Maximum Dimensions Working Group

In 2006 ECG convened a Working Group in order to discuss the issue of maximum dimensions and modular concept. The working group consisted of logistics services providers as well as heavy duty vehicles manufacturers. The participants included:

• Francesca Barbero, IVECO
• Chris De Baere, Volvo Logistics
• Krzysztof Dakowicz, Adampol
• Marcin Grabowski, Mostva
• Hans-Peter Hitzenberger, Kaessbohrer
• Jure Karnelutti, Kastelec
• Georg Mekle, Mosolf
• Chris Minnican, DF Services Ltd
• Jaume Mira, Tradisa
• Ken Moore, IVECO
• Herve Morel, Lohr
• Chris Murkin, VMEX
• Simon Parsons, Autologic
• Paul Plomteux, PSA HNN
• Maarten Vliegen, Transportvoiture

Issue of maximum dimensions

Issue of maximum dimensions (no harmonization at the European level) has been a major problem for the vehicle logistics sector since a long time.

The vehicle logistics sector possesses the ability to extend its cargo (vehicles) legally outside the physical limits of transport infrastructure (car carriers). Vehicles can exceed the truck at the back, at the front or at the top.

This however has not been taken into account when the European legislation on maximum dimensions was adopted. The maximum dimensions of vehicles are regulated by the Directive 53/96/EC. The directive differentiates between maximum weight (“for use of a laden vehicle”) and maximum dimensions (‘for use of the vehicle’) of road trains (article 2). Consequently, no general prescription is laid down regarding maximum loading dimensions. It was left to individual member states to regulate it and as a result there are currently 10 different maximum lengths ranging from 18,75 m to 25,25 m and 5 maximum heights ranging from 4 m to no limit.

Besides the complexity of the legislation which very often results in erroneous or unjustified fines, the problem has been accentuated by two recent developments which are beyond the control of car carriers:

1. Two major EU enlargements resulting in shifting of car production towards the East, hence changing and lengthening the routes from manufacturers to end users.
2. The growing size of vehicles. The growing size of most car models makes it impossible to load as many cars on a transporter as before.

As a result the loading capacity of car carriers has been significantly reduced leading to the possible loss of capacity in the vehicle logistics sector during the last 10 years of about 10%.

The modular concept - 25, 25 meters

Many stakeholders would like to see the modular concept being allowed across the different European states. Modular concept is a concept which allows for joining a combination of two standard trailers together is such a way that they can extend up to the 25,25 meters. Every vehicle forming part in a 25.25 m vehicle combination has to be in conformity with the dimensions in annex 1 to Directive 96/53.

Here are some possible combinations:

Source: Scania

This concept has been introduced by the European Commission in 1995 when the Scandinavian countries joined the European Union in order to allow them to keep their national dimensions and is currently being used within their territory. Once leaving these countries the trailers need to be separated to comply with the shorter dimensions rules.

Since 1995 a number of trials have been taking place in Holland and Germany. At the beginning of 2008 Denmark began a trial period, the UK has been investigating the possible effects of allowing longer and heavier vehicles and Belgium has just announced plans to start a trial project on fixed trajectories. The results of these trials have been or will be used to convince the national governments of the merits of relaxing the current dimensions laws, although there is concern that the public is against what it sees as a less safe vehicle being allowed on the roads.

Supporters of the concept argue that larger vehicles are likely to pollute less and make a fewer number of journeys to carry the same volume of goods.

Working Group

Members of the Working Group discussed the issue at length and as a result created a ‘position paper’ which suggests which changes need to be made to the current legislation in order to  improve the situation of maximum dimensions and whether the sector has an interest in supporting the modular concept .

Solution:

As a result of the Working Group, ECG proposed the following amendments to the directive 96/53/EC:

• Length: setting the maximum authorized length at, at least, 20,75 m;
• abandon of all restrictions on front and rear overhangs; instead, ECG proposes that the length of the overhangs be included in the total authorized length of the vehicle;
• height: flexibility on consideration of height

 

ECG advocated the revision of Directive 96/53 to allow for harmonization of maximum dimensions in all EU member states, however in international traffic only. Each individual member state should be free to decide on its national dimensions.

Benefits of the solution:

• Road safety: there will be no significant changes to the braking, overtaking or  swept path of the vehicles at 20.75 meters. On the other hand harmonization at 20.75 meters will reduce the number of trucks on the roads and hence the collision risk may be reduced

• Energy efficiency and CO2 emissions/Noxious emissions (PM and NOx levels): harmonisation should lead to the reduction in the number of truck loads by over 200 000 or 4.3% on average across Europe, this shall translate into 18.5% reductions of CO2 emissions and noxious emissions per each vehicle/km

• Road infrastructure: no or beneficial effects on the road wear due to reduction of trucks on the roads; no effects on bridges due to the vehicles being a light type of cargo, (total weight of vehicle of 20.75 meters =  32.33 tonnes)

• Effect on combined transport and other intermodal combinations: no effect on combined transport, it will only help to optimize the use of the current fleet of trucks; no effect on intermodal combinations because there will be no technical changes made to the existing fleet of trucks

• Effect on meeting current and future freight transport demand: In a short run harmonization will help to meet the current challenge of the transport sector: shortage of drivers and lack of trucks or rail wagons. In the long run it will help to contain the growing demand for transport

As regards the modular concept, vehicle logistics companies have not been involved in any trials so far, although Volvo Logistics have been testing specially made transporters along specially designated routes in Belgium to prove the benefits and have produced some interesting results. Working Group members supported the concept of 25, 25 meters trucks, but decided that harmonisation of maximum dimensions of existing fleet at the level of 20,75 meters should be a priority for the vehicle logistics sector.

Lobbying actions

The position of ECG has been communicated to the relevant department of the European Commission, which in the meantime decided to analyse whether indeed there is a need to modify the current legislation. In 2007 EC decided to launch a new study that would look at the effects of adapting Directive 96/53. ECG was actively involved in the consultation process and apart from the constant contact with the officer responsible for the subject in the EC, our actions involved:

1. Solution to the maximum weights and dimensions bottlenecks in Freight Transport Bottlenecks Exercise, November 2007
2. Presentation in the stakeholders meeting on 4 March 2008 in Brussels
3. Participation to the Expert Workshop in Stockholm on 29 of April 2008
4. Submission of ECG’s response to the document on the study on the effect of adapting directive 96/53/EC, 9 of May 2008
5. Letter to the Commission, 29 August 2008
6. Letter to the Commission, 2 February 2009

The final results of the study, and in particular Scenario 4 which was supposed to reflect wishes of car transporters completely misrepresented the position of our industry at the end. Scenario 4 looked at the impact of trucks 20.75 meters long (ECG’s proposal), but 44 tonnes heavy (chemical’s industry proposal). By mixing the two proposals in a single scenario, the report completely ignored the specificity of finished vehicle logistics sector, which is that cars are a bulky but relatively light cargo. Even worse, the final study distorted the otherwise significant positive impact of the maximum length harmonization stipulated by ECG.

As a result ECG immediately complained to the European Commission. The European Commission (EC) has recognised as founded the strong complains made by ECG against the results of a study commissioned by the EC. The European Commission has responded to the consistent ECG action developed in the previous months, by sending a letter in which it acknowledged the ECG position and announced that yet another study will be launched this year to investigate the impact of harmonising maximum dimensions.

In fact the EC admitted that the results of the study did not sufficiently differentiate between the effects of increasing length in the car transport sector and that of general freight. As a result the EC decided that more detailed work is needed before it can attempt to develop the change to the current directive. Hence for the first time, the EC has accepted to consider all the peculiarities of the Finished Vehicle Logistics sector as regards the lack of harmonisation of maximum dimension of car transporters across Europe. ECG is confident that new study will investigate our industry issues in the proper way by taking into account overhangs and extra load length of car transporter. Meanwhile, ECG has been invited to attend a stakeholders meeting that the EC plans to hold in the next few months.

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