Other points

2.2.1. Road pricing

Several stakeholders have pointed to the fact that road freight transport does not pay its full cost at this moment as an argument against increasing weights and dimensions of heavy commercial vehicles. This study has demonstrated that different types of external costs do not behave uniformly when such a change is made. Demand generation and modal split greatly determine which of the effects will dominate.

Although the argument of incomplete payment is not directly relevant to the discussion on dimensions, it should be accounted for in the total freight transport picture. Ideally, every cost that is the result of an action should be paid by the one performing the action. These external costs include emissions, conges-tion, infrastructure, accidents, etc. In road transport, this implies that road pricing system should be in-stated that 1) calculates the exact cost generated by a move of freight; and 2) allows the charging of this cost to the mover. Such systems exist already in a number of European countries, although not as elabo-rate as desirable.

It should be noted that this reasoning does not solely apply to road transport. Fair competition can only be achieved when every mode is held accountable for all costs it causes. The valuation of external effects is not an easy process however, and might be the subject of a tense political discussion.

2.2.2. Enforcement

Many of the same stakeholders from the previous section have also made the argument that the first prior-ity should be to enforce current regulation, rather than making current regulation less restrictive.

This study has taken the assumption that legal limits and regulations are respected. Evidently, when infrac-tions are common, the outcome of calculainfrac-tions for several of the effects could be entirely different (e.g.

overloading causing more infrastructure damage, not respecting driving time or speed limits decreases safety, etc.). Enforcement is a key issue to maintaining a strong and credible freight transport system.

The most interesting concept in enforcement is the weigh-in-motion system, which even can become automated in future.

Therefore, any change (increase) of the permitted load (and length) of heavy commercial vehicle should be accompanied by a better control of overloading and oversizing, as well as overspeeding, to avoid an unfair competition with the other transport modes or between road transport companies. That would also con-tribute to balance any negative effect on road safety and infrastructure durability. While the ITS technolo-gies quickly progress, it is recommended to impose on future lorries, first on LHVs and then on all HGVs.

It is thus recommended to develop automatic systems for overload (and overspeed) screening and en-forcement, using both road side and on-board sensors and equipments (including Weigh in motion:

WIM). Efficient and automated WIM systems shall be developed and implemented to strictly avoid over-loads of LHVs and even reduce the general overloading rate, to compensate the effects of these new vehi-cles.

2.2.3. Implementation mechanism

If the directive 96/53 EC is modified, and the concept of LHV (EMC) is implemented in EU member states, it would be recommended to do so respecting the necessary delays, on a win-win agreement be-tween the involved parties.

A scenario for that could be to propose a list of specifications which have to be met by the carriers which apply to get a licence to operate LHVs. These specifications could contain:

- a list of safety equipments to be installed and operated in the LHVs,

- a detailed list (map) of the itineraries and periods of time on which the LHVs can be operated, - a list of monitoring and survey equipments (e.g. on-board WIM, GPS…) with the data to be

re-corded and transmitted on real time to a concessionary operator, in charge of checking that the LHVs operation comply with all the specified rules.

The carriers which fully satisfy the specifications and sign a chart to respect them will get a licence (e.g.

temporarily for a test period first, and then, after a given amount of time without violation report, perma-nent).

The concept would be that all the LHVs are remotely monitored by a concessionary independent com-pany or independent organisation (as done in Germany for the truck tolling system), which ensures that all the rules are respected; which reports any violation to the governmental authorities; and which may suspend or cancel the licence of the violators.

The licences could be given for a limited number of LHVs by company fulfilling the required specifica-tions, and then progressively increased if the experience is satisfying regarding all criteria of evaluation. In such a way the competitiveness of the SMEs (carriers) will not be too much affected by a quick transfer from current HGVs to LHVs, as well as the railway, waterway and combined transport sectors. It will give time to them to adapt and improve their technology and competitiveness.

The concessionary company or organisation in charge to operate the system is placed under the control of the member states, with representatives of the main professional unions or organisations involved.

If the scenario 2 is adopted, each member state could then sign an agreement with the concessionary com-pany or organisation on a voluntary basis to join the set of countries in which LHVs are accepted.

2.2.4. Heights

Heights have not been a major part of discussion in this study. One of the stakeholders has made a strong push to abandon all height regulations, as is already the case in a number of countries. For car transport-ers, working with loads outside the net dimensions of the transport vehicle, significant gains can be made.

Effort will however need to be made to map all bridges and other infrastructure where height may be an issue.

2.2.5. Noise

Noise emissions have not been considered in this study. The point can however be made that noise pro-duction is closely related to vehicle-kilometres, number of axles and axle load. The effect on human beings and the rest of the environment (noise perception) is not linearly related to actual noise level.

The overall effect is likely to be small compared to the base case situation.

2.2.6. Coaches

This study was solely directed at researching the freight transport market. However, directive 96/53/EC also contains regulation on weights and dimensions of coaches, for passenger transport. Some stake-holders have made the request to study this topic.