requires consideration in the evaluation of regulatory options. European research on public attitudes about trucks indicates that medium sized goods vehicles are often preferred to either fewer larger or more small goods vehicles".
The LTSA Overview document (page 21, 2nd paragraph) itself states:
"The basic right to proceed along a road without unreasonable interference from other road users is balanced by an obligation not to interfere with other road users."
Regardless of the actual changes in risk in moving to larger and/or heavier vehicles, there will always be a public perception that the risk to other road users has increased. This will impact particularly on more vulnerable road users who will feel the greatest potential threat. The upshot may be that cyclists (or parents of cyclists) may be less inclined to travel (or allow their children to travel) by bicycle. A resulting reduction in cycling (with a corresponding increase in motor vehicle traffic) would, in the long term, have negative effects on road safety overall.
A large truck thundering up behind you at 100 km/hr when you are on a bicycle understandably makes you nervous. Knowing that the truck driver is very unlikely to slow down until it is safe to pass, whatever the conditions, adds to that.
It may be that driver education, minimum passing distances and speed restrictions are the answer to this problem, but until a solution is found, the size of heavy goods vehicles should not be increased.��
Forward distance, Length and Overall Length
We object to the proposed limit of 9.5 m (Section 4.1, Table 4.1 - Forward distance) for all rigid vehicles and recommend that the present limits remain. The proposed limit is an increase of 1.0 m for both light vehicle and heavy vehicle categories and brings them up to the existing limit for buses.� It is not unusual for cyclists to find that they are squeezed into the kerb when overtaken by buses turning left at intersections.� Bus drivers are well trained and normally familiar with their particular routes, and it can be reasonably expected that by allowing all light vehicles and heavy vehicles to operate at this greater length, there would be an even greater threat to the safety of cyclists under the new regulations.
We object to the proposed increases in Length and Overall Length for light vehicles, heavy vehicles, and trailers, for the same reasons as given above. We ask that an analysis of the risks to cyclists from encroachment by turning motor vehicles is made by the LTSA, with reference both to NZ statistics and the experience of cyclists overseas.
CTI width
We are concerned at the proposal (Section 4.1(4)(e) of the Rule) which would allow central tyre inflation hoses to extend up to 75 mm beyond the outside of the tyre.� Our concern is that these hoses may present a hazard to cyclists, potentially getting caught on a cyclist's clothing or equipment.
Ideally, of course, trucks would not come that close to cyclists, but the reality is that they do, as evidenced by death and injury reports. This is particularly likely in urban areas where speeds are lower and drivers tend to give less clearance to cyclists, though it is also an issue on open roads where there is little or no hard shoulder and on narrow bridges.
Transit NZ Proposals for Higher Mass and Dimension Limits (Issues Paper)
This document lacks any discussion of the effects which the limits proposed by Transit NZ would have on cyclists. There is a section in Transit NZ's 'Answers to some common questions' document (dated 9 July 2001) which discusses the effect on cyclists of wind turbulence, extra lane widths required and the need for 2 metre wide hard shoulders ("where possible, without compromising the traffic lane"), but these issues should have been carried through to the main document. We are not aware that any consultation was done with cyclists as part of this project.
'Safety benefits'
Transit's safety 'benefits' seem to be derived from either the introduction of better vehicle standards (e.g. stability, power/weight ratio), or a reduction in truck vehicle kilometres travelled (VKT).
The first could be introduced without any change to mass or dimension limits, and indeed is already being implemented by the industry. The VKT reduction argument appears to be based on the assumption that the same amount of freight will transported by fewer trucks. This appears to ignore the likely switch of freight currently transported by other modes (rail, sea, air) to road because of economic efficiencies introduced. This may result in no change in truck VKT or, worse, an increase.
Road widths
We are appalled to read in the Transit 'Issues Paper' that (depending on off-tracking distances for longer trucks) "widening would still not be necessary as long as two trial vehicles travelling in opposing directions could pass with 1 metre clearance between their swept paths and 0.5 metres clearance to the edge of the road" (section 4.2 - Road Width). That would leave nowhere for cyclists to go unless they were riding on the very left of a wide (1.5 metres) hard shoulder. The Austroads Guidelines, Part 14 give a bicycle design envelope of 1.0 metre width and 1.5 metres minimum clearance to the edge of 100 km/hr traffic lane.
Air displacement from big trucks, as any cyclist knows, can destabilise you very easily. When there are wind gusts or strong cross winds, the slipstream moves sideways in response and can suck or blow a cyclist under the wheels of a following vehicle or into the side of the road. The faster the vehicle is, the greater the risk.
A particular issue of concern relates to roads with no sealed shoulder where the cyclist has no option but to ride in the traffic lane.� The cyclist is at greatest risk when being overtaken by motor vehicles in the face of on-coming traffic. The driver of any motor vehicle is obviously reluctant to slow down� to the speed of a cyclist and when these situations develop it seems that the majority of drivers will endeavour to overtake the cyclist allowing only the barest minimum of clearance.� Cyclists feel much safer if they can ride on a sealed shoulder.� Improving the standards of roading to provide an adequate sealed shoulder on all roading should be a priority for Transit NZ. Until such time that real progress is made in improving our roads, we are of the view that no consideration should be given to any increase in vehicle dimension limits.
We are also concerned that� at corners in urban areas there would either be encroachment on the side of the road (or footpath), or (if the road widths were modified) unwanted effects on other road users, such as increasing the speed at which cars could take the corner. This should be analysed.
Performance based standards�
We support the introduction of safety-related PBS measures (Part One - 3.2 of the 'Issues 'Paper) on the grounds that the prevailing rate of serious accidents caused by trucks is totally unacceptable and will only be improved by enforcing higher standards in the industry.
Directional Performance for truck and trailer units is probably of greatest significance to cyclists. In the open road situation, sway or high-speed off-tracking can be a real danger to cyclists.� The degree of sway appears independent of the class of vehicle, e.g. a light or heavy truck towing an unladen full trailer (two-axle sets) at speed can develop significant sway or off-tracking, to the extent that the trailer off-tracks across the full lane width of a rural road.� Where this motion has been observed it may have been accentuated by a road surface which is uneven but not uncommonly so for rural areas. We therefore seek a substantial improvement to Directional Performance of vehicles. This should, however, be introduced irrespective of any proposed increase in vehicle size.
Incomplete analysis
We are also concerned that the Transit NZ 'Issues Paper' appears to be a one-sided analysis of the costs and benefits of allowing substantially larger tracks on the roads. The paper says the "benefits from increased mass and dimension limits [have] the potential to materially improve NZ transport costs". However, the specified routes are almost all covered by rail freight services, and there appears to be no attempt to cost the benefits of shifting that heavy freight to rail or coastal shipping - a much preferable solution for the cyclists currently trying to use the roading network.
It is also of concern that Transit has chosen the least-cost option of $44M for 'geometry costs' (Scenario B) as being most likely. Given that slight changes in assumptions raised the costs to as high as $292M, it would seem prudent to apply a more probabilistic approach to the estimated cost of geometric improvements.
When addressing road widening in relation to Scenario A, Transit NZ uses the 'status quo' argument to allow a continuation of the existing situation. It does not reflect the fact that a considerable part of the existing network already requires geometric improvement to meet an acceptable standard. If in fact truck VKT increase with new higher mass limits, then the safety situation will become worse.
The claim that "[freight transport cost] benefits could be achieved without compromising safety whilst also making an overall reduction in exhaust emissions and fuel consumption" because "increased heavy vehicle limits will enable fewer fully laden and partly laden trucks to perform a specified road freight task" is disingenuous. Commonsense suggests that if the per tonne cost of freight transport by road goes down, freight will be attracted from other modes, and the number of trucks will rise. The rise in both actual and perceived risk to cyclists from such a rise in numbers as well as size is obvious, and would� effectively infringe� cyclists' right to use the roads.
Cycling Advocates' Network
PO Box 6491
Auckland
Phone/Fax: 04-385 2557
Email: can@actrix.gen.nz