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Direct Vision Standard

Transport for London

Integrated Impact Assessment of the Direct Vision Standard


1 | 1

20 September 2017

Economic and Busi ness Impact Assessment


1

Direct Vision Standard

Project No: B2315700

Document Title: Integrated Impact Assessment of the Direct Vision Standard

Document No.: 1

Revision: 1

Date: 20 September 2017

Client Name: Transport for London

Client No:

Project Manager: Gabi Cordero

Author: Irina Davis, Wendy Cheung

File Name: I:\11 Freight & Fleet Programmes\05 - Safety\27 - DVS Implementation\25) Integrated

Impact Assessment\IIA document\Final Draft IIA (co-location period version)\B2315700

DVS Draft IIA report 20 September 2017 Latest Version 3.1.docx

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Document history and status

Revision Date Description By Review Approved

Draft 1 04.09.2017 Draft IIA Report ID GC JP

Version 1 20.09.2017 IIA Report – for Client review ID, WC GC/BK JP

2

Contents

Executive Summary ............................................................................................................................................... 4

1. Glossary ................................................................................................................................................... 10

2. Introduction .............................................................................................................................................. 12

2.1 Background ............................................................................................................................................... 12

2.2 Purpose of the IIA Report .......................................................................................................................... 12

2.3 Structure of the IIA Report ......................................................................................................................... 12

2.4 Public Consultation .................................................................................................................................... 13

2.5 Stakeholder Engagement and Consultation to Date ................................................................................. 13

3. Strategic Objectives of the Standard .................................................................................................... 14

3.1 The Mayor’s Transport Vision for London and Road Safety – Vision Zero ............................................... 14

3.2 Using the Standard for Large HGVs to Support Vision Zero ..................................................................... 14

3.3 Ultra-Low Emission Zone (ULEZ) Proposals and Consultation ................................................................ 14

4. IIA Approach ............................................................................................................................................ 16

4.1 What is an IIA? .......................................................................................................................................... 16

4.2 Requirements for IIA .................................................................................................................................. 16

4.3 Stages of the IIA Process .......................................................................................................................... 17

4.3.1 Stage 1 of the IIA Process ......................................................................................................................... 17

4.3.2 Stage 2 of the IIA Process ......................................................................................................................... 19

4.4 Spatial Scope of the IIA ............................................................................................................................. 20

4.5 How will the IIA process influence the development of the scheme proposals?....................................... 20

4.6 Proposed Methodology for Each Element of the IIA ................................................................................. 20

4.6.1 Predicting the effects of the scheme against the IIA objectives ................................................................ 25

4.7 Development of the Scheme Options ........................................................................................................ 25

4.7.1 Four Step Scheme Options Development Approach ................................................................................ 26

5. Tier 1 Assessment – Option Sifting ....................................................................................................... 29

5.1 Assessment summary results from the CBIA ............................................................................................ 29

5.1.1 Cost to the Public Sector ........................................................................................................................... 30

5.2 Assessment summary results from the safety report/CIA study ............................................................... 33

5.2.1 Purpose of the CIA study .......................................................................................................................... 33

5.2.2 Findings of the CIA .................................................................................................................................... 33

5.3 Tier 1 assessment (Option Sifting) overall results and conclusions .......................................................... 35

5.4 DVS scheme Options taken to the full IIA ................................................................................................. 35

6. Tier 2 Assessment of the Shortlisted Options ..................................................................................... 36

6.1 Tier 2 Assessment Process at this stage .................................................................................................. 36

6.2 Comparative Analysis of the DVS Options ................................................................................................ 36

7. Summary of the Significant Impact of the Shortlisted Options .......................................................... 40

7.1 Do Minimum Scenario ............................................................................................................................... 40

7.1.1 Environmental IIA Objectives .................................................................................................................... 40

7.1.2 Equalities IIA Objectives ............................................................................................................................ 40

7.1.3 Road Safety IIA Objectives ....................................................................................................................... 40

7.1.4 Health IIA Objectives ................................................................................................................................. 41

7.1.5 Economic IIA Objectives............................................................................................................................ 41

7.2 Option 1 – Outright Restriction .................................................................................................................. 42


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7.3 Option 5 – HGV Safety System Scheme................................................................................................... 45






8. Cumulative effects of the proposed scheme and the Ultra-Low Emission Zone (ULEZ) scheme ..................................................................................................................................................... 48

9. Transboundary Effects ........................................................................................................................... 53

9.1 Economic ................................................................................................................................................... 53

9.2 Environmental ............................................................................................................................................ 53

9.3 Social ......................................................................................................................................................... 53

10. Mitigation Measures ................................................................................................................................ 55

11. Conclusion of the IIA ............................................................................................................................... 56

Appendix A. Relevant Plans and Policies ......................................................................................................... 58

Appendix B. Scoping out of sustainability topics and associated objectives .............................................. 73

Appendix C. IIA Methodology ............................................................................................................................. 77

Appendix D. Cost and Business Impact Assessment (CBIA) Report ............................................................ 92

Appendix E. Casualty Impact Assessment (CIA) Report ................................................................................. 93

Appendix F. Detailed IIA of the Shortlisted Scheme Options ......................................................................... 94


Executive Summary

Background

The Mayor of London is adopting a ‘Vision Zero’ approach to road danger reduction based on the view that no

loss of life is inevitable or acceptable. The Mayor’s Vision Zero strategy is looking to make streets safer,

especially for cyclists and pedestrians by eliminating road danger at source. As part of his Vision Zero approach

to reducing road danger across the Capital, the Mayor of London launched the world’s first Direct Vision

Standard (DVS).

The Mayor announced his intention to use the DVS to ban or restrict the most unsafe ‘zero star’ rated Heavy

Goods Vehicles (HGVs) over 12 tonnes from entering London by 2020 and only allow vehicles with ‘good’ three

star direct vision ratings from 2024. We are supporting TfL to develop and assess options for a DVS Scheme

that reduces road risk, improves HGV/VRU casually rates, and does not undermine the city’s competitiveness

create a disproportionate cost to businesses operating in on serving London

An Integrated Impact Assessment (IIA) has been undertaken to support a Phase 2a Policy Consultation on the

Standard and is due to be launched in autumn 2017. Jacobs was commissioned by Transport for London (TfL)

to undertake a Cost and Business Impact Assessment (CBIA) alongside the Transport Research Laboratory

(TRL), which was commissioned by TfL to undertake a Casualty Impact Analysis (CIA) of the proposed policy to

inform the wider impact assessment undertaken by TfL.

TfL developed a number of Options to implement the scheme, hereafter referred to as the “scheme Options”,

which were evaluated based on their technical, environmental, economic, social and other factors. This IIA

report provides the results of this evaluation, the findings of which have been collated into one overall IIA report.

The scheme Options have been subject to a rigorous IIA comprising: Environmental Assessment (EA);

Equalities Impact Assessment (EqIA); Health Impact Assessment (HIA); Quantified costs and benefits -

Economic and Business Impact Assessment (EBIA); and Community Safety Impact Assessment (CSIA), as well

as given regard to Road Traffic Act Duties and other legal considerations.

Purpose of the IIA Report

The purpose of the IIA report is two-fold:

Tier 1 Assessment – Option Sifting: To present the findings of the process of shortlisting the long list of five

scheme Options, considering initial costs and benefits identified in the CBIA report and Casualty Impact

Assessment (CIA) report; and

Tier 2 Assessment – Shortlisted Options: To consider the detailed impacts of the shortlisted scheme

Options, suggest mitigation measures and provide recommendations about the way forward.

Tier 1 Assessment – Option Sifting Results

Prior to the commencement of the full detailed IIA of the shortlisted Options, the initial Tier 1 assessment

(Option Sifting) has been carried out on the long list of Options that was informed by the CBIA and safety report

/CIA studies.

Jacobs evaluated the costs for the scheme options identified by TfL. These costs included costs to business as

well as costs to implement and enforce the scheme. Five options were assessed:

Do Minimum: DVS is available to inform purchasing decisions of businesses, however compliance is

not mandated, resulting in no costs to businesses as a result of DVS. There is no restriction scheme.

Option 1 – Outright Restriction: ban N3 class vehicles rated zero stars by 2020 and those rated

below three stars by 2024. (All N3 HGVs to apply for permit to prove star rating).

Option 2 – Phased Outright Restriction: only newly registered N3 vehicles must comply with at least

three stars by 2020 and all N3 class vehicles must comply with three stars by 2024.


Option 3 – Outright Restriction with Transitional Mitigation: allow zero star rated vehicles to

demonstrate mitigating safety features in 2020 temporarily. N3 class vehicles rated below three stars

are prohibited from entering Greater London by 2024.

Option 4 – N3G Ban: an outright ban on all N3G1 class vehicles entering Greater London from 2020.

Option 5 – HGV Safety System Scheme: all vehicles rated 1 star or better on DVS automatically given

a permit from 2020 and vehicles rated at least 3 stars or better automatically given a permit from 2024.

Please note, there were many limitations to both the CBIA and CIA that may have compromised the accuracy of

the results. The main issue faced was the inability to identify the exact number of vehicles rated zero stars, one

stars etc. To address this issue, a lower and higher estimate of vehicles rated zero stars, one star etc. were

estimated. The lower height estimate of non-compliant vehicles is considered the “best case” scenario. The

higher height estimate of non-compliant vehicles is considered the “worst case” scenario. Please note, referral

to “non-compliant” vehicles apply to the vehicles not complying to the conditions of the Option tested.

Key findings from the CBIA showed:

Option 1 (Outright Restriction) presents the highest and largest range of costs, ranging from £8 billion to

£31 billion, forecasted to impose substantial cost across all sectors. In particular, the Construction

Sector would borne the most significant costs as the majority of N3G class HGVs are rated below three

stars, and would forecast (temporarily) to affect their day-to-day on site work.

Similarly, Option 4 (N3G Ban) shows the financial impact of Construction businesses that are no longer

able to operate in London presents the most substantial cost.

Option 5 (HGV Safety System Scheme) presents the lowest cost of £635 million to £676 million

(undiscounted), as the only cost incurred is the cost of extra safety mitigation equipment for 0-2 star

rated vehicles.

Option 1 (Outright Restriction) and Option 5 (HGV Safety System Scheme) were recommended for

further assessment

The CIA undertaken by TRL presented the following findings on Option 1 (Outright Restriction) and Option 5

(HGV Safety System Scheme):

Option 1 (Outright Restriction) is estimated to prevent a total of 8-16 fatalities and 4-14 serious injuries

by 2030, at a value of £18m to £43m (undiscounted).

Option 5 (HGV Safety System Scheme) is estimated to prevent 3-15 fatalities and 2-15 serious injuries

by 2030 at a value of £7m to £40m (undiscounted).

The following table summarises the quantified costs2 and benefits over the 10-year appraisal period from the

year 2020.

1 N3 class HGVs that are able to operate “off-road” 2 Rounded to nearest million


Table 1-1: Summary of Option 1 (Outright Restriction) Cost and Benefits, £000s

Undiscounted Discounted

Low High Low High

Benefits

Casualty 18,000 43,000 14,000 32,000

Cycling 92,000 92,000 65,000 65,000

Total Benefits 110,000 135,000 79,000 97,000

Costs

Cost to Businesses 7,820,000 30,600,000 6,740,000 27,400,000

Cost of Enforcement 10,000 10,000 10,000 10,000

Total Costs 7,830,000 30,610,000 6,750,000 27,410,000

Net Present Value -6,671,000 -27,410,000

Benefit-Cost Ratio 0.012 0.004

Table 1-2: Summary of Option 5 (HGV Safety Mitigation Scheme) Costs and Benefits, £000s

Undiscounted Discounted

Low High Low High

Benefits

Casualty 7,000 40,000 5,000 29,000

Cycling 73,000 73,000 52,000 52,000

Total Benefits 80,000 113,000 57,000 81,000

Costs

Cost to Businesses 630,000 680,000 330,000 570,000

Cost of Enforcement 10,000 10,000 10,000 10,000

Total Costs 640,000 690,000 340,000 580,000

Net Present Value -283,000 -499,000

Benefit-Cost Ratio 0.168 0.140


The core option, Option 1 (outright restriction), presents the lowest BCR, ranging from 0.004:1 to 0.012:1 as a

result of the potential high number of vehicles that would need to be replaced earlier and the impact on the

economy as a result of withdrawing non-compliant vehicles from entering London.

In contrast, Option 5 (HGV Safety System Scheme) presents the highest BCR, ranging from 0.140 to 0.168,

showing the impact of mitigating early replacement and withdrawal of non-compliant vehicles from entering

London. Although Option 5 (HGV Safety System Scheme) presents the highest BCR in comparison to Option 1

(high estimate), the BCR of 0.168:1 in the best case scenario falls below the benchmark BCR of 1.5:1, i.e.

considered not economically viable to implement.

Tier 2 Assessment of the Shortlisted Scheme Options Results

The assessment of the schemes shortlisted Options is the Tier 2 assessment and has been carried out against

the IIA objectives (please refer to Table 1-3) to evaluate how each Option performed on its own merits in

respect of the IIA objectives. Please note, the scores of the IIA objectives cannot be comparatively be

compared, for example, the score of two plus (++) for environmental is insignificantly minor when compared to

the score of two plus (++) for road safety for Option 1.

Table 1-3: Proposed scheme IIA Assessment Framework

Topic IIA objective

Air Quality 1. To contribute to a reduction in air pollutant emissions and compliance

with EU limit values

Climate change mitigation 2. To reduce CO2 emissions and contribute to the mitigation of climate

change

Economic competitiveness and

employment

3. To provide a high quality environment that will help to attract and

retain internationally mobile businesses.

Economic Sectors 4. Encourage the development of new businesses in new and growth sectors

Road Safety 5. To contribute to safety and security and the perceptions of safety3

Connectivity 6. To contribute to the avoidance, elimination or reduction of road congestion or other disruption of the movement of traffic

Population and Equality 7. To reduce the number of casualties from protected groups as a

result of HGV related accidents

8. To advance equality of opportunity of small and medium enterprise

owned by protected and disadvantaged groups.4

Health and well-being

9. To contribute to enhanced health and wellbeing for all within London

.

The results of the Tier 2 Assessment of Option 1 (outright restriction) and Option 5 (HGV Safety System)

showed the following:

3 The DVS scheme is concerned with the design of the HGVs and thus will not have direct impacts on the crime and disorder. These issues

as well other Road Traffic Act duties have been streamlined through the selection of the road safety related IIA objective 5 and IIA objective 6 to ensure the overall conformity with Road Traffic Act duties in respect of safety, movement of traffic and congestion elimination. Testing the DVS scheme Options against this tailored IIA objectives ensures their compliance with those duties.

4 Both equality IIA objectives addresses the requirements to meet the Equality Act 2010, 149 Public sector equality duty


Table 1-4: Summary of Tier 2 Assessment – Option 1 (outright restriction) and Option 5 (HGV Safety System)

Theme

Do Minimum Option 1 - Outright

Restriction

Option 5 HGV safe

system scheme

Ranking

Score Score Score

Air Quality ++ + Baseline: Do Minimum

Best Option: Option 1

Worst Option: Option 5

Option 1 will provide the highest impact on Air Quality; total reduction

in NOx of 0.15kg-1.2kg and PM10 of 14g-112g estimated.

Climate change

mitigation

++ +

Option 1 will provide the highest impact on CO2; Option 1 estimates a

total reduction by 2020 of CO2 between 121kg-968kg

Baseline: Do Minimum



Economic

competitiveness

and employment

--- -

Option 1 estimates the highest cost to businesses, ranging from £8

billion to £31 billion

Option 5 estimates a lower cost to businesses compared to Option 1,

ranging from £635m to £676m

No costs are forecasted in the Do-Minimum scenario




Economic Sectors --- -

The economic environment for Small to Medium Enterprises (SMEs)

and potential new business start-up would become less attractive.

SMEs are expected to have less financial flexibility to adjust their fleet

to meet compliance, or the capital to replace their vehicles earlier and

on what the sector may consider short notice (the Standard ratings will

be announced in 2018 and the scheme opens in 2020).




Road Safety ++ +

Option 1 achieves the greatest possible benefit to road safety by 2030;

a total of 8-16 fatalities and 4-14 serious injuries are estimated by

2030, at a value of £18m-£43m.

Option 5 estimates a reduction of 3-15 fatalities and 2-15 serious

injuries by 2030 at a value of £7m-£40m.




Connectivity ++ +

Option 1 estimates an improvement in connectivity of 22-176 hours in

the year 2020, higher than Option 5

Option 5 estimates an improvement in connectivity of 11-88 hours.




Population and

Equality

+++ +++

For Option 1 and Option 5, the ban on HGVs with less than three stars

from the roads (by 2020) will improve the perception of safety for

vulnerable road users such as cyclists, younger population and

women.




Health and well-

being

++ +

Option 1 estimates induced cycle demand of 53,770 cyclists by 2030

and associated health benefits of £92m

Option 5 estimates induced cycle demand of 42,451 cyclists by 2030





Recommendation

Overall, although the benefits of DVS would positively improve the road safety of London, improve the

perception of road safety among the public and have a minor improvement on the environment, the magnitude

of the beneficial impact is insignificantly minor in comparison to the significantly high costs imposed on

businesses.

The very short time-scale of introducing DVS to the public (the Mayor intends to introduce DVS beginning of

2018) and the opening year of enforcement (2020) does not allow businesses sufficient time to be able to

comply with the original proposal (i.e. Option 1 – Outright Restriction), forcing thousands of HGVs to either be

replaced early or withdraw from entering London altogether.

Jacobs recommends taking Option 5 (HGV Safety System) forward for further consultation as the costs imposed

on businesses are significantly lower than Option 1 (outright restriction). Option 1 (outright restriction) should be

disregarded completely as it would prove to be too detrimental to businesses operating in London, and not

economically viable to implement.

and associated health benefits of £73m.


1. Glossary

Term Abbreviation Description

Automatic Number Plate Recognition ANPR A technology for automatically reading vehicle number plates.

Benefit Cost Ratio BCR An indicator, which summarises the overall value for money of a

project.

Casualty Impact Assessment CIA Casualty Impact Assessment produced by TRL, a consultancy

commissioned by TfL

Cost and Business Impact Assessment CBIA Cost and Business Impact Assessment produced by Jacobs, a

consultancy commissioned by TfL

Construction Logistics and Community

Safety

CLOCS An industry-led project to reduce injuries and deaths due to work-

related road risk.

Cycling Network Model for London Cynemon Developed by TfL, Cynemon is a model, which estimates cycling

routes, journey times and flows at a strategic level across London for

scheme and policy appraisal.

Department for Transport DfT Government department responsible for the English transport network

Direct Vision Standard DVS An objective measure of a HGV’s driver’s direct vision.

DVS Star Rating A simple description of an HGV’s DVS articulated on a zero (worst) to

five (best) star system

Economic and Business Impact

Assessment

EBIA Identifies and assesses impacts on London’s economy as a result of

the DVS

Gross Domestic Product GDP A monetary measure of the market value of all final goods and services

produced in a period of time.

Gross Value Added GVA A measure of the value of goods and services produced in an area,

industry or sector of an economy.

Fleet Operator Recognition Scheme FORS A voluntary accreditation scheme that promotes best practice for

commercial vehicle operators.

Integrated Impact Assessment IIA The IIA, produced by Jacobs, is a systematic and iterative process that

provides opportunity to consider ways by which a policy could

contribute to improvements in environmental, social and economic

conditions, as well as a means of identifying and mitigating any

potential adverse effects that the policy might otherwise have.

Internal Rate of Return IRR IRR is a method to calculate the rate of return of an investment.

Limited Liability Company LLC A corporate structure whereby the members of the company cannot be

held personally liable for the company’s debts or liabilities.

Light Goods Vehicle LGV Light Goods Vehicle (under 3.5 Tonnes Maximum Permissible Weight)

Loughborough Design School LDS From Loughborough University, LDS was commissioned by TfL to

develop the DVS rating system

Heavy Goods Vehicle HGV Heavy Goods Vehicle (over 3.5 Tonnes Maximum Permissible Weight)

Killed or Seriously Injured KSI A standard metric for safety policy.

N3 Vehicles over 12 Tonnes Maximum Permissible Weight


Term Abbreviation Description

N3G N3 class vehicles that operate off-road

Transport for London TfL Local government body responsible for the transport system in Greater

London

Transport Research Laboratory TRL Consultancy firm

Ultra-Low Emission Zone ULEZ An area within which all vehicles will need to meet exhaust emission

standards. ULEZ is due to be implemented in 2020.


2. Introduction

2.1 Background

The Mayor of London is adopting a ‘Vision Zero’ approach to road danger reduction based on the view that no

loss of life is inevitable or acceptable. The Mayor’s Vision Zero strategy is looking to make streets safer,

especially for cyclists and pedestrians by eliminating road danger at source. In September 2016, the Mayor of

London launched the world’s first Direct Vision Standard (DVS). The Mayor announced his intention to use the

DVS to ban or restrict the most unsafe ‘zero star’ rated HGVs from entering London by 2020 and only allow

vehicles with ‘good’ three-star direct vision ratings from 2024. Jacobs are supporting TfL to develop and assess

options for a DVS Scheme that reduces road risk, improves HGV/VRU casually rates, and does not undermine

the city’s competitiveness create a disproportionate cost to businesses operating in on serving London

An Integrated Impact Assessment (IIA) has been developed to support a Phase 2a Policy Consultation on the

Standard and is due to be launched in autumn 2017. To this end, Jacobs was commissioned by Transport for

London (TfL) to undertake a Cost and Business Impact Assessment (CBIA) of the scheme Options. The CBIA

would inform the IIA, a process that provides opportunity to consider ways by which the scheme Options could

contribute to improvements in environmental, social and economic conditions, as well as a means of identifying

and mitigating any potential adverse effects the proposed policy might otherwise have. TfL developed a number

of Options, hereafter referred to as the “scheme Options”, which were evaluated based on technical,

environmental, economic, social and other factors.

Ensuring that sustainable development objectives are embedded in the design and implementation of the

scheme has been the overall aim of conducting the IIA, and the wide range of sustainability issues relevant to

the proposal have been covered by the objectives used in the assessment.

2.2 Purpose of the IIA Report

The purpose of the IIA report is to evaluate the options developed by TfL under a Two-Tier Assessment:

Tier 1 Assessment – Option Sifting: To present the findings of the process of shortlisting the long list of five

scheme Options, considering initial costs and benefits identified in the CBIA report and Casualty Impact

Assessment (CIA) report; and

Tier 2 Assessment – Shortlisted Options: To consider the detailed impacts of the shortlisted scheme

Options, suggest mitigation measures and provide recommendations about the way forward.

2.3 Structure of the IIA Report

The report is structured as follows:

Section 3 provides brief introduction to the IIA report;

Section 4 describes the IIA approach and methodology;

Section 5 describes the Tier 1 assessment of the long list of the scheme Options;

Section 6 describes the Tier 2 assessment of the scheme shortlisted Options;

Section 7 provides summary of the likely significant effects of the scheme Options;

Section 8 provides summary of the cumulative effects;

Section 9 outlines details about transboundary effects;

Section 10 describes mitigation measures for the proposed scheme Options;

Section 11 provides conclusions; and;

Section 12 outlines next steps and details about public consultation.


2.4 Public Consultation

At the time of writing this IIA report, it was anticipated that public consultation on the publication of the scheme

proposals and the accompanying IIA Report, with public stakeholders being invited to comment upon the

findings of the IIA Report and its recommendations, would take place in autumn 2017.

2.5 Stakeholder Engagement and Consultation to Date

A phased, comprehensive period of public and industry consultation is necessary before the Mayor’s plans can

be implemented and is taking the following approach:

Phase 1 (24 January and 18 April 2017) - presented the technical scheme concept and the evidence

gathered to date with a view to collecting views on the scheme. It also aimed to collect important

information on the impacts on all stakeholders, particularly HGV operators, manufacturers and the wider

freight industry. The results have been analysed to inform this IIA report and would be published as part

of the Mayor’s consultation plans in autumn 2017.

Phase 2a (Autumn 2017) - will be informed by Phase 1 and will set out the final scheme proposals for

public consultation, the complete evidence base, the Integrated Impact Assessment on the impacts of

the proposals and respond to any technical issues and concerns raised in Phase 1.

Phase 2b (by Spring 2018) – a statutory consultation on the appropriate mechanism that would

implement any ban or other restrictions on zero-rated or low-rated HGVs e.g. Traffic Regulation Order.


3. Strategic Objectives of the Standard

3.1 The Mayor’s Transport Vision for London and Road Safety – Vision Zero

The Mayor’s vision for London, set out in his draft Transport Strategy (June 2017) is to create a future London

that is not only home to more people, but is a better place for all of those people to live in.

The Mayor believes that the success of London’s future transport system relies upon reducing Londoners’

dependency on cars in favour of increased walking, cycling and public transport use.

Minimising road danger is fundamental to the creation of streets where everyone feels safe walking, cycling and

using public transport. Road danger disproportionately affects people travelling on foot, by cycle or by

motorcycle, with 80 per cent of all those killed or seriously injured on London’s roads travelling by these modes.

Safety concerns are the main reasons people give for not cycling more, and for being unwilling to let their

children walk unaccompanied.

The safety concerns have led to the Mayor’s proposal to adopt Vision Zero for road danger in London. This

means that road danger will be targeted at its source by ensuring the street environment incorporates safe

speeds, safe people, safe street design and safe vehicles. It means reducing the dominance of motor vehicles

on streets, and then making the remaining essential motorised journeys as safe as possible. The Mayor’s aim is

to work towards eliminating all deaths and serious injuries from road collisions from London’s streets by 2041.

3.2 Using the Standard for Large HGVs to Support Vision Zero

In September 2016 TfL launched the world’s first Standard for HGV (over 12 tonnes), designed to reduce the

danger posed by HGVs to cyclists and pedestrians.

Previous research had identified that HGVs were substantially over-involved in fatal collisions with vulnerable

road users and that in certain close proximity manoeuvres, blind spots appeared to be a contributory factor with

a large proportion of the vehicles being of ‘off road’ specification and relatively high from the ground. Studies of

the field of view through the windscreen of HGVs, direct vision, suggested that the direct vision was poorer from

this type of vehicle. In response to these findings, two scheme Options were put forward for consideration and

further detailed analysis:

Option 1 – Outright Restriction: ban N3 class vehicles rated zero stars by 2020 and those rated

below three stars by 2024. (All N3 HGVs to apply for permit to prove star rating); and

Option 5 – HGV Safety Mitigation Scheme: all vehicles rated 1 star or better automatically given a

permit from 2020 and vehicles rated at least 3 stars or better automatically given a permit from 2024.

Permits to enter London are only issued to zero star vehicles from 2020 (or zero, one or two star from

2024) where they can prove they have fitted appropriate additional safety equipment.

Two scheme Options were taken forward to the full detailed IIA, assessment of which is the subject of this IIA

report, enabling TfL to analyse the cost and safety benefits of the proposed scheme Options as well as to look

at their wider environmental, social and economic effects through the IIA process. The IIA process had

examined which of the above Options could offer greater sustainability benefits at the proportionate cost and

without undermining London’s competitiveness, determine the magnitude of these benefits and assessment of

the Value for Money.

3.3 Ultra-Low Emission Zone (ULEZ) Proposals and Consultation

In parallel to this scheme, TfL has also been working on delivering options to implement the Mayor’s proposals

to improve Air Quality, including ULEZ, which is another proposal put forward by the Mayor as part to this vision

for London to create a future London that is a better place for all to live in. The ULEZ proposals will also affect

HGV operators and are to be implemented in similar timescales. High level proposals include requiring HGVs to

meet Euro VI emissions standards, by bringing the ULEZ forward from 2020 for all vehicles in central London,

extending it further to the North and South Circular, and applying ULEZ emissions standards for HGV, buses

and coaches London-wide in 2019 (or later). Against this background, HGV operators considering upgrading


their fleets to meet the ULEZ emission standards should consider vehicles that have a higher Standard star

rating.


4. IIA Approach

4.1 What is an IIA?

The IIA is an assessment tool that uses an integrated appraisal approach across a number of relevant topics to

measure the potential impacts of the scheme shortlisted Options, selection of which has been informed by the

Cost and Business Impact Assessment (CBIA) study and the Casualty Impact Assessment (CIA). The IIA is a

systematic and iterative process that provides an integrated appraisal of potential impacts and benefits that can

occur as a result of the DVS Scheme Options.

Starting with the Tier 1 assessment (i.e. Option Sifting) of the long list of potential five scheme Options using

findings of CBIA and the safety studies prepared by Transport Research Laboratory (TRL), both of which are

the integral part of the IIA. The outcome of Tier 1 assessment (Option Sifting) informs the Tier 2 Assessment - a

more detailed evaluation of the shortlisted scheme Options 1 (Outright Restriction) and 5 (HGV Safety System)

against ‘Do Minimum’ scenario, assessment of which is the main focus of this IIA report.

The purpose of the IIA is to promote sustainable development by assessing the extent to which the emerging

scheme, when judged against reasonable alternatives, will help to achieve relevant environmental, economic

and social (including health, equality and community safety objectives). The output of this assessment is a

single IIA report that has enabled synergies and cross-cutting impacts to be identified as part of an iterative

approach to the assessment.

4.2 Requirements for IIA

The scheme would be implemented through existing policies covered in the Consultation Draft MTS 3 that has

been subject to Strategic Environmental Assessment (SEA) and a Traffic Regulation Order. There is no

requirement to carry out a SEA for the scheme-level proposals, however, the process of selecting the right

option for this proposal should be handled in a thorough and robust manner.

TfL’s view is that the implications of the scheme would be best understood through full assessment of the

scheme in relation to the environment, health, equality, road safety and economic and business impacts. The

IIA brings together the findings of each of these assessments into one concise integrated document.

TfL considers that undertaking an IIA is critical to clearly articulate and identify key impacts associated with the

proposed scheme Options including how identified negative impacts can be avoided and mitigated where

possible, and positive impacts enhanced.

This report takes into consideration relevant legislative requirements, policy and guidance including:

Directive 2001/42/EC ‘on the assessment of the effects of certain plans, and programmes on the

environment’ (European Commission, 2001) i.e. the SEA Directive.

Environmental Assessment of plans and programmes Regulations 2004 (SI 2004 No 1633)

A Practical Guide to the Strategic Environmental Assessment Directive (ODPM, 2005).

Equality Act 2010

The Crime and Disorder Act 1998 (as amended) and the Police and Justice Act 2006 (as amended)

Traffic movement duty under Road Traffic Act 1984;

Network management duty under Traffic Management Act 2004.


4.3 Stages of the IIA Process

The IIA process has been carried out in two stages:

Stage 1: Developing the scope, policy context, key issues and assessment framework (IIA objectives)

Stage 2: Conducting the Tier 1 and Tier 2 IIA assessments (including assessment of cumulative effects

with the Ultra-Low Emissions Zone (ULEZ)), where appropriate, and reporting (including mitigation and

recommendations where applicable).

4.3.1 Stage 1 of the IIA Process

Developing the assessment framework

The first stage of the IIA process was completed in June 2017 and set out the scope, context and assessment

framework with relevant IIA objectives. The assessment framework was developed through reviewing the

relevant policies, identifying the key sustainability issues (to inform the IIA objectives), and development of

relevant IIA objectives (against which to assess the performance of the proposal).

The IIA objectives deemed relevant to the scheme have been taken forward and the ones that are not have

been scoped out.

Review of relevant legislation and policies

A review of the relevant legal and policy context for the IIA helped to define the right assessment scope for the

scheme by identifying specific issues and policy objectives surrounding this proposal. A brief summary of the

legal and policy documents reviewed to inform the IIA framework is provided in Appendix A.

Identification of sustainability issues for DVS scheme

A review of relevant plans, programmes and policies as well as the results of stakeholder engagements has

identified a number of issues that need to be taken into consideration when developing the scheme Options and

the IIA objectives. The main purpose of the proposed scheme is to address the following issues:

Safety on the roads;

Reduce casualties resulting from the HGVs collisions while at the same time reducing the impacts of

cost on businesses associated with introduction of the new standard by 2020; and

Introduction of which will happen in the similar short timeframes with the new ULEZ proposals.

Therefore, these issues are likely to be significantly and directly affected by the scheme. However, it is a

requirement of the IIA to look at the wider sustainability issues including environmental, economic and social

when assessing the sustainability performance of the shortlisted scheme Options.

For full details of the sustainability issues identified for the scheme, please refer to Appendix B.

Identifying relevant IIA objectives

The IIA objectives provide a means by which the environmental, social and economic performance of the

scheme proposals can be assessed. IIA objectives are used to show whether the scheme proposals are

beneficial for the achievement of sustainable development, to compare the sustainability effects of alternatives,

or to suggest improvements.

We have already undertaken a scoping exercise during the first stage of the IIA when the likely impacts of the

scheme proposal against the objectives used in the similar IIAs undertaken for the ULEZ and the Revised

Mayor’s Transport Strategy 3 have been identified. The results of this can be seen in Appendix B and based on


this it was recommended that a number of environmental issues were to be scoped out of the IIA on the basis

that the scheme would not have any material effects (beneficial or adverse) on their achievement. A rationale

for their exclusion has been included in Appendix B.

The draft IIA objectives have been developed in accordance with:

The findings from the review of relevant plans and programmes, and data gathered during

scoping;

Consultation with the TfL;

Feedback from the key stakeholders.

The IIA framework includes nine IIA Objectives which address each of the five components of the IIA, i.e. EqIA,

HIA, EA, CSIA and EBIA. Alongside each IIA objective is a set of potential impacts against each IIA objective.

This has allowed a focused assessment to be carried against each topic where potential impacts were

quantified to identify the nature of those impacts based on the evidence presented in the EBIA and CIA studies.

Table 4-1 presents the IIA objectives and associated potential impacts of the scheme and signposts the reader

to the relevant IIA assessment component and the studies that have been determining those quantified impacts

and benefits.

Table 4-1: Proposed DVS IIA Assessment Framework

Topic IIA objective DVS Potential Impacts Assessment

component/Study

Environmental Assessment

Air Quality 10. To contribute to a reduction in

air pollutant emissions and

compliance with EU limit values

Reduction in NOx, PM10 and

PM2.5 emissions as a result

of the reduced congestion

and diversion from collisions

avoided

CIA

Climate change

mitigation

11. To reduce CO2

emissions and contribute to the

mitigation of climate change

Reduction in CO2 emissions

as a result of the reduced

congestion and diversion

from collisions avoided

Economic and Business Impact Assessment

Economic

competitiveness

and

employment

12. To provide a high quality

environment that will help to

attract and retain internationally

mobile businesses.

Increased costs of doing business in London due to a requirement to replace non-compliant vehicles.

CBIA

EBIA

Economic

Sectors

13. Encourage the development

of new businesses in new and

growth and specific sectors

Significant increase in costs to operate HGVs for Small and Medium Enterprises

Distributional impact on different industries for e.g. Construction.

Community Safety Impact Assessment

Road Safety 14. To contribute to safety and

security and the perceptions of

safety5

Reduction of the number of

collision casualties

CIA

5 The DVS scheme is concerned with the design of the HGVs and thus will not have direct impacts on the crime and disorder. These issues as well

other Road Traffic Act duties have been streamlined through the selection of the road safety related IIA objective 5 and IIA objective 6 to ensure


Topic IIA objective DVS Potential Impacts Assessment

component/Study

Connectivity 15. To contribute to the

avoidance, elimination or

reduction of road congestion or

other disruption of the

movement of traffic

Reduction in the total delay in monetary values

Equality Impact Assessment

Population and

Equality 16. To reduce the number of

casualties from protected

groups as a result of HGV

related accidents

Reduction in casualty rates

of protected groups and

disadvantaged communities

from HGV related accidents

Improvement in the

perception of safety for

cyclists leading to an

increase in active travel

CIA

EqIA 17. To advance equality of

opportunity of small and

medium enterprise owned by

protected and disadvantaged

groups.6

Disproportionate impacts of

the DVS scheme costs for

Small and Medium

Enterprises and specific

sectors

Health Impact Assessment

Health and well-

being

18. To contribute to enhanced

health and wellbeing for all

within London

Reduced fatalities and

injuries as a result of the

scheme

Monetised value of

increased physical activity

due to changes in cyclist

demand as a result of the

scheme

Increase in active travel

(cycling and walking) due to

improvements in perceptions

of road safety

CIA

EBIA

4.3.2 Stage 2 of the IIA Process

The second stage of the IIA process focused on developing the long list of the scheme Options (initially five

Options were considered for the scheme) and conducting the Tier 1 assessment (Option Sifting) of these

options through CBIA and the initial findings of the CIA studies. This enabled TfL to make an informed decision

about the costs and benefits of the long list of Options, prior to shortlisting Options for the Tier 2 assessment - a

more detailed IIA incorporating EBIA, HIA, EqIA and CSIA elements of the IIA.

A subsequent detailed IIA of the shortlisted scheme options against the ‘Do Minimum’ scenario has been

carried out using the IIA framework consisting of nine IIA objectives. The sustainability performance of each of

these shortlisted options has been assessed and compared to determine which of these Options provided the

the overall conformity with Road Traffic Act duties in respect of safety, movement of traffic and congestion elimination. Testing the DVS scheme Options against this tailored IIA objectives ensures their compliance with those duties.



greater amount of sustainability benefits at a proportionate cost and without undermining London’s

competitiveness. The Tier 2 assessment of the shortlisted options also included assessment of cumulative

effects with new ULEZ proposals.

4.4 Spatial Scope of the IIA

The spatial scope refers to the geographic area that is covered by the IIA. The principal spatial scope for the IIA

is the GLA area.

For IIA purposes, the geographical area is specific to the Greater London area. However, in reality most

businesses which operate in Greater London also serve areas outside of London. The impacts assessed under

the IIA are most likely to be imposed more on a national basis and to an extent international basis (for multi-

national corporations). However, the impact on a national basis has not been assessed under the IIA.

4.5 How will the IIA process influence the development of the scheme proposals?

From the outset, the IIA process has sought to actively influence the development of the scheme proposals,

with the objective of enhancing its sustainability. To facilitate this, there was close and ongoing interaction

between the TfL scheme drafting and IIA teams, with the aim to provide continuing review and advice on the

sustainability of the scheme proposals. The central components of the interrelationship between the IIA and the

preparation of the scheme proposals were:

Early engagement between the IIA and the TfL scheme drafting teams to determine the issues and

challenges for progressing the scheme proposals development in Greater London;

Workshops undertaken jointly with the TfL scheme drafting team to provide feedback and review on the

development of proposals; and

IIA personnel working alongside the TfL scheme team to input into the drafting of the scheme proposals

through ongoing liaison.

4.6 Proposed Methodology for Each Element of the IIA

Prior to the commencement of the full detailed IIA of the shortlisted Options, the initial Tier 1 (Option Sifting)

assessment has been carried out on the long list of Options that was informed by the CBIA and the CIA, details

of which can be found in Appendix D and Appendix E of this report.

The IIA adopts the recommended single integrated approach, whereby the options were considered from five

different topics. The IIA consists of a range of assessments undertaken separately by either Jacobs or TRL:

Economic and Business Impacts Assessment (EBIA) informed by the CBIA and CIA.

Environmental Assessment (EA);

Equalities Impact Assessment (EqIA);

Health Impact Assessment (HIA); and

Community Safety Impact Assessment (CSIA) informed by CIA and prepared by TRL.

The Options assessed for the IIA were measured against the baseline scenario, the Do Minimum. The Do

Minimum scenario informs consumer choice and is incentivised through public sector procurement. However,

compliance with DVS is not mandated and is not considered a restriction scheme.

Table 4-2 below summarises the description of each element of the IIA, their likely impacts and brief

methodology of the assessments, outlining those informed by the CBIA or/and the CIA.


A detailed methodology for each assessment can be found in Appendix C of this IIA report.


Table 4-2: IIA Topics Assessment and Methodology

Topics

Description

Key Issues Potentially Influenced by the DVS

Scheme

How the IIA will assess the topic

Environmental

Assessment

(EA)

Identifies and assesses the impacts across

a range of environmental issues as a result

of the scheme including: air quality and

climate change mitigation.

The scheme impacts on these topics will be

identified by analysing the greenhouse and

harmful air quality emissions (NOx, PM and

CO2) changes due to reduction of the

collision accidents.

High levels of NOx, PM10 and PM2.5 emissions

from road transport

London is not compliant with legal limit values for

NO2 and PM10.

Large numbers of the population are exposed to

levels of NO2 above the EU limit value. This

tends to be those who are also more susceptible

to the health effects of air pollution.

HGVs are expected to contribute a higher

proportion of CO2 emissions in the future.

The EA would analyse the greenhouse and harmful

air quality emissions (NOx, PM and CO2) changes

due to reduction of the collision accidents.

They have been calculated by TRL using casualty

impacts analysis using calculations for congestion

and diversion resulting from traffic accidents.

Defra’s Emission Factors Toolkit (EFT) has been

used to calculate the emissions from the traffic. The

input to this is the vehicle flows and speeds.

Health Impact

Assessment

(HIA)

Identifies and assesses impact on the

health and wellbeing of the population of

Greater London by identifying: Reduced fatalities and injuries as a

result of the scheme; Monetised value of increased

physical activity due to changes in cyclist demand as a result of the scheme; and

Increase in active travel (cycling) due to improvements in perceptions of road safety.

The HIA will also examine the whether the

scheme would make pedestrians more at

ease as well, particularly vulnerable ones

who feel intimidated crossing roads, e.g.

older people, children and disabled people

and will be reported as non-quantified

benefits.

The Mayor has an ambition to increase the

proportion of people cycling and walking.

Many Londoners are not doing enough physical

activity each day, affecting their overall health

(low rates of physical activity are linked to a

range of health issues including the leading

causes of premature death: cancer,

cardiovascular disease and strokes, as well as

obesity and poor mental wellbeing).

Reducing fear on the streets is an essential

element in encouraging more use of walking as a

means of transport in London and as a form of

physical activity. Perception of poor road safety is

a deterrent to more people taking up cycling and

for pedestrians.

The World Health Organisation’s (WHO) Health

Economic Assessment Tool (HEAT) will provide

monetised values of health benefits of increased

physical activity due to increase in cycling demand in

London.


Equalities

Impact

Assessment

(EqIA)

Identifies and assess impact on equalities

issues, in particular those groups of

people with protected characteristics or

are socio-economically disadvantaged. It

will focus on:

Reduction in casualty rates of

protected groups and disadvantaged

communities from HGV related

accidents;

Improvement in the perception of

safety for cyclists leading to an

increase in active travel; and

Disproportionate impacts of the

scheme costs for Small and Medium

Enterprises and specific sectors.

Disproportionate effects of costs on businesses

owned by protected and disadvantaged groups.

The potential impacts have been determined using a

combination of data outputs from traffic modelling,

Geographical Information Systems (GIS) mapping

and technical professional judgement.

Baseline data has been compiled from a wide range

of sources including Census 2011, IMD2010, and TfL

surveys and research.

The scale of impact has been defined as positive,

negative or neutral and disproportionate or

differential, based on best-practice guidance and

professional judgement.

Economic and

Business

Impact

Assessment

(EBIA)

Identifies and assesses impacts on

London’s economy as a result of the

scheme and identifies potential impacts on

small to medium sized enterprises (SMEs).

An economic model that compares benefits

and costs of alternative implementation

options and sensitivities with a “Do

Minimum” baseline has been produced for

the IIA. Findings and recommendations

from the TRL CIA will be incorporated into

the model.

The EBIA is the essential technical

assessment that provides the quantitative

analysis and data that informs other

elements of the IIA such as health and

equality impact assessments.

High freight vehicle kilometres on the road

network adding to congestion.

Congestion on roads reduces economic output.

Retail and wholesale distribution, and

construction are the main sectors served by

HGVs, which are likely to be affected by the DVS

proposals.

Costs of compliance to industry and knock on

economic costs.

Restricting access and reducing freedom of

movement restricting market and reducing city’s

competitiveness. Cumulative costs to businesses

associated with both proposed schemes for DVS

and ULEZ happening in a similar timeframe.

Operators delaying purchases of ULEZ compliant

vehicles due to uncertainties with the standard.

Disproportionate effects of costs on specific

industry sector or on SMEs.

Costs: informed by the CBIA

Benefits: informed by the CIA

Calculation of Net Present Value (NPV)

Calculation of the Benefit-Cost Ratio (BCR), an

economic indicator which measures the return on the

investment of a project


Community and

Safety Impact

Assessment

(CSIA)

Identifies the quantity of casualties that

could be affected by the scheme proposals,

profile of casualties involved and the

associated costs, as well and congestion

and emissions savings associated with the

reduced casualties.

The primary objective of the CIA

requirement is to identify and objectively

assess the impact in terms of reducing the

numbers of people killed and seriously

injured associated with the scheme

proposals.

The CIA will measure the benefits for

London by quantifying expected casualty

changes from current and future baselines.

A London-specific CIA of the scheme will

inform the IIA and development of the final

scheme.

The number of vulnerable road users

(pedestrians and pedal cyclists) that are killed or

seriously injured in collisions involving Heavy

Goods Vehicles (HGVs) is disproportionate to

those involving other types of vehicle.

Construction type vehicles (e.g. 4 axle rigid

tippers) are substantially over-represented in the

data regarding these collisions.

Between 2011 and 2015, there were a total of 80

VRU fatalities in collisions in London where

heavy goods vehicles were involved.

Safety concerns are a barrier to active travel and

contribute to inactivity, which, in turn, has impacts

on health and wellbeing.

During the period 2011-2015, between 129 and

159 people were killed on London’s roads each

year, with the number of fatalities staying fairly

constant from 2012.

Mayoral objective to achieve a 40 per cent

reduction in the number of people killed or

seriously injured on the Capital’s roads by 2020.

To prioritise safety of the most vulnerable groups

– pedestrians, cyclists and motorcyclists – which

make up 80 per cent of serious and fatal

collisions.

Casualty Impact

Defining the target population of collisions estimated

by TRL

Congestion Effects

An average vehicle delay was calculated from the

Stats19 accident data merged with traffic data from

TfL’s Automatic Traffic Counter Networks.

The total delay was turned into a monetary value

using the values of time from DfT’s WebTAG.

Emissions Effects

Defra’s Emission Factors Toolkit (EFT) has been

used to calculate the emissions from the traffic.

The input to this is the vehicle flows and speeds.

Normally, AADT (annual average daily traffic) are

used, but for this work TRL has used the hourly

flows and speeds, collated over all the lanes for

each direction.

Direct Vision Standard Integrated Impact Assessment: IIA Report

4.6.1 Predicting the effects of the scheme against the IIA objectives

A symbol based scoring system has been employed to record the findings of the assessment of the scheme

Options and measures against the IIA objectives as per Table 4-3. In determining the significance of impacts in

the IIA, account has been taken of the criteria set out in of Schedule 1 of the SEA Regulations including the

scale or magnitude of change, the value and vulnerability of receptors affected and the probability, duration,

frequency and reversibility of impacts. In terms of duration effects has been defined as:

Short-term effects – those effects that occur within the first five years of implementation of the scheme;

Medium to long-term effects – those effects that occur beyond five years of the implementation of the

scheme;

Long-term effects – those effects that will occur beyond fifteen years.

The assessment has considered the inter-project cumulative effects, whereby significant effects of the scheme

act in combination with the effects of other relevant Mayoral proposals (e.g. ULEZ).

Table 4-3: Significance ratings and definition

Scale of effect Definition

+++ Major positive effect Scheme contributes greatly towards achieving the IIA

objective/significant effects

++ Moderate positive

effect

Scheme contributes to achieving the IIA objective

+ Minor positive effect Scheme makes minor contribution to the IIA objective

0 Neutral or no effect Scheme does not impact upon the achievement of the IIA

objective

- Minor negative effect Scheme has minor tensions with the IIA objective

- - Moderate negative

effect

Scheme hinders or prevents the achievement of the IIA

objective

--- Major negative effect Scheme greatly hinders or prevents the achievement of the

IIA/significant effects

? Uncertain Scheme can have positive or negative effects but the level

of information available at a time of assessment does not

allow to make a clear judgement

However, the symbol based scoring system does not allow comparison of the scores across the IIA objectives.

For example, the magnitude of the score of positive two plusses (++) for an environmental objective is not

comparatively equal to the magnitude of the score of positive two plusses for an economic objective. If, for

example, a positive (++) environmental benefit of £9 million per annum is estimated, this positive score may be

insignificantly minor in comparison to an economic benefit (++) of £50 million per annum. The scale of the

impact outlined in Table 4-3 differs across the IIA objectives.

4.7 Development of the Scheme Options

The opportunities to use the Standard to restrict access are limited by what is practically enforceable. This is

because the Standard is a novel technical standard and does not exist in law (e.g., it cannot be identified from

existing vehicle registration data). Therefore, any scheme Option that uses the Standard rating will have to


either a) require all large HGVs entering London to have a permit, proving their DVS star rating, or b) restrict

vehicles based on other already identifiable criteria.

The core proposal (Option 1) is that all large HGVs (i.e. N3 class, over 12 tonnes) wishing to enter London must

apply for a permit in order to prove their Standard star rating. A permit would not be issued to any vehicles with

a zero-star rating from 2020, and would not be issues to any vehicles with a zero, one or two-star rating from

2024.

Any scheme that outright bans a large number of vehicles relative quickly will remove the highest number of the

least safe vehicles but will result in a high compliance cost.

TfL have commissioned two independent reports to consider the indicative cost and safety impacts of the

scheme Options under consideration. The CBIA report considered a core “outright restriction” option, and four

additional options designed to reduce the scheme cost. The safety/CIA report has tested the “highest benefit”

and “lowest cost” scenarios. The results of these two reports enabled TfL to shortlist scheme Options for a full

IIA to investigate further the magnitude of their effects and the proportionality of their benefits to the cost of the

scheme shortlisted Options.

4.7.1 Four Step Scheme Options Development Approach

The selection process of the scheme Options to be taken forward to public consultation has been carried out in

four steps and is presented in Figure 4-1 below:

Step 1 - based on existing collision data, practical concerns and consultation feedback (Phase 1 and workshops) TfL has defined a shortlist of possible scheme Options to test and take to a detailed IIA assessment. When sifting through Options, TfL has given regard to the three pillars informing developing scheme options to consult on:

1. The right legal tool:

A ban not a charge – because ‘unsafe’ vehicles should not be able to pay to enter.

Use of a Traffic Regulation Order (TRO) enables a ban and TfL reviewed different

options for doing so.

2. Practical enforceability:

The Standard is neither a pre-existing standard nor easily identifiable visually (unlike

Safer Lorry Scheme).

Enforcement creates constraints on scheme design.

Two core options: A permit scheme – operators to prove compliance beforehand. A proscribed list of vehicles – what can we observe that matches a risk? (E.g.

Construction) but data show vehicles beyond construction are involved.

3. A proportionate scheme supported by evidence: Specialist consultants appointed to assess collision and economic impacts. Which variables can be used to refine the core options? The impacts have been assessed to inform decision making. Practical implementation through and enforce i.e. through a TRO and use of a permit

scheme. The need to develop a scheme proportionate to the problem of HGV and VRU safety. Subset of vehicles overrepresented within the statistics (i.e. construction).


Figure 4-1: Scheme Options Development and IIA Interactions

When developing options TfL has also given consideration to the following: The pace of implementation was ambitious and application to new vehicles only would be

more practical and reduce costs. TfL should recognise safety measures beyond direct vision and what industries were

already doing in this space. TfL need to work towards the alignment of existing schemes for HGVs in London e.g.

Safer Lorry Scheme and ULEZ, which would be London wide.

Emerging impacts in terms of scale and cost as the IIA and collision impact analysis was

being carried out: Geography – no concentration in Central London and enforcement complexity suggests

an all London scheme. HGVs beyond construction industry were also involved in collisions and should not be

the only vehicle looked at to achieve Vision Zero.

The initial CIA studies indicated at an early stage that an outright restriction ban of 0 star vehicles or, off-road

vehicles as a proxy, would have costs one or two orders of magnitude greater than the benefits even if all

vulnerable road user casualties in London were eliminated. Thus, some of the options initially identified for

examination, such as limiting the geographical area that the ban would be applied to, or limiting the times of day

at which it would apply, were unlikely to substantially change the overall conclusions.

IIA Report for Phase 2 Consultation

Testing Shortlisted Options against IIA Objectives

Environmental Assessment (EA) Community & Safety Impact

Assessment (CSIA) Health Impact Assessment (HIA) Equality Impact Assessment (EqIA) Business Impact Assessment (EBIA)

Tier 2 Assessment of Option 1 & Option 5 (STEP 4) (Section 6)

Option 1 and Option 5 shortlisted (STEP 3) (Section 5.4)

Testing "highest benefit" & "lowest cost" scheme scenarios

Safety Report (TRL) Cost & Business Impacts Assessment Report (CBIA) (Jacobs)

Tier 1 Assessment of 5 Scheme Options (STEP 2) (Section 5)

Long list of 5 Scheme Options developed (Section 5 )

Problem definition (STEP 1) (Section 3) HGV Populatin Report

(TRL) Rating Tables

(Loughborough) ANPR Data Stats 19 Data Operator Survey Stakeholder Interviews Focus Groups Results

Phase 1 Consultation Responses


Step 2 – Tier 1 assessment (Opting Sifting) has calculated an estimation of cost to businesses and the cost of enforcement and operation of each of the five Options as well as tested the “highest benefit” and “lowest cost” scenarios through the safety report that can be found in Appendix D of this report. The summary results of the CBIA and safety report study can be found in the next Section of this report. The full CBIA report can be found in Appendix E of this IIA report.

Step 3 – Based on the findings of Step 2, Options were shortlisted via option sifting based on the cost estimation results and safety report that has tested the “highest benefit” scenarios.

Step 4 – Tier 2 assessment – a full IIA of the shortlisted Options against the Do Minimum – Baseline Option was carried out to inform the decision maker about the potential impacts and benefits of each of the shortlisted Options to make a meaningful comparison. The full IIA is comprised of the estimation of the costs, benefits and the benefit-cost ratio, environmental, inequality, health and economic impacts of the shortlisted options. Recommendations have been provided about the option with greater sustainability benefits and at a proportionate cost.


5. Tier 1 Assessment – Option Sifting

This section presents the findings from the CBIA undertaken by Jacobs, used to shortlist the five options

provided by TfL to test. The shortlisted options were taken forward for further assessment under the CIA,

conducted by TRL.

In conformity with the Option Sifting Process described in Section 4.7.1, TfL developed five Options presented

in Table 5-1 below.

Table 5-1: Five initial options developed by TfL

Scheme Options Description

Do Minimum – informing consumer

choice and incentivised through

public sector procurement

The DVS being used to inform purchasing decision but not being mandated. There is no restriction scheme.

Option 1 – Outright restriction

All N3 HGVs to apply for permit to prove star rating. Ban zero star rated N3 HGVs from 2020 and less than three star rated HGVs from 2024.

Option 2 – Phased outright restriction

All N3 HGVs to apply for a permit to prove their star rating. As for option 1, but ban only applies to newly registered vehicles up to 2024.

Option 3 – Outright restriction with

transitional mitigation

All N3 HGVs to apply for a permit to prove their star rating. As for

option 1, but some zero star rated HGVs may be issued with a permit if

they can demonstrate mitigating safety measures.

From 2024, not mitigation is accepted (i.e. the scheme is per Option 1 (outright restriction).

Option 4 – N3G ban Without the need for a permit, prohibit all N3G class vehicles from 2020.

Option 5 – HGV safe system scheme

All N3 HGVs to apply for permit to prove a safe system standard is

met.

All vehicle rated 1* or better on DVS automatically given permit (from

2020, 3* from 2024).

Permits only issued to vehicles 0* (from 2020, less than 3* from 2024) where they can demonstrate they are “above par” on a number of key safety aspects.

The options outlined above would be assessed in the CBIA.

5.1 Assessment summary results from the CBIA

Jacobs was commissioned by TfL to undertaken the Cost and Business Impact Assessment (CBIA) of the five

shortlisted Options provided by TfL for the scheme. The CBIA has assessed the cost to businesses and the cost

to the Public Sector based on the number of vehicles forecasted to borne financial cost as a result of the

scheme. This section provides the costs considered in the CBIA and the subsequent findings of the cost

estimation. For full details of the CBIA, please refer to Appendix D of this report.


5.1.1 Cost to the Public Sector

Jacobs considered the costs to set up, operate and enforce the scheme. TfL identified the following

implementation and operating costs at this stage includes the cost of certification, staff, permit and data

administration and ANPR maintenance.

Cost to Businesses

Jacobs has identified the potential costs to businesses through field research, consultation with stakeholders

and manufacturers, previous experience of similar policy implementations and professional judgement &

expertise. Please note, for economic analysis purposes, all businesses affected by the Standard are assumed

to comply with the mandate i.e. no HGVs would enter London illegally. No fines imposed on businesses would

be considered in the analysis.

For each sector, the following costs were considered as quantifiable at this stage:

Purchase of compliant vehicles – the financial impact of replacing your vehicle early to meet

compliance

Withdrawal of vehicles – the financial impact of withdrawing non-compliant vehicles from serving the

Greater London market

Safety mitigation features – under Option 3 (Outright Restriction with Transitional Mitigation) and 5

(HGV Safety Mitigation Scheme), the cost of retrofitting the existing, zero-rated vehicles to be “above

par” zero stars temporarily

Wider impact on the economy – a high level assessment of the impact of the withdrawal of vehicles

from serving the Greater London market

Certification of Vehicles – cost of certification and the Standard assessment of every vehicle

Safety Mitigation Measure Assessment – the cost of assessing the compliance of safety mitigating

measures/equipment installed for vehicles opting to retrofit for Option 3 and Option 5.

Businesses may incur in other costs that have not been quantified at this stage but analysed qualitatively:

Loss of residual value – vehicles rated below 3 stars would be expected to lose residual value as a

result of the scheme (i.e. fall in demand non-compliant vehicles)

Downtime due to the change in fleet – the additional time spent adjusting the fleet to comply with the

DVS scheme

Switching manufacturers – purchase of new, three star rated vehicles from another manufacturer may

incur the indirect cost of additional training for drivers and mechanics and purchase of additional

equipment/features compatible with the new manufacturer produced vehicles

Findings of the CBIA

The following table presents the summary of the quantified costs to businesses and public sector over the 10

year appraisal period from the year 2020 for all Options. The lower height estimate of non-compliant vehicles is

considered to be the “best case” scenario; the lower the height of the HGV cab, the more the driver has of the

direct vision of their surroundings, particularly vision of surroundings in close vicinity of the front windows. The

higher height estimate of non-compliant vehicles is considered the “worst case” scenario. Please note, referral

to “non-compliant” vehicles means the latter do not comply with the conditions of the Option.


Table 5-2: Summary of the total cost of the scheme (undiscounted), £000s

Costs, £000s

Option 1 – Outright Restriction

Option 2 – Phased Outright

Restriction

Option 3 – Outright

Restriction with Transitional

Mitigation

Option 4 – N3G Ban

Option 5 - HGV Safety

System

Low

High

Low

High

Low

High

Low

High

Low

High

Cost to Businesses

Early Replacement 572,000 728,000 195,000 390,000 195,000 390,000 87,000 111,000 - -

Withdrawal 7,224,000 29,850,000 4,918,000 4,990,000 4,755,000 4,990,000 19,429,000 26,219,000 - -

Safety Mitigation Measures - - - - 262,000 298,000 - -

381,000

403,000

Vehicle Certification 19,000 19,000 19,000 19,000 19,000 19,000 19,000 19,000

19,000

19,000

Safety Mitigation Test - - - - 114,000 130,000 - -

235,000

254,000

Total Cost to Businesses

(1) 7,815,000 30,597,000 5,132,000 5,399,000 5,345,000 5,827,000 19,535,000 26,349,000 635,000 676,000

Cost to the Public Sector

Implementation 8,000 8,000 8,000 8,000 8,000 8,000 8,000 8,000 8,000 8,000

Operating 6,000 6,000 6,000

6,000 6,000 6,000 6,000 6,000

6,000

6,000


Total Cost to Public

Sector (2) 14,000 14,000 14,000 14,000 14,000 14,000 14,000 14,000 14,000 14,000

TOTAL COST (1)+(2) 7,829,000 30,611,000 5,146,000 5,413,000 5,359,000 5,841,000 19,549,000 26,363,000 649,000 690,000


The key findings of the cost to businesses assessments are as follows:

Option 1 (outright restriction) presents the highest and largest range of costs, ranging from £8 billion to

£31 billion, forecasted to impose substantial cost across all sectors as result of the high cost of early

replacement of vehicles not compliant to the conditions of Option 1 and the impact of withdrawing non-

compliant from entering London.

Option 5 (HGV Safety System) presents the lowest cost of £635 million to £676 million, as the only cost

incurred is the cost of extra safety mitigation equipment (installation and proving compliance) for 0-2

star rated vehicles.

The costs of implementation and operation have been assumed equal across all options at this stage,

although the nature of the mandate for each Option may increase/decrease the estimated costs.

5.2 Assessment summary results from the safety report/CIA study

5.2.1 Purpose of the CIA study

The consultancy firm Transport Research Laboratory (TRL) was commissioned by TfL to undertake the

Casualty Impact Assessment (CIA) of the scheme. The CIA would:

Establish methods of converting the Standard ratings from LDS for individual HGV makes and models,

to estimates of the proportion of the London HGV parc that fall into each Standard category and would,

therefore, be affected by the proposal

Seek information to quantify the scope of likely effects that could be achieved with a range of different

policy options relating, for example, to different geographies or times for a ban as well as considering

alternative or complementary measures.

Combine data from Jacobs with the Standard data to forecast how the composition of the HGV parc

would change in response to different policy options.

Identify evidence of the likely effectiveness of direct vision in preventing casualties.

Forecast the combined effects of each policy option over a period of time to quantify the casualty

impacts of the measure.

This section summarises the findings of the CIA. For full details of the CIA, please refer to Appendix E.

5.2.2 Findings of the CIA

The following table presents the summary of the cumulative effect of Option 1 (outright restriction) and Option 5

(HGV Safety System) relative to the “Do-Minimum” scenario, based on most sold low/high mapping of the

Standard rating to population data, showing the number of casualty prevention by fatal, serious and slight.


Table 5-3: Number of Casualties Prevented, based on the most sold vehicles (appraisal period)

Number of Casualty

Prevented

Low

High

Fatal

Serious

Slight

Fatal

Serious

Slight

Option 1 7.2 4.0 10.8 15.9 13.4 57.6

Option 5 2.5 1.7 4.8 14.3 14.6 59.5

Table 5-4: Summary of Casualty Impact Benefit, £000s (undiscounted)

Costs, £000s Casualty Prevention Benefit, £000s

Low High

Option 1 £ 18,000 £ 43,000

Option 5 £ 7,000 £ 40,000

The key findings of the CIA are as follows:

The result was an estimate that a large proportion of the current vehicle fleet would be rated zero star and, therefore, affected by any policy Options that implemented a ban in the short term.

The two policy Options were measured against the ‘do minimum’ option and their benefits are, therefore, in addition to those of the ‘do minimum’ Option.

An outright restriction banning 0 star HGVs from 2020 and 0-2 star HGVs from 2024 would likely prevent a total of 8-16 fatalities and 4-14 serious injuries by 2030, at a value of £18m to £43m

A HGV Safety System scheme was estimated to prevent 3-15 fatalities and 2-15 serious injuries by 2030 at a value of £7m to £40m.

Although the effects of both systems are similar on a cumulative basis to 2030, this masks substantial differences in the timings of effects. The outright restriction option was expected to promote a compliance culture where few operators voluntarily exceeded the minimum standard because of the additional costs it forced them to bear. Thus, the benefits of the ban came early in the analysis period but did not increase with time.

The ‘safe system’ approach was considered more likely to promote a best practice approach and competition between suppliers of safety equipment to produce the best. Thus, the benefits were found to be considerably lower earlier in the assessment period but to increase over time as the quality of the ‘safe system’ increased. By 2030, the annual benefits of the safe system approach were predicted to be higher than for the ban.

Other costs to businesses not quantified include the impact on the residual value of vehicles rated 0*-2* stars. Although the loss of residual value has not been quantified, we anticipate for Option 1 (outright restriction) the scheme would reduce the residual value. However, we do not predict the same impact for Option 5 (HGV Safety System) as the latter is designed to negate the need of replacing non-compliant vehicles early, and businesses would still be able to purchase used HGVs rated below three stars and retrofit to comply with the scheme.


5.3 Tier 1 assessment (Option Sifting) overall results and conclusions

The CBIA has found that Option 1 presents the highest and largest range of costs, ranging from £8 billion to £31

billion, forecasted to impose substantial cost across all sectors as result of the high cost of early replacement of

non-compliant vehicles and the impact of withdrawing non-compliant from entering London. At the same time,

Option 5 presents the lowest cost of £635 million to £676 million, as the only cost incurred is the cost of extra

safety mitigation equipment (installation and proving compliance) for 0-2 star rated vehicles.

Following the findings from the CBIA, Jacobs recommended Option 1 (outright restriction) and Option 5 (HGV

Safety System) to be take forward for further analysis.

The safety/CIA report has found that Option 1 (outright restriction) would likely prevent a total of 8-16 fatalities

and 4-14 serious injuries by 2030, at a value of £18m to £43m, while Option 5 (HGV Safety System) was

estimated to prevent 3-15 fatalities and 2-15 serious injuries by 2030 at a value of £7m to £40m. The above

findings indicate that Option 1 offers greater amount of safety benefits while Option 5 presents the lowest costs

Option.

5.4 DVS scheme Options taken to the full IIA

Following the results and conclusions of the tier 1 assessment, this IIA report has considered the wider impact

of those two options:

1. Option 1 (outright restriction) – an outright ban on zero (2020) / zero, one or two (2024) star vehicles

(with the star rating of all large HGVs proven to TfL via a permit application process.)

2. Option 5 (HGV safe system scheme) – where permits to enter London are only issued to zero star

vehicles from 2020 (or zero, one or two star from 2024) where they can prove they have fitted

appropriate additional safety equipment.

The assessment of the scheme Options against nine IIA Objectives has been undertaken using the IIA

Framework set out in Table 1-3 of this IIA Report. The assessment results can be found in Section 6 of this IIA

report.


6. Tier 2 Assessment of the Shortlisted Options

6.1 Tier 2 Assessment Process at this stage

The assessment of the scheme shortlisted Options is the Tier 2 assessment and has been carried out against

the IIA objectives to evaluate how each Option performed on its own merits in respect of the IIA objectives. The

main objective of the assessment is to analyse how the scheme contributes to the achievement of sustainable

development at a proportionate cost and without undermining London’s competitiveness.

The previous Section of the report has already outlined the findings of the CBIA study concerning the costs

associated with the implementation of each of the initial five options put forward for consideration during the first

tier assessment. It has identified that Option 5 (HGV Safety System) was the most cost effective Option and

should be shortlisted for the full IIA. The CIA report has indicated that Option 1 (Outright Restriction) could

potentially offer the greatest amount of benefits and this would need to be explored further prior to making a

decision of eliminating this Option based only on its costs. Thus, it was decided to bring forward Option 1

(Outright Restriction) and Option 5 (HGV Safety System) to a more detailed analysis to allow for a meaningful

comparison to be made about the sustainability and suitability of these two Options when tested against the IIA

objectives.

The section below summarises the findings of the IIA. In order to understand the differences in impacts and

benefits between Options, initially a full assessment of each scheme Option has been undertaken against nine

IIA objectives (please refer to Table 1-3 of the report) on their own merits. All three scheme Options have been

tested: Option 1 (Outright Restriction), Option 5 (HGV Safety System) and “Do minimum”. This has allowed for a

detailed analysis of how each Option individually performed against IIA objectives and ultimately contributed to

sustainable development. The full IIA results for each of the Options can be found in Appendix F of this report.

The magnitude of the impact against the IIA objectives then was determined by assigning the scoring for each

element of the IIA depending on the results of above mentioned studies.

In summary, the results of the initial detailed IIA (please refer to Appendix F) suggest that Option “Do Minimum”

has been assessed as having five minor positives, two neutrals and one uncertain effect against the IIA

Objectives.

Option 1 (Outright Restriction) has been assessed as having four minor positives, one major positive, one

moderate positive and two major negative effects against the IIA Objectives.

Option 5 (HGV Safety System) has been assessed as having four minor positives, one major positive, one

moderate positive and two minor negative effects against the IIA Objectives.

The comparative analysis of the Options then was carried out to make a meaningful comparison about the

benefits and impacts of each of the shortlisted Options and can be found in the next Section 6.2 of this report.

6.2 Comparative Analysis of the DVS Options

A comparative assessment of Options has been carried out to determine which of the proposed Options

potentially offers the greater amount of sustainability benefits at a proportionate cost and without undermining

London’s competitiveness across the IIA objectives to support the derivation of the preferred Option for the

Standard. Table 6-1 below shows the scoring results between the Options illustrating how each Option

contributes to the achievement of the IIA objectives across all topical assessments of the IIA.

The assessment of the Options has been provided in tabular form within the structure of the assessment

framework. This allows the reader to view what the relative performance of the Options is, against the specific

objectives set out in the IIA framework.

Options 1 (outright restriction) and 5 (HGV Safety Mitigation Scheme) have been assessed against the baseline

of Option “Do Minimum” and comparative to each other. Option “Do Minimum” has not, therefore, been given an

assessment ‘score’ or rating, as it is the baseline against which Options 1 And 5 have been assessed.


Table 6-1: Comparative summary of how the proposed scheme options contribute towards the IIA objectives

Theme

Objectives

Do Minimum Option 1 - Outright

Restriction

Option 5 HGV safe system

scheme

Ranking

Score Score Score

Air Quality 1. To contribute to a

reduction in air pollutant

emissions and compliance


++ + Baseline: Do Minimum



Air Quality Analysis:

Option 1 will provide the highest impact on Air Quality; total reduction in NOx of 0.15kg-1.2kg and PM10

of 14g-112g estimated.

Do Minimum scenario estimates a reduction in NOx of 0g-150g and PM10 of 0-14g.

Option 5 estimates a reduction in NOx of 75g-600g and PM10 of 7g-56g.

Climate change

mitigation

2. To reduce CO2 emissions

and contribute to the

mitigation of climate change

++ +

Option 1 will provide the highest impact on CO2; Option 1 estimates a total reduction by 2020 of CO2

between 121kg-968kg

The Do Minimum estimates a reduction in CO2 of 121kg-968kg by 2020

Option 5 estimates a total reduction in 2020 of 60kg-484kg




Economic

competitiveness and

employment

3. Provide high quality

environment will help to

attract and retain

internationally mobile

businesses

--- -

Option 1 estimates the highest cost to businesses, ranging from £8 billion to £31 billion

Option 5 estimates a lower cost to businesses compared to Option 1, ranging from £635m to £676m

No costs are forecasted in the Do-Minimum scenario




Economic Sectors 4. Encourage the

development of new

businesses in new and

growth sectors

--- -

In the Do Minimum Scenario, little impact on SMEs is expected; the non-mandate of the Standard does

not impose a cost to SMEs and therefore does not detract or encourage any development of new

businesses in all sectors.

SMEs are expected to have less financial flexibility to adjust their fleet to meet compliance, or the

capital to replace their vehicles earlier and on what the sector may consider short notice (the Standard

ratings will be announced in 2018 and the scheme opens in 2020).

The withdrawal of vehicles for SMEs would not only cost businesses their revenue, but may put them

out of business altogether. The economic environment for SME’s and potential new business start-up





would become less attractive.

Option 5 would have the same impact described under objective 3, however, for SME’s the cost of

retrofitting vehicles with safety equipment and the downtime costs of the accompanying annual safety

tests would be relative larger when compared to the size of their operations. The economic

environment for SME’s and potential new business start-up would become less attractive.

Road Safety 5. To contribute to safety

and security and the

perceptions of safety

++ +

Option 1 achieves the greatest possible benefit to road safety by 2030; a total of 8-16 fatalities and 4-

14 serious injuries are estimated by 2030, at a value of £18m-£43m.

The Do Minimum Scenario estimates a total reduction of 2-9 fatalities, 1-9 serious and 3-36 slight by

2030

Option 5 estimates a reduction of 3-15 fatalities and 2-15 serious injuries by 2030 at a value of £7m-

£40m.

In the long term, the benefit of Option 5 may exceed Option 1.




Connectivity 6. To contribute to the

avoidance, elimination or

reduction of road congestion

or other disruption of the

movement of traffic

++ +

In the Do Minimum scenario, the impact on connectivity is estimated to be small but directly

proportional to the road safety effects. A total benefit in 2020 of 0-22 hours is estimated.

Option 1 estimates an improvement in connectivity of 22-176 hours in the year 2020, higher than

Option 5

Option 5 estimates an improvement in connectivity of 11-88 hours.




Population and

Equality

7. To reduce the number of

casualties from protected

groups as a result of HGV

related accidents

8. To advance equality of

opportunity or small and

medium enterprise owned by

protected and disadvantaged

groups.

+++ +++

For Option 1 and Option 5, the ban on HGVs with less than three stars from the roads (by 2020) will

also improve the perception of safety for vulnerable road users such as cyclists. This will have a

disproportionate impact on women who are more likely to view risk of accidents as a barrier to cycling.

Overall, this will have major positive impact on perception of safety in the short to long term, especially

when HGVs with less than three stars will be banned from the roads by 2024.

This will also have a major positive impact on vulnerable road users especially those with protected

characteristics (i.e. the Younger and Older Londoners).





Within each row (i.e. for each element of the IIA framework) the columns to the right hand side seek to both categorise the performance of each Option in terms of ‘significant

effects’ (using red / amber / green) and also rank the alternatives in order of performance. For example, Option 1 has been given a rank 2 against “economic competitiveness

and employment” theme and has been presented in red. Therefore, Option 1 has the worst rank of preference in comparison to other two Options and has been identified as

having significant negative effects against this theme.

For full details of the IIA Objectives Assessment, please refer to Appendix F.

Health and well-being

9. To contribute to enhanced


within London

++ +

Cycling health benefits are expected as a result of the scheme as the ban on the most dangerous

HGVs are likely to improve the safety perception of the roads for cyclists.

Option 1 estimates induced cycle demand of 53,770 cyclists by 2030 and associated health benefits of

£92m

Option 5 estimates induced cycle demand of 42,451 cyclists by 2030 and associated health benefits of

£73m.





7. Summary of the Significant Impact of the Shortlisted Options

7.1 Do Minimum Scenario

The detailed assessment results in Appendix F and the results of the comparative assessment presented in

Table 6-1 have illustrated that Option “Do Minimum” has been assessed as having five minor positives, two

neutrals and one uncertain effect against the IIA Objectives. These scoring results suggest that “Do Minimum”

has performed less favourably than Option 5 (HGV Safety System) and Option 1 (outright restriction).

7.1.1 Environmental IIA Objectives

The IIA included two assessment objectives that relate to environmental aspects of sustainability: IIA Objective

1 (air quality) and IIA Objective 2 (climate change mitigation).

Option “Do Minimum” will have minor positive effects against these two IIA objectives.

This Option will lead to the reduction of the number of casualties from road traffic collisions (cumulatively, 2-9

fatal; 1-9 serious and 3 to 36 slight by 2030). The assessment suggested that each collision avoided in 2020

would reduce emissions of NOx by around 150g and PM10 by around 14g. In total in 2020, this would translate

to a reduction in NOx of between around 0g and 150g and in PM10 of between 0 and 14g. The benefits per

avoided collision attributable to the scheme are expected to be smaller in later years as the vehicle parc gets

cleaner such that the benefit diminishes over time.

Air pollution impacts are tied directly to casualty effects. In the Do Minimum scenario, the casualty effects are

significant but less than are achievable with either Option 1 (outright restriction) or Option 5 (HGV Safety

System). The effects also start slowly as voluntary uptake will be slow initially, accelerating later as momentum

builds. This later effect reduces the air quality benefit further in relation to option 1 because the vehicle parc is

expected to be much cleaner at the time the scheme related benefits are felt.

In 2020, the analysis suggested a reduction per collision avoided of around 121kg CO2 for a total reduction in

2020 of between around 121 and 968kg. The effect on CO2 are similar to air quality although the effect of

vehicle parc changes in the future do less to erode the CO2 benefits of the scheme than they do for air quality.

7.1.2 Equalities IIA Objectives

The IIA included two objectives that relate to inequalities. The IIA Objective 7 (to reduce the number of

casualties from protected groups as a result of HGV related accidents) and IIA Objective 8 (To advance equality

of opportunity or small and medium enterprise owned by protected and disadvantaged groups).

Option “Do Minimum” will have a minor positive effect on the IIA Objective 7.

This is unlikely to have any positive effect in the short term for any of the protected groups as the zero star rated

HGVs will likely remain in service until it is due for renewal which could be a few years later. The Standard may

encourage the purchase of safer vehicles when the fleet is due for renewal but does not completely remove

unsafe zero star HGVs from the roads. Therefore, any benefits are likely to be minor and realised only in the

medium to long term.

In the medium term, this will have a minor positive impact on perception of safety.

7.1.3 Road Safety IIA Objectives

The IIA framework also included Objective 5 (To contribute to safety and security and the perceptions of safety)

to test how the scheme Options facilitate road safety.

Option “Do Minimum” has a minor positive effect on this IIA Objective.


This Option will lead to a reduction of the number of casualties from road traffic collisions (cumulatively, 2-9

fatal; 1-9 serious and 3 to 36 slight by 2030).

The benefits would be likely to accrue disproportionately to elderly pedestrians and younger cyclists. These may

represent protected groups and disadvantaged communities. The same low base numbers and minimum

voluntary actions constrain the total benefit of this option.

The Do Minimum scenario will have minor positive effects against IIA Objective 6 (connectivity).

The analysis suggested an average total delay associated with collisions of 22 hours. This can be considered,

for example, in terms of a few minutes delay for many drivers or a more significant delay for a few drivers. This

has been assumed to remain constant over time such that the total benefit in 2020 for example would be

between around 0 and 22 hours.

7.1.4 Health IIA Objectives

The IIA framework included the IIA Objective 9 (to contribute to enhanced health and wellbeing for all within

London) that relates to the health aspect of sustainability.

The IIA identified an uncertain effect of this Option against this IIA Objective. The non-mandated Standard is

not expected to have a significant impact on cyclists unless businesses opt to switch to higher-rated vehicles

when replacing older vehicles. The businesses are most likely to consider the Standard for purchasing

decisions, and depending on whether there is a cost premium of higher-rated vehicles, the number of the

Standard-compliant vehicles is expected to grow. However, whether the Standard would encourage more cycle

trips is uncertain due to the non-mandate, and cyclists may not be convinced the road is safer unless the

Government intervenes.

7.1.5 Economic IIA Objectives

The IIA included two objectives that relate to economic aspects of sustainability. IIA Objective 3 (economic

competitiveness and employment) and IIA Objective 4 (Economic Sectors)).

This Option will have neutral effect on the IIA Objectives 3 and 5. The “Do Minimum” does not require

intervention from TfL or the Local Authorities, therefore no cost is incurred by the public sector. Additionally,

businesses are not required to adjust their fleet to meet the Standard, therefore no induced cost as a result of

the scheme is incurred. No detrimental cost to the wider economy is expected, as well as employment and

economic competitiveness as there is little evidence the presence of the Standard would attract more

businesses to operate in London.

If there is a limited supply of three star or above rated vehicles on the market, the price of the latter may

increase as a result of demand surplus. Additionally, if there is a lower demand for lower-rated vehicles (0*-2*),

the price of these vehicles may reduce on the market. In both cases, price conscious businesses do not have

the incentive to purchase the higher-rated vehicles and may not switch to 3* or above rated vehicles as a result

of the cost premium.

The “Do Minimum” scenario would have little impact on Small to Medium Enterprises (SMEs); the non-mandate

of the Standard does not impose a cost to SMEs and therefore does not detract or encourage any development

of new businesses in all sectors.

Table 7-1 below presents the summary of the quantified benefits of Option “Do Minimum”.

Table 7-1: Summary of the quantified benefits of Option “Do Minimum”

IIA impacts Results

Reduction in NOx

(g) in 2020 0 - 150


IIA impacts Results

Reduction in PM10

(g) 0 - 14

Reduction in CO2

(kg) 0 – 121

Reduction in total delay

(hours) 0 - 22

Reduction in casualties by 2030

(number of casualties)

2 - 9 fatal

1 – 9 serious

3 – 36 slight

7.2 Option 1 – Outright Restriction


Table 6-1 have illustrated that Option 1 (outright restriction) has been assessed as having four minor positives,

one major positive, one moderate positive and two major negative effects against the IIA Objectives. This

scoring result suggests that Option 1 (outright restriction) has performed the worst in comparison to Option 5

(HGV Safety System) based on the economic objectives assessment and “Do Minimum” Option. Section below

outlines a detailed overview of how this Option performed against the IIA Objectives.




Option 1 will have a minor positive effects against these two IIA objectives. Option 1 will lead to the reduction of

the number of casualties from road traffic collisions (8-16 fatal; 4-14 serious and 11 to 58 slight by 2030); the

assessment suggested that each collision avoided in 2020 would reduce emissions of NOx by around 150g and

PM10 by around 14g. In total in 2020, this would translate to a total reduction in NOx of between around 0.15kg

and 1.2kg and in PM10 of between 14g and 112g. The benefits per avoided collision attributable to this scheme

option are expected to be smaller in later years as the vehicle parc gets cleaner such that the benefit diminishes

over time.


2020 of between around 121 and 968kg.


The IIA included two objectives that relate to inequalities: the IIA Objective 7 (to reduce the number of



Option 1 (outright restriction) will have a major positive effect on the IIA Objective 7.

The restriction of zero star HGVs along with the requirement for all N3 HGVs to have a permit to enter London is

expected to reduce the number of HGVs on the streets of London as soon as it is in effect. It is expected that

this will reduce the number of casualties in the short to long term and have a major positive impact on

vulnerable road users especially those with protected characteristics. The benefits would be likely to accrue

disproportionately to elderly pedestrians and younger cyclists.


The ban on HGVs with less than three stars from the roads (by 2020) will also improve the perception of safety

for vulnerable road users such as cyclists. This will have a disproportionate impact on women who are more

likely to view risk of accidents as a barrier to using public transport.

Overall, this will have major positive impact on perception of safety in the short to long term, especially when

HGVs with less than three stars will be banned from the roads by 2024. The effects of Option 1 (outright

restriction) were not identified due to the lack of available data.



to test how the DVS Options facilitate road safety.

Option 1 has a minor positive effect on this IIA Objective. This Option will lead to a reduction of the number of

casualties from road traffic collisions (8-16 fatal; 4-14 serious and 11 to 58 slight by 2030). Although high profile

and highly variable in number such that some years the numbers may be much higher than others, on average,

the total number of collisions of this type that occur in London is relatively low and although Direct Vision is

expected to be an effective countermeasure it will not eliminate collisions, merely reduce their frequency. Also,

as a minimum, the Standard will be used in existing best practice schemes such that some of the maximum

benefit cannot be directly attributable to this Option.

Option 1 (outright restriction) achieves the greatest possible benefit to road safety by 2030 and will have the

greatest effect in the immediate short term. However, in the long term, the benefit of Option 5 (HGV Safety

System) may exceed Option 1 (outright restriction).

Option 1 will have a minor positive effects against IIA Objective 6 (connectivity). The analysis suggested an

average total delay associated with collisions of 22 hours. This can be considered, for example, in terms of a

few minutes delay for many drivers or a more significant delay for a few drivers. This has been assumed to

remain constant over time such that the total benefit in 2020 for example would be between around 22 and 176

hours, which are higher than for Option 5.




The IIA identified a moderate positive effect of Option 1 (outright restriction) against this IIA Objective. Cycling

health benefits are expected as a result of the scheme as the ban on the most dangerous HGVs are likely to

improve the safety perception of the roads for cyclists. The induced number of cyclists estimated by 2031 as a

result of the enforcement of each option. The induced cycle demand as a result of the scheme is estimated to

be 53,770 cyclists and associated health benefits were appraised to be £92m.

Creating a sense of a safer environment of banning the most dangerous HGVs would encourage more

cyclists and/or existing cyclists to cycle more, improving the health of those impacted and well-being.

Studies have shown that although safety perception (fear of collision) of travelling is one of the main factors

taken into consideration by cyclists, the same magnitude of consideration is less for pedestrians. There is little

evidence to show that a road safety scheme such as DVS would have altered the perception of safety for

pedestrians and therefore, would induce a significant number of pedestrians to quantify. However, the scheme

may encourage existing pedestrians to walk more or take longer trips, increasing active travel and subsequently

inducing health benefits.


The IIA included two objectives that relate to economic aspects of sustainability: IIA Objective 3 (economic



Option 1 will have major negative effects against IIA Objective 3 and IIA Objective 5. The total cost to

businesses for Option 1, whereby the biggest cost businesses are expected to incur are the impact of

withdrawing their non-compliant vehicles from operation, ranging from £8 billion to £31 billion.7

The high estimate of vehicles expected to be non-compliant with the Standard forecasts a “knock on” effect on

the economy as a whole, especially for the construction sector. As a result of this negative impact, a cost to the

economy of the equivalent of the Construction Gross Value Added (GVA) for 2020 is accounted for in the “high”

estimate cost of withdrawal as an indicative estimation of the impact on the wider economy. Additionally, non-

quantified costs to businesses include the loss of business time as a result of certification and proving

compliance of vehicles, the potential loss of residual value and the cost of switching manufacturers. Therefore,

Option 1 has performed the worst in comparison to Option 5 and Option “Do Minimum” against these IIA

Objectives.

Due to the limited time frame allowed for businesses to adjust their fleet to meet compliance by 2020 and 2024,

the EBIA considered the impact of businesses withdrawing their fleet from serving Greater London, and the

withdrawal would be expected to have a negative impact on the industries considered so far.

This is likely to trigger wider impacts on London’s economy such as:

• Reduction in revenue and consequently profit;

• Redundancies;

• Closure of business (especially among small to medium businesses); and

• Insufficient supply in London of services affected.

Not only does the direct loss of income generated from the sector economies needs to be considered, but the

indirect impact of the multiplier effect. This can lead to a bigger eventual final effect on output and employment.

Impact on Economic Sectors

The scheme is expected to have a severe impact on small businesses that operate a smaller fleet, relative to

larger, established businesses; compliance with the scheme would potentially require substantial capital and

time dedicated to adjusting the fleet. Small businesses simply do not have the capital and flexibility to adjust

their fleet within two years (assuming information on the scheme would become public by 2018 and opening

year of Option 1 is 2020).

The Construction Sector is identified to be the most vulnerable due to the reliance on N3G classed vehicles,

which are estimated to be mostly zero star rated. Banning the majority of N3G classed vehicles from London is

expected to initially delay/stop on-site construction to take place until an alternative solution is identified.

Table 7-2: Summary of Quantified Benefits – Option 1 (Outright restriction)

IIA impacts Results

Reduction in NOx

(g) in 2020 150 - 1200

Reduction in PM10

(g) 14 - 112

Reduction in CO2

(kg) 121 - 968

Reduction in total delay 22 - 176

7 Undiscounted, 2017 prices


IIA impacts Results

(hours)



8 - 16 fatal

4 – 14 serious

11 – 58 slight

7.3 Option 5 – HGV Safety System Scheme


Table 6-1 have illustrated that Option 5 (HGV Safety System) has been assessed as having four minor

positives, one major positive, one moderate positive and two minor negative effects against the IIA Objectives.

This scoring result suggests that overall Option 5 (HGV Safety System) provides greater amount of

sustainability benefits in comparison to Option 1 (outright restriction) and “Do Minimum” Option. The section

below outlines a detailed overview of how this Option performed against the IIA Objectives.




Option 5 (HGV Safety System) will have a minor positive effects against these two IIA objectives. Option 5

(HGV Safety System) will lead to the reduction of the number of casualties from road traffic collisions

(cumulatively, 3-15 fatal; 2-15 serious and 5 to 60 slight by 2030). The assessment suggested that on average

each collision avoided in 2020 would reduce emissions of NOx by around 150g and PM10 by around 14g. In

total in 2020, this would translate to a reduction in NOx of between around 75g and 600g and in PM10 of

between 7 and 56g.

The benefits per avoided collision attributable to the scheme are expected to be smaller in later years as the

vehicle parc gets cleaner such that the benefit diminishes over time.

Option 5 (HGV Safety System) retains strong elements of voluntary improvement but where the Standard is not

best practice requires a wider ranging approach to solving the problem that ultimately could be more effective

than direct vision alone. The effectiveness is much lower than Option 1 (outright restriction) in 2020, but by 2028

could be exceeding that of Option 1 (outright restriction) as alternative technologies improve. Thus, in terms of

air quality collision reduction at a later stage is less valuable than at an early stage so this option will be less

effective than Option 1 (outright restriction).


2020 of between around 60 and 484kg. Option 5 will prevent fewer collisions (by 2030) than Option 1 (outright

restriction) in total and those prevented will be more likely to relate to later years. Thus, the CO2 effect of Option

5 (HGV Safety System) will be smaller.


The IIA included two objectives that relate to inequalities. The IIA Objective 7 (to reduce the number of



Option 5 (HGV Safety System) will have a major positive effect on the IIA Objective 7.

The requirement for zero to two star HGVs to have a “safe system” is expected to improve the safety of the

HGVs, as well as the perception of safety. This will have a major positive impact on vulnerable road users

especially those with protected characteristics. The benefits would be likely to accrue disproportionately to


elderly pedestrians and younger cyclists. Additionally, this will have a disproportionate impact on women, as

they are more likely to view risk of accidents as a barrier to using public transport.

Option 5 (HGV Safety System) is likely to have a major positive effect in the short term when it is implemented.

This is unlike the “Do Minimum” Option, which is unlikely to have any positive impacts in the short-term.

In Option 5 (HGV Safety System), the presence of zero to two star HGVs (albeit with a “safe system” installed)

may have less of a positive impact on the perception of safety compared with Option 1 (outright restriction).

However, Option 5 (HGV Safety System) will have a greater positive impact than “Do Minimum”.



to test how the scheme Options facilitate road safety.

Option 5 (HGV Safety Mitigation) has a minor positive effect on this IIA Objective. This Option will lead to a

reduction of the number of casualties from road traffic collisions (3-15 fatal; 2-15 serious and 5 to 60 slight by

2030). The same low base numbers and minimum voluntary actions constrain the total benefit of this option.

The cumulative benefits of Option 5 will be slightly less than for Option 1 in the period to 2030. However, in the

longer term Option 5 may become more beneficial than Option 1.

Option 5 will have a minor positive effect against IIA Objective 6 (connectivity). The analysis suggested an

average total delay associated with collisions of 22 hours. This can be considered, for example, in terms of a

few minutes delay for many drivers or a more significant delay for a few drivers. This has been assumed to

remain constant over time such that the total benefit in 2020 for example would be between around 11 and 88

hours, which is lower than for Option 1. The cumulative benefits of option 5 will be slightly less than for Option 1

in the period to 2030. However, in the longer term Option 5 may become more beneficial than Option 1.




The IIA identified a moderate positive effect of Option 5 against this IIA Objective. The induced cycle demand

as a result of the scheme is estimated to be 42,451 cyclists and associated health benefits were appraised to be

£73m.

Studies have shown that although safety perception (fear of collision) of travelling is one of the main factors

taken into consideration by cyclists, the same magnitude of consideration is less for pedestrians. There is little

evidence to show that a road safety scheme such as DVS would have altered the perception of safety for

pedestrians and therefore, would induce a significant number of pedestrians to quantify. However, the scheme

may encourage existing pedestrians to walk more or take longer trips, increasing active travel and subsequently

inducing health benefits.


The IIA included two objectives that relate to economic aspects of sustainability. IIA Objective 3 (economic


Option 5 (HGV Safety Mitigation) will have minor negative effects against IIA Objective 3 and IIA Objective 5.

The total cost to businesses for Option 5 (HGV Safety System), whereby the biggest cost businesses are

expected to incur is the cost of retrofitting the non-compliant vehicles with additional safety mitigation measures,

ranging from £381m to £403m. No vehicles are forecasted to be replaced earlier than planned or withdrawn

from operating in London.


Downtime costs are likely to be higher than Option 1 (outright restriction) because not only all vehicles will need

to prove compliance, but also non-compliant vehicles opting to retrofit their vehicles with extra safety mitigating

equipment would require annual assessment.

The scheme is expected to have a severe impact on small businesses that operate a smaller fleet, relative to

larger, established businesses; compliance with the scheme would potentially require substantial capital and

time dedicated to adjusting the fleet.

Table 7-3: Summary of Quantified Benefits – Option 5 (HGV Safety System)

IIA impacts Results

Reduction in NOx

(g) in 2020 75 – 600

Reduction in PM10

(g) 7 – 56

Reduction in CO2

(kg) 60 - 484

Reduction in total delay

(hours) 11 - 88



3 - 15 fatal

2 – 15 serious

5 – 60 slight


8. Cumulative effects of the proposed scheme and the Ultra-Low Emission Zone (ULEZ) scheme

This section assesses the potentially significant cumulative effects of the scheme in combination with the ULEZ

proposals. The assessment of cumulative effects assists in the identification of the total direct and indirect effect

on receptors. Often, effects may result from the accumulation of multiple small and often indirect effects rather

than few large obvious ones.

The ULEZ scheme is another TfL scheme, which is likely to affect HGVs operators in Greater London therefore

it is important for the IIA to look at the possible cumulative effects of this scheme alongside the DVS proposals.

The approved ULEZ scheme comes into force in Central London (CCZ area) in September 2020; and TfL has

consulted upon proposals to bring forward the introduction of the ULEZ to April 2019. The ULEZ will require

cars, motorcycles, vans, minibuses, buses, coaches and heavy goods vehicles to meet minimum exhaust

emissions standards. A vehicle that does not meet the ULEZ standard would still be able to drive in central

London but would be required to pay a daily charge to do so. The charges for non-compliant heavy vehicles

including HGVs, buses and coaches would be £100 per day. Light vehicles for non-compliant including cars,

motorcycles, vans and minibuses would pay a daily charge of £12.50. ULEZ would apply 24 hours a day, 7 days

a week.

TfL is also developing proposals to extend the ULEZ scheme for heavy vehicles to cover the entire Greater

London area. For the purposes of this cumulative assessment, the ULEZ scheme comprises the approved

scheme (CCZ) and the proposed extension of that scheme to apply to heavy goods vehicles across the entire

Greater London Authority area.


Table 8-1 below sets out the predicted significant cumulative impacts across the DVS and the ULEZ proposals. It outlines those receptors that could potentially experience significant cumulative effects based on current knowledge and methods of assessment.


Table 8-1: ULEZ and DVS cumulative effects

IIA Objectives

Proposed scheme ULEZ (CCZ + Proposal to extend to GLA area for HGVs) Significance of cumulative effects

Environmental IIA

Objectives

There anticipated to be a number of

minor positive effects against the

environmental IIA objectives arising

from the scheme.

The collisions avoided would reduce

emissions of NOx and PM10 as well

cause a reduction in CO2 emissions

which negatively affects human

health and environment.

There anticipated to be significant positive effects on air quality

through PM and NO2 reductions as a result of the proposed

extensions to ULEZ. The Greater London ULEZ is likely to result in

substantial reductions in CO2 emissions in Greater London.

Reductions in CO2 emissions resulting from the ULEZ would

predominantly be achieved through increased uptake of low and

zero emission vehicles and greater compliance with more stringent

euro fuel standards.

There may also be indirect reductions through the increased use of

other transport modes such as public transport and active travel.

There is anticipated to be a minor

positive cumulative effect as both

proposals are likely to support and

complement each other, contributing

towards the environmental IIA

objectives.

Economic IIA

Objectives

While it is not expected that

businesses will withdraw from the

market, they would still incur

compliance expenses and downtime

costs.

The scheme is expected to have a

severe impact on small businesses

that operate a smaller fleet, relative

to larger, established businesses;

compliance with the scheme would

potentially require substantial capital

and time dedicated to adjusting the

fleet.

The introduction of the scheme creates uncertainty around the

required Standard that freight operators need to meet in addition to

the new ULEZ requirements coming into force in 2020 and could

potentially be brought forward to 2019.

HGV operators are therefore likely to defer the purchase of ULEZ

compliant vehicles until the new Standard is clearly defined; to

ensure that any new vehicle will comply with both standards. The

alternative would be to purchase a vehicle, which is likely to require

retrofitting to comply with as yet unspecified new Standard.

In addition, the lead times for new HGVs can be up to 18 months,

so any delay in the purchase of a ULEZ compliant vehicle could

The two schemes together could

potentially give rise to adverse

cumulative impacts on businesses.

SMEs, particularly London based SMEs

are likely to be most significantly

affected by the introduction of the two

proposals in similar and short

timeframes, providing minimal time for

operators and manufacturers to adapt

to both sets of compliance

requirements.


IIA Objectives

Proposed scheme ULEZ (CCZ + Proposal to extend to GLA area for HGVs) Significance of cumulative effects

make it harder for secure a vehicle prior to the introduction of the

scheme if it is brought forward to April 2019.

This will have a disproportional adverse impact on SMEs, which

will be in a disadvantaged position in comparison to larger

companies to ensure compliance with both DVS and ULEZ by

2019, which will require substantial capital and time dedicated to

adjusting the fleet.

Social IIA Objectives The proposed scheme is expected to

improve the safety of the HGVs.

This will have a major positive impact

on vulnerable road users especially

those with protected characteristics.

The benefits will disproportionately

affect elderly pedestrians and

younger cyclists.

The scheme is likely to improve the

safety perception of the roads for

cyclists leading to health benefits due

to the increased cycling demand.

There anticipated to be significant positive effects on human health

and associated economic benefits for the improved health due to

the potential reduction in NO2 concentrations as a result of the

ULEZ CCZ scheme and proposals for extension.

If ULEZ led to a minor improvement in traffic congestion due to a

reduction in traffic volume, it could have positive effects on safety

and reduction in collisions, injuries and deaths. However, this is

considered unlikely.

Furthermore, any potential improvement in safety would need to be

balanced against the likelihood that the remaining traffic travels

faster and thus increases collision risk for cyclists and pedestrians.

However, it is not anticipated that the introduction of ULEZ in CCZ

or its extension to Greater London for HGVs will have any

significant effects on traffic volumes or speeds, and

consequentially, road safety.

There is likely to be a minor positive

cumulative effect on social objectives as

both proposals are likely to support the

improvement in human health due to

likely increase in active travel and the

improvement in air quality.

The benefits of road safety could be

offset by faster moving traffic as a result

of any improvements to in traffic

congestion as a result of a reduction in

traffic volumes as a result of the ULEZ

proposals. But this is not an anticipated

outcome of ULEZ. .


There are expected to be positive cumulative effects across the DVS and ULEZ proposals in relation to harmful

air pollution and CO2 emissions reduction, health impacts associated with an increase in road safety and the

perception of safety as well as induced cycling demand. As compliance with the Standard and ULEZ would

potentially incur substantial capital costs there are expected to be a significant adverse cumulative effect on

small businesses (SMEs) who operate smaller HGV fleets, with low vehicle replacement rates compared to

larger, established businesses, which have larger fleets with regular fleet turnover.


9. Transboundary Effects

The spatial scope of the IIA is restricted to the Greater London area. However, this section provides a

qualitative analysis of the transboundary effect of the scheme outside of Greater London.

9.1 Economic

The scheme is not mandated in other areas, and therefore will not present costs to businesses operating

outside the Greater London area.

Option 1 (outright restriction) suggests that a significant number of operators are likely to withdraw from the

market depending on the level on non-compliant vehicles and will likely to terminate their activity. However,

there is no indication that they could move their business to other geographical areas. Therefore, no

transboundary economic effects are anticipated.

9.2 Environmental

There anticipated to be a number of minor transboundary positive effects on the environment arising from the

DVS scheme, especially when taking into consideration the cumulative positive effects with ULEZ. The

collisions avoided as a result of safer vehicles that operate in Greater London as well as outside the standard

area alongside compliance with ULEZ could reduce emissions of NOx and PM10 as well cause a reduction in

CO2 emissions, which negatively affects human health and environment.

9.3 Social

Equality and Health

The scheme covers Greater London area. The improved safety of the HGVs that operate in Greater London

area as well as areas outside London are likely to have positive effects on health and inequalities as improved

safety of vehicles outside the standard boundary is likely to have a positive impact on vulnerable road users

especially those with protected characteristics. The benefits will also disproportionately affect elderly

pedestrians and younger cyclists. The scheme is also likely to improve the safety perception of the roads for

cyclists leading to health benefits due to the increased cycling demand in areas outside Greater London.

Safety effects

Although many features will influence direct vision performance, achieving a higher Standard rating will tend to

mean a lower mounting height for the vehicle cab, particularly in the short term between scheduled major re-

designs of cab ranges. Jacobs reported that stakeholders cited concerns that a tall cab and a high vantage

point increased safety outside of city driving because of the more commanding view that it enabled. This is

consistent with survey responses reported by (Arup, 2017) where it was apparent that drivers felt safe in a high

cab. Similar views have been expressed in the field of passenger cars when considering the views from SUVs

compared to smaller cars.

While there is evidence that drivers have a perception of increased safety in a tall vehicle, there is little, if any,

objective evidence of a relationship with casualty rates. In the absence of this evidence, there are several

factors that may need consideration:

Relative height: it is possible that the perceived advantage comes not from the absolute height of the

vehicle but the height of the eye point relative to that of other road users. That is, it is being able to see

over the top of other vehicles that drivers perceive to be of benefit. Thus, if a policy promotes lower

vehicles more generally, it is possible that the effect on the ability to see over other vehicles will not be

greatly affected. Even in a 5 star Standard HGV, the driver will be able to see over the top of passenger

cars. There will be more models of HGV and bus that it cannot see over any more but those models will

be discouraged by the standard and will therefore be fewer in number. If all HGVs were 5 star, there

might be no disadvantage.


The effect on smaller vehicles - while a very tall vehicle may be perceived to be safer by its driver in

highway driving because it enables a better view, that increase in height has the potential to further,

degrade the view of the smaller passenger cars around it. For example, HGVs can obscure roadside

signs from the view of a passenger car overtaking in a second or third lane. A taller HGV would

increase the distance at which the obstruction can occur. This could make sudden late reaction, for

example, to motorway exits, more frequent with a consequent increase in collision risk.

In summary, there is a risk that high Standard compliant vehicles that perform well in cities may perform less

well in inter-urban driving but there is little objective evidence and the issue is far from clear cut. It is also at

least theoretically possible that the benefits to car drivers on highways of decreasing the height of HGVs could

outweigh any disbenefit to HGV drivers, such that the same issue represented a further net safety benefit.


10. Mitigation Measures

The impact to businesses of Option 1 “outright restriction” has been assessed as largely detrimental for all the

sectors under analysis, due to the need to replace a large amount of vehicles to in order to comply with the

Direct Vision Standard. An effective mitigation measure would be enabling non-compliant vehicles to retrofit to

make them safer for vulnerable road users. This measure would be equivalent to Option 5 safe system scheme.

Where all vehicles rated 1 star or better on DVS would automatically receive a permit (1 star from 2020, 3 stars

from 2024) and non-compliant vehicle could retrofit. All vehicles with a non-optimal rating would be issued a

permit if they can demonstrate that they are “above par” on a number of key safety aspects, yet to be defined.

Option 5 (HGV Safety System) would still represent some cost to businesses. While it is not expected that

businesses will withdraw from the market, they would still incur compliance expenses and downtime costs. This

option has been assessed as minor detrimental to businesses; however it is expected to have a relatively larger

impact on SMEs due to the ratio of these additional costs to the size of their operations. Possible mitigation

measures may involve some type of subsidies or loan schemes for very small businesses without access to

financial resources for retrofitting or a waiver for some vehicles if a large percentage of the fleet proves to be

non-compliant.

It is anticipated to be adverse negative cumulative effects as a result of DVS and ULEZ proposals on

businesses, with SMEs, particularly London based SMEs with less flexibility, being disproportionally affected by

the introduction of these two proposals at the similar and tight timeframes.

The mitigation measures may include:

TfL to publish as soon as possible the list of ULEZ compliant HGVs that meet 1star standard to provide

certainty to freight operators when they plan their capital expenditure; and

To provide subsidies to London based SMEs for safety system retrofitting who plan to buy the ULEZ

compliant vehicles prior to the publication of the Standard to ensure compliance to both standards by

2019.


11. Conclusion of the IIA

This section concludes the overall findings of the IIA assessment of the shortlisted options, Option 1 (outright

restriction) and Option 5 (the HGV safety mitigation system). The two options were assessed against the

baseline scenario, the Do Minimum option, and the impact were analysed against the IIA objectives that

covered a range of topics.

Environmental IIA Objectives

Option 1 (outright restriction) presents the highest environmental benefit, leading to the reduction of

NOx emissions of 0.15kg – 1.2kg and PM10 14g-112g in year 2020. A total reduction of 121kg-968kg

CO2 is estimated.

Equalities IIA Objectives

Option 1 (outright restriction) and Option 5 (HGV Safety Mitigation System) will have a positive impact

on reducing the number of casualties from protected groups and the benefits would be likely to accrue

disproportionately to elderly pedestrians and younger cyclists.

The scheme will improve the perception of safety for vulnerable road users such as cyclists. This will

have a disproportionate impact on women who are more likely to view risk of accidents as a barrier to

using public transport.

Road Safety IIA Objectives

Option 1 (outright restriction) estimates the highest safety benefits compared to Option 5 (HGV Safety

Mitigation System) and the Do Minimum.

Option 1 (outright restriction) has a minor positive effect on the contribution to safety, security and the

perception of safety; Option 1 (outright restriction) estimates a reduction of the number of casualties

from road traffic collisions (8-16 fatalities, 4-14 serious and 11 to 58 slight by year 2030).

Option 5 (HGV Safety Mitigation System) estimates a total reduction in the number of casualties from

road traffic collisions (3-15 fatalities, 2-15 serious and 5-60 slight by year 2030).

Option 1 and Option 5 will have minor positive effects on connectivity; Option 1 estimates an average

total delay reduction of 22-176 hours in 2020, higher than Option 5, which estimates an average total

delay of 11-88 hours in 2020.

Health IIA Objectives

Option 1 (outright restriction) estimates total cycling health benefits of £92m (appraisal period), higher

than Option 5 of £73m (appraisal period)

Studies have shown that although safety perception (fear of collision) of travelling is one of the main

factors taken into consideration by cyclists, the same magnitude of consideration is less for pedestrians.

Economic IIA Objectives

Option 5 (HGV Safety Mitigation System) will have minor negative effects on economic competitiveness

and employment; cost to businesses is estimates between £635m to £676m (undiscounted) over the

appraisal period.

Option 1 (outright restriction) will have major negative effects, whereby the highest cost to businesses

are estimated between £8 billion to £31 billion (undiscounted).


Option 5 (HGV Safety Mitigation System) presents a BCR ranging from 0.140 to 0.168, higher than

Option 1 BCR ranging from 0.004 to 0.012.

None of the options meets/surpasses the standard benchmark of 1.5:1 (benefits are 1.5 times larger

than the costs) and even at a level of 1:1 (whereby the benefits and costs break-even), none of the

options assessed are considered economically viable. The standard benchmark of 1.5:1 is defined

by TfL as the minimum BCR in which classifies a project as economically viable (TfL’s Business Case

Development Manual, 2014).

SMEs and the Construction Sector are predicted incur the most adverse impact of the scheme due to

the high number of N3G vehicles estimated to be rated below 3 stars and the high cost of meeting

compliance.

Other issues identified by the IIA includes the new proposals for ULEZ and DVS schemes together could

potentially give rise to adverse cumulative impacts on businesses. Potential mitigation measures for the latter

issue include:

TfL to publish as soon as possible the list of ULEZ compliant HGVs that meet 1 star standard to provide

certainty to freight operators when they plan their capital expenditure; and

To provide subsidies to London based SMEs for safety system retrofitting whom plan to buy the ULEZ

compliant vehicles prior to the publication of the standard to ensure compliance to both standards by

2019.

Overall, although the benefits of DVS would positively improve the road safety of London, improve the

perception of road safety among the public and have a minor improvement on the environment, the magnitude

of the beneficial impact is insignificantly minor in comparison to the significantly high costs imposed on

businesses. The very short time-scale of introducing DVS to the public (the Mayor intends to introduce DVS

beginning of 2018) and the opening year of enforcement (2020) does not allow businesses sufficient time to be

able to comply with the original proposal (i.e. Option 1 – Outright Restriction), forcing thousands of HGVs to

either be replaced early or withdraw from entering London altogether.

Jacobs recommends taking Option 5 (HGV Safety System) forward for further consultation as the costs imposed

on businesses are significantly lower than Option 1 (outright restriction). Option 1 (outright restriction) should be

disregarded completely as it would prove to be too detrimental to businesses operating in London, and not

economically viable to implement.


Appendix A. Relevant Plans and Policies

Plan or policy Assessment Description of relevance to this IIA

update

Proposed IIA Objective

Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

EU Directives

European Road Safety

Charter in 2009

The Charter includes an aspiration to

reduce fatal collisions by 50 per cent

across the whole of the European Union

by 2020. Internationally, road safety has

a prominent position (for example the UN

Decade of Action for Road Safety 2011-

2020) as rising levels of motorised traffic

increase the exposure to risk on the

roads of developing nations.

IIA Objective 6

To contribute to safety and

security and the


EU Ambient Air Quality

Directive (2008/50/EC)

A revision of previously existing

European air quality legislation, which

sets out long‐term air quality objectives

and legally binding limits for ambient

concentrations of certain pollutants in the

air. The directive replaced nearly all the

previous EU air quality legislation and

was made law in England through the Air

Quality Standards Regulations 2010.

IIA Objective 1

To contribute to a




UK Legislation



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

National Strategic

Framework for Road

Safety (SFRS) 2011

The SFRS sets out the national policies

that are intended to continue to reduce

deaths and injuries on the roads. The

long-term vision of the SFRS is to ensure

that Britain remains a world leader on

road safety. In support of this ambition, it

places an expectation on local

government to continue to prioritise road

safety and to seek improvements by

adopting policies that reflect local

priorities and circumstances.

IIA Objective 6


security and the


The Crime and Disorder

Act 1998

Crime and Disorder Act 1998 (as

amended) makes provision for preventing

and combatting crime and disorder. The

GLA and TfL have a statutory duty under

section 17 of the Crime and Disorder Act

and DVS proposal should therefore

consider potential impacts on crime and

disorder.

IIA Objective 6


security and the


Traffic movement duty

under Road Traffic Act

1984

Duty deals with managing the road

network with the aim of securing the

expeditious movement of traffic on an

authority’s road network and facilitating

IIA Objective 6


security and the




update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

this on other authorities’ road networks

(TMA, Section 16, Part 1). The objective

of the Duty is the efficient operation of

the road network as a whole. Our nation

has one road network and the goal of the

Duty is for seamless operation of that

network across the 149 LTAs.

Network management

duty under Traffic

Management Act 2004

Duty deals with managing the road

network with the aim of securing the

expeditious movement of traffic on an

authority’s road network and facilitating

this on other authorities’ road networks

(TMA, Section 16, Part 1). The objective

of the Duty is the efficient operation of

the road network as a whole. Our nation

has one road network and the goal of the

Duty is for seamless operation of that

network across the 149 LTAs.

IIA Objective 6


security and the


Safe London streets:

Our six road safety

commitments (Transport

for London, 2014)

An ambitious and comprehensive plan to

make the Capital’s roads safe. The six

commitments set out are:

To lead the way in achieving a

40 per cent reduction in the

IIA Objective 6


security and the




update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

number of people killed or

seriously injured on the Capital’s

roads by 2020 – with a longer

term ambition of freeing

London’s roads from death and

serious injury;

To prioritise safety of the most

vulnerable groups – pedestrians,

cyclists and motorcyclists –

which make up 80 per cent of

serious and fatal collisions;

To provide substantial funding for

road safety, invested in the most

effective and innovative

schemes;

To increase efforts with the

police, boroughs and

enforcement agencies in tackling

illegal, dangerous and careless

road user behaviour that puts

people at risk;

To campaign for changes in

national and EU law to make

roads, vehicles and drivers safer;

and



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

To work in partnership with

boroughs and London’s road

safety stakeholders to spread

best practice and share data and

information.

Pedestrian Safety

Action Plan (Transport

for London)

The Road Safety Action Plan for London

2020 set a target to reduce killed or

seriously injured (KSI) casualties by 40

per cent, from the 2005-2009 baseline

periods, by 2020. In 2013, a total of 838

pedestrians were killed or seriously

injured on London’s streets – the largest

number for a single transport mode. More

than a third of all KSI casualties in

London are pedestrians, so reducing the

number of these casualties will be key to

achieving the 2020 target.

IIA Objective 6


security and the


Safe London streets:

Our approach

(Transport for London,

2015)

See above for Safe London streets: Our

six road safety commitments (Transport

for London, 2014).

IIA Objective 6


security and the


Health and Social Care

Act 2012

Creates a duty on the Secretary of State,

NHS and Directors of Public Health to

IIA Objective 9

To contribute to enhanced



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

secure continuous improvement in the

quality of services provided to individuals

for or in connection with public health.


within London

Equality Act 2010

Requires public authorities to work to

eliminate discrimination and promote

equality in all their activities. Under the

Act, a public authority has a duty to

ensure that all decisions are made in

such a way as to minimise unfairness,

and do not have disproportionately

negative impacts on people because of

their protected characteristics or

background.

IIA Objective 7, 8

To enhance equality and

social inclusion

Healthy Lives, Healthy

People: Our Strategy for

Public Health in England

(Department of Health,

2010)

Sets out Government’s approach to

tackling obesity in England. Increasing

physical activity and active travel is

identified as a measure to achieving the

specified targets.

IIA Objective 9



within London

Department of Health.

Healthy Lives, Healthy

People: a Call to Action

on Obesity in England.

London: Department of

Sets out Government’s approach to

tackling obesity in England, in the context

of the White Paper Health Lives, Healthy

People. Sets two overarching targets:

• a sustained downward trend in the

IIA Objective 9



within London



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

Health 2011. level of excess weight in children by 2020

• A downward trend in the level of

excess weight averaged across all adults

by 2020.

Increasing physical activity and active

travel identified as one of the measures

for achieving these targets. Guidance

subsequently provided in Healthy Lives,

Healthy People briefing paper: Obesity

and the environment (DoH 2013).

Everybody active

everyday (Public Health

England, 2014)

A national action plan for promoting

physical activity to improve public health.

Identifies thoughtful urban design,

understanding land use patterns, and

creating transportation systems that

promote walking and cycling as helping

to create active, healthier, and more

liveable communities.

IIA Objective 9



within London

Environment Act 1995

Under this Act local authorities have a

duty to declare Air Quality Management

Areas.

IIA Objective 1

To contribute to a






update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

Air Quality Standards

Regulations 2010

Establishes mandatory standards for air

quality and set objectives for sulphur and

nitrogen dioxide, suspended particulates

and lead in air.

IIA Objective 1

To contribute to a




National Planning Policy

Framework (Department

of Communities and

Local Government,

2012)

Sets out requirements for planning

policies to sustain compliance with and

contribute towards EU limit values or

national objectives for pollutants.

IIA Objective 1

To contribute to a




Air Quality Plan for the

achievement of EU air

quality limit value for

nitrogen dioxide (NO2)

in the UK (Defra, 2015a)

The air quality plans set out targeted

local, regional and national measures to

ensure that UK air will be cleaner than

ever before. This will build on significant

improvements in air quality in recent

decades and fulfil environmental

responsibilities, benefit health and make

cities better places to live and work.

IIA Objective 1

To contribute to a




UK’s Air Quality Action

Plan (Defra, revised

January 2016)

Includes zone specific air quality plans,

which set targeted local, regional and

national measures to ensure the UK air

will be cleaner than ever before. There is

IIA Objective 1

To contribute to a





update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

an air quality plan for achieving EU air

quality limit value for NO2 in Greater

London (September 2011).


London policy context8

City for All Londoners

(Mayor of London,

2016)

The document sets out a direction for

London, which the Mayor will later

expand upon in detailed strategies,

including:

land use and growth (the London

Plan)

transport

housing

economic development

the environment

policing and crime

culture

health inequalities

The document encourages Londoners to

take more trips on foot or by bike - as

part of Mayoral plan for ‘Healthy Streets’.

These initiatives, designed to reduce

overcrowding, reducing health inequality,

IIA Objectives 1-9

8 Some of these documents and strategies were prepared by the previous administration and are currently in the process of being updated. However, in the interim, these plans and policies still apply.



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

making the roads safer, and contributing

to a better quality of life in London – a

demonstration of effective policy

integration.

Mayor’s Climate

Change Mitigation and

Energy Strategy

(Mayor of London,

2011)

Details the programmes and activities

that are ongoing across London to further

limit climate change and achieve the

Mayor’s target to reduce London’s CO2

emissions by 60 per cent of 1990 levels

by 2025.

IIA Objective 2

To reduce CO2 emissions


mitigation of climate

change

London Plan (Mayor of

London, 2016) The overall strategic plan for London,

setting out an integrated economic,

environmental, transport and social

framework for the development of

London over the next 20–25 years. It

considers a range of social issues such

as children and young people and health

inequalities. It also considers a range of

environmental issues such as climate

change, air quality, noise and waste.

IIA Objectives 1-9

Draft Mayor's

Transport Strategy

(Mayor of London,

Provides the statutory policy basis for

DVS. Aims to reduce emissions to

mitigate climate change and improve

IIA Objectives 1, 2

To contribute to a




update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

2017) London’s air quality. emissions and

compliance with EU limit

values




change

Mayor’s Strategy for

improving transport

safety, security and

reliability in London

2015-2017, The Right

Direction (May 2015)

Provides police partners and operators

to work together to improve transport

safety, security and reliability.

IIA Objective 6

To contribute to safety

and security and the


Draft Mayor’s

Environment Strategy

(Mayor of London,

2017)

The strategy will focus on creating a city

that is healthy, resilient, fair and green

as well as resource efficient. The

strategy provides framework for the

reduction of exposure to poor air quality,

reducing the adverse noise impacts of

road transport, reducing waste

generation and reducing CO2 emissions

from buildings and road transport.

IIA Objectives 1, 2



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

Transport Emissions

Roadmap (TfL, 2014a)

Focuses on reducing emissions from

ground based transport in London. It

introduces a range of proposed

measures to be considered by

Government, GLA, TfL and London

boroughs to help meet the challenge of

reducing CO2 emissions and air

pollutants, particularly NOx, NO2 and

PM10, in London.

IIA Objectives 1, 2

To contribute to a


emissions and

compliance with EU limit

values




change

Economic

Development Strategy

(GLA, 2010)

The Economic Development Strategy

sets out this vision with respect to the

London economy, and how it can be

realised. The Mayor’s ambitions are for

London to be the World Capital of

Business, and to have the most

competitive business environment in the

world; to be one of the world’s leading

low carbon capitals, for all Londoners to

share in London’s economic success.

IIA Objectives 3-5

Provide high quality

environment will help to

attract and retain

internationally mobile

businesses

Encourage the

development of new

businesses in new and

growth sectors



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

Equal Life Chances for

All (Policy Statement)

(GLA, 2014)

Aims to ensure that diverse

communities, particularly the most

vulnerable and disadvantage benefit

from London’s success and that services

delivered are accessible and

appropriate.

IIA Objective 7, 8


social inclusion

Action on Equality:

TfL’s Commitments to

2020 (TfL, 2016)

Action on Equality sets out the

commitments to promoting equality for

TfL customers, staff and stakeholders,

and TfL’s compliance with the Equality

Act 2010 for 2016-20.

IIA Objective 7, 8


social inclusion

London Health

Inequalities Strategy

(Mayor of London,

June 2015)

Sets out a framework for improving the

physical health and mental wellbeing of

all Londoners; reducing the gap between

Londoners with best and worst health

outcomes; creates the conditions to

improve quality of life for all; and

empower individuals and communities to

take control of their lives.

IIA Objective 7, 8


social inclusion

Improving the health of

Londoners, Transport

Action Plan (TfL,

2014b)

Sets out a framework focusing on

improvement of physical health and

mental well-being of all Londoners.

IIA Objective 9


health and wellbeing for



update


Environmental

Assessment

(EA)

Economic

and

Business

Impact

Assessment

(EBIA)

Equality

Impact

Assessment

(EqIA)

Health

Impact

Assessment

(HIA)

Community

and Safety

Impact

Assessment

(Casualty

Impact

Analysis)

(CSIA)

all within London

Better Health for

London: Next Steps

(London Health

Commission, 2015)

Builds upon the ‘Better Health for

London’ overarching goal to make

London ‘the world’s healthiest major

global city’, by identifying shared

ambitions and providing a strategic

approach for the achievement of those

ambitions.

IIA Objective 9



all within London

Mayor’s vision for

cycling in London. An

Olympic Legacy for all

Londoners (March

2013) and Human

Streets, the Mayors

Vision for Cycling

three years on (2016)

This document promises ambitious new

cycle routes and infrastructure. They are

a step-change in cycling provision. The

document sets out key outcomes to

increase cycling in London:

• a tube network for the bike;

• safer streets for the bike;

• more people travelling by bike;

• Better places for everyone.

Human Streets reports on the progress

implementing the vision and defines the

priorities for the future.

IIA Objective 9



all within London


Appendix B. Scoping out of sustainability topics and associated objectives

Assessment IIA topic ULEZ IIA Objective MTS IIA Objective Scoping for proposed DVS Scheme

EA Air quality To contribute to a reduction in air

pollutant emissions and compliance


To reduce emissions and concentrations

of harmful atmospheric pollutants

particularly in areas of poorest air quality

and reduce exposure

Scoped in on the basis that there could be effects on

air quality due to collisions accidents.9 The effects of

the proposed scheme Options will be identified by

analysing the harmful air quality emissions (NOx, PM)

changes due to collision accidents. They will be

calculated by TRL using casualty impacts analysis

using calculations for congestion and diversion

resulting from traffic accidents.

Noise To reduce disturbance from general

traffic noise

To minimise noise and vibration levels and

disruption to people and communities

across London and reduce inequalities in

exposure

Scoped out. The aim of the Direct Vision Standard is

to maximise, and rate, how much an HGV driver can

see directly from each vehicle’s cab, rather than

through mirrors or other equipment. It will give

regulators, manufacturers, operators and contractors

an objective standard by which to rate and improve the

safety of HGVs. Whilst it is not related to noise in that

its primary objective is to reduce danger for cyclists

using the city’s roads the Mayor’s vision includes

Healthy Streets to ultimately improve peoples’ health.

Reductions in noise are contributors to increased

health benefits for city dwellers and city users. Noise

and air pollution from commercial vehicles area

currently being addressed via the LoCITY programme.

Therefore, the Direct Vision Standard does not require

noise impacts to be addressed directly but does

require formal linkages and regular updates from

initiatives such as LoCITY and ULEZ.

Climate change To reduce CO2 emissions and

contribute to the mitigation of

climate change

To help tackle climate change through

reducing greenhouse gas emissions and

moving towards a zero carbon London by

Scoped in. There could be effects on climate change

as a result of CO2 emissions change due to collisions

accidents. The effects of the proposed scheme

9 The topic was scoping in on the assumption that TfL and TRL will provide necessary data on congestion and CO2 emissions.



2050 Options will be identified by analysing the greenhouse

emission (CO2) changes due to collision accidents.

They will be calculated by TRL using casualty impacts

analysis using calculations for congestion and

diversion resulting from traffic accidents.

Biodiversity

including flora

and fauna

To protect and enhance the natural

environment, including biodiversity,

flora and fauna

To protect, connect and enhance

London’s natural capital (including

important habitats, species and

landscapes) and the services and benefits

it provides, delivering a net positive

outcome for biodiversity

Scoped out. No significant effects on natural

environment are expected.

Cultural heritage To protect and enhance historic,

archaeological and socio-cultural

environment

To conserve and enhance the existing

historic environment including sites,

features, landscapes and areas of

historical, architectural, archaeological

and cultural value in relation to their

significance and their settings

Scoped out. No significant effects on cultural heritage

are expected.

Water To protect and enhance river

spaces and waterways through

planning and operation

To protect and enhance London’s eater

bodies by ensuring that London has a

sustainable water supply, drainage and

sewerage system

Scoped out. No significant effects on water

environment are expected.

Material

resources and

waste

To promote more sustainable

resource use and waste

management

To keep materials at their highest value

and use for as long as possible. To

significantly reduce waste generated and

achieve high reuse and recycling rates

Scoped out. The impact would mainly be focused on

the vehicles used to collect the various waste

materials. These are generally Refuse Collection

Vehicles (RCVs) and would fall under consideration for

the scheme restrictions due to their size. However,

waste disposal (refuse) trucks use low entry cabs with

good direct vision and are up to 5 star rated and

therefore waste collection and disposal services are

not likely to be affected by the scheme.

The main impact in waste generation would be relating

to any scrappage that would have to take place within



Waste management fleets/HGVs in order to meet any

future scenarios.

In terms of scrappage, the impact would not likely be

significant due to the ‘musical chairs’ effect, where by

most older or unsuitable vehicles aren’t scrapped but

instead are sold on the second hand market, leading

to a low scrappage %. Most vehicles that would be

swapped by owners for newer models would find their

way into the logistics system via another avenue. Also

this process could happen within Haulage firms,

whereby they swap older vehicles out to be used on

routes outside of the Standard zone and purchase

compliant vehicles for use where required.

Therefore, it is not anticipated that there would be any

waste impacts and Jacobs recommend that this topic

is not scoped into the Environmental Assessment.

Geology and soils Not included To conserve London’s geodiversity and

protect soils from development and over

intensive use

Scoped out. The proposal is not likely to result in

material or significant changes to impacts on the

geology and soils.

Landscape,

townscape and

urban realm

To protect and enhance the built

environment and streetscape

To create attractive, mixed use

neighbourhoods, ensuring new buildings

and spaces are appropriately designed

that promote and enhance existing sense

of place and distinctiveness, reducing the

need to travel by motorized transport

Scoped out. The scheme would require the installation

of new signage on main roads and at junctions. The

scheme will use the existing network of cameras. A

camera network is already in operation due to the Low

Emissions Zone, and it is anticipated that any signage

could be combined with existing Low Emission Zone

signs. Therefore, it is not anticipated that there would

be any landscape, townscape or urban realm impacts

and Jacobs recommend that this topic is not scoped



into the Environmental Assessment.

HIA Health and well-

being

To contribute to enhanced health

and wellbeing for all within London

To improve the mental and physical health

and wellbeing of Londoners and to reduce

health inequalities across the City and

between communities

Scoped in. The scheme may have significant effects

on health and wellbeing.

EBIA London’s

economic

competitiveness

Provide an environment which will

help to attract and retain

internationally mobile businesses

To maintain and strengthen London’s

position as a leading, connected,

knowledge based global city and to

support a strong, diverse and resilient

economy providing opportunities for all


on London’s economic competitiveness.

SMEs Support the growth and creation of

SMEs

Not explicitly included Scoped in. There may be some particular sectors that

will be more significantly impacted as a result of the

scheme

CSIA Community and

Road Safety

N/A To contribute to safety and security and

the perceptions of safety


on road safety and security and the perceptions of

safety.

EqIA Population and

equality

To enhance equality and social

inclusion

To improve the mental and physical health

and wellbeing of Londoners and to reduce

health inequalities across the City and

between communities

Scoped in. The scheme may have disproportional

effects on the most vulnerable road users.


Appendix C. IIA Methodology

C.1 Economic and Business Impacts Assessment

One of the purposes of the GLA (GLA Act 1999: Section 30 (2) (a)) is to promote economic development and

wealth creation in Greater London. The proposed DVS should therefore take account of its likely effects on

London’s economy through an EBIA.

Whilst there is no statutory guidance on undertaking an EBIA, economic development is a key element of

sustainability.

The primary aim of the DVS EBIA requirement is to determine and objectively asses the economic and business

impacts associated with implementing the scheme in London 2020 and 2024 to form part of the full IIA of the

scheme.

The specific objectives of the EBIA are to:

Provide a comprehensive understanding of the economic and business impacts with specific focus on the HGV and Freight industries, their customers, vehicle manufacturers and more widely as identified.

Complete an assessment of the scale of the economic and business impacts when applied to different scheme options.

Provide an estimate of monetary value of the impacts both positive and negative of the implementation of the scheme options.

Ensure the EBIA:

o Uses the most up to date data and inputs available

o Considers the economic and business impacts of the scheme on HGV manufacturers and dealers, freight operators and other individual businesses with specific consideration of the impacts on Small to Medium Enterprises (SMEs)

o Considers the impact on the Freight industry’s customers, including the housing and construction industry.

o Considers the impact on London’s wider economy in terms of competitiveness, market opportunity and other potential costs or benefits from the scheme

o Provides a commentary on whether the economic and business impacts identified affect any of the other impacts (equality, environmental, health, and other statutory duties detailed in 2.4.4) to be considered within the wider DVS Integrated Impact Assessment.

o Considers the potential combined impact of the Mayor’s Ultra Low Emission Zone (ULEZ) and the scheme proposals on HGV operators and manufacturers using existing ULEZ scheme information and data analysis and information provided by TfL.

The EBIA supports and informs the IIA and informs the scheme development by assessing the impacts on all

stakeholders.

An economic model that compares benefits and costs of alternative implementation options and sensitivities

with a “Do Minimum” baseline has been produced for the IIA. Findings and recommendations from the TRL CIA

will be incorporated into the model.


The EBIA is the corner stone of the IIA and provides the quantitative analysis and data that informs other

elements of the IIA such as health, economic and equality impact assessments.

In addition to the data sources the following work has been carried out in parallel to the EBIA by consultants on

TfL’s behalf, which will inform the development of the IIA.

Rating HGVs to the DVS. Loughborough University Design School has been commissioned by TfL to work with manufacturers to finalise the methodology for rating HGVs to the DVS and produce an initial set of HGV star ratings. The ratings were available for Euro VI (ULEZ emissions compliant) vehicles from the end of May 2017. It is expected that these ratings would also be able to broadly apply to older Euro IV and V vehicles as a number of HGV cab designs have not changed.

Collision and casualty impact analysis (CIA). The TRL has been commissioned by TfL to assess the impact of the scheme on collisions with a specific focus on the number of people killed and seriously injured.

EBIA methodology

The EBIA has been integrated into the IIA framework through identification and inclusion of relevant economic

IIA Objectives in the IIA framework and the IIA assessment will be informed by the findings of the EBIA and CIA

studies. The IIA objectives for EBIA are shown in the table below:

IIA EBIA Objectives

3.Provide high quality environment will help to attract and retain internationally mobile

businesses

4.Encourage the development of new businesses in new and growth sectors

Working with Transport for London (TfL), Transport Research Laboratory (TRL) and Loughborough University, a

model has been developed to estimate the number of N3 vehicles that would comply by 2020 and 2024

respectively, their likely behavioural response for non-compliant vehicles, the safety implications, impact on

demand as a result of the scheme, the health implications, emissions and reliability implications, and the

financial cost of the scheme. The economic impacts on businesses as a result of the scheme were assessed for

the following sectors:

General Distribution: retail, wholesale, manufacturing specialised cargo distribution

Construction: delivery of goods and services to/and from construction sites

Food & Drink: deliveries to accommodation and food service facilities

Utilities and Servicing: refuse and waste management, utility and communications service

providers

Office, light freight and servicing: post and package deliveries and other services

This requires analysis of the number of N3 class vehicles forecasted to be (non) compliant by the years 2020

and 2024 respectively, assessing the proportion of N3 class vehicles by sector entering Greater London and

assessing the behavioural responses of those not compliant to the required star ratings. N3 class vehicles

make up less than 4% of the miles drive in London, but in 2015 they were involved in around 78% of cyclist

fatalities and 20% of pedestrian fatalities.10

The EBIA has taken the following steps:

10 Direct Vision Standard Phase 1 Consultation Support Document, TfL, 2017


1. Estimation of cost to businesses and the cost of enforcement and operation

2. Shortlist the five options via option sifting based on the cost estimation

3. Estimation of the benefits and the benefit-cost ratio of the shortlisted options

In assessing the impact of the proposed scheme, the Benefit-Cost Ratio (BCR) has been calculated for the

shortlisted options. The BCR has been used to inform the value for money of the options assessed, whereby

the scale of the impact has been determined by the following scores applied based on the BCR:

Poor VfM if the BCR was less than 1.0.

Low VfM if the BCR was between 1.0 and 1.5.

Medium VfM if the BCR was between 1.5 and 2.0.

High VfM if the BCR was between 2.0 and 4.0.

Very high VfM if the BCR was greater than 4.0.

The Net Present Value (NPV) has also been calculated, which is simply the sum of future discounted benefits

minus the sum of future discounted costs. The appraisal period of the scheme is 10 years, assuming an

opening year of 2020; we estimate by 2029 all HGVs entering London would be compliant to three stars.

The assessment has reported the safety implications in the form of the change in the number of casualties,

induced demand of cyclists as a result of the scheme, health benefits as a result of induced cycle demand and

the financial implications of the proposed scheme overall, based on the feedback from the focus groups and

surveys, highlighting the key sectors most impacted by the proposals and their expected behavioural

responses, as can be seen in Figure below.


Economic and Business Impact Model Overview

The following costs and benefits of the scheme have been assessed:

Purchase of compliant vehicles

Withdrawal of vehicles

Safety mitigation features

Impact on the economy as a result of withdrawal from the London market

Loss of residual value

Downtime due to the change in fleet

Costs associated with switching manufacturers

Casualty prevention values

Cycling health benefits

C.2 Environmental Assessment

Although the scheme proposal is not a plan or a programme as defined in the Strategic Environmental

Assessment (SEA) Directive, the Environmental Assessment (EA) will be undertaken with reference to

Government Guidance on SEA. It is a systematic process that identifies and predicts the potential significant

environmental effects of plans / programmes, informing the decision-making process by testing different

alternatives or options against environmental sustainability objectives. The following SEA principles will be

applied to this IIA:

the findings of the assessment are published in an IIA Report, which sets out the significant

effects of the scheme;

consultation is undertaken on the proposals and the draft IIA;

the results of consultation are taken into account in decision-making relating to the adoption of

the proposal; and

Information on how the results of the assessment have been taken into account is made

available in the IIA report.

The process of undertaking the IIA contemporaneously with the development of the Standard has enabled TfL

to follow the Government Guidance on SEA.

EA Methodology

The objective of the environmental assessment is to assess the environmental impact of the scheme Options in

in Greater London.


An EA has been integrated into the IIA framework through identification and inclusion of relevant environmental

IIA Objectives in the IIA framework and the IIA assessment has been informed by the findings of the CIA

studies. The IIA objectives for environment are shown in the table below:

The IIA objectives for environment are shown in the table below.

IIA EA Objectives

1.To contribute to a reduction in air pollutant emissions and compliance with EU limit values

2.To reduce CO2 emissions and contribute to the mitigation of climate change

Temporal Scope

It is assumed that the scheme would be introduced in 2020, and that the proposed scheme Options would be

introduced in 2020 and 2024 respectively. It is suggested that the Environmental Assessment focuses on a time

period from 2020 – 2025 to demonstrate the impacts beyond the start date of DVS.

The study area for the Environmental Assessment will fall within the Greater London Administrative Area

(GLAA).

Scope

Jacobs proposed to scope in the following environmental topics:

Air quality

Climate change

Emissions calculations

The effects of the proposed scheme Options on these topics has been identified by analysing the greenhouse

and harmful air quality emissions (NOx, PM and CO2) changes due to reduction of the collision accidents. They

have been calculated by TRL using casualty impacts analysis using calculations for congestion and diversion

resulting from traffic accidents. Defra’s Emission Factors Toolkit (EFT) has been used to calculate the emissions

from the traffic. The input to this is the vehicle flows and speeds.

Topics scoped out

The scoping exercise carried out in June 2017, identified that the following topics would not be assessed as part

of the Environmental Assessment:

Landscape, townscape and urban realm: The scheme would require the installation of new signage on main roads and at junctions. The scheme will use the existing network of cameras. A camera network is already in operation due to the Low Emissions Zone, and it is anticipated that any signage could be combined with existing Low Emission Zone signs. Therefore, it is not anticipated that there would be any landscape, townscape or urban realm impacts and Jacobs recommend that this topic is not scoped into the Environmental Assessment.

Water: Due to the nature of the scheme proposals, no measurable impacts on water resources are expected in terms of changes to water resources or water quality. Therefore, Jacobs recommend that this topic is not scoped into the Environmental Assessment.

Soils: In the context of the urbanized London study area and given the likely level of air quality changes anticipated, it is not expected that there would be any significant impacts to soil quality due to air pollution deposition.


Noise: The aim of the Direct Vision Standard is to maximise, and rate, how much an HGV driver can see directly from each vehicle’s cab, rather than through mirrors or other equipment. It will give regulators, manufacturers, operators and contractors an objective standard by which to rate and improve the safety of HGVs. Whilst it is not related to noise in that its primary objective is to reduce danger for cyclists using the city’s roads the Mayor’s vision includes Healthy Streets to ultimately improve peoples’ health. Reductions in noise are contributors to increased health benefits for city dwellers and city users. Noise and air pollution from commercial vehicles area currently being addressed via the LoCITY programme. It is a structured, collaborative programme that brings together the full range of stakeholders needed to stimulate the uptake of low emission commercial vehicles with the objective of engaging with freight and fleet operators, vehicle manufacturers and infrastructure providers to increase the availability and uptake of low emission commercial vehicles operating in London. Therefore, the Direct Vision Standard does not require noise impacts to be addressed directly but does require formal linkages and regular updates from initiatives such as LoCITY and ULEZ.

Biodiversity and nature conservation: Due to the nature of the scheme proposals, no measurable impacts on cultural heritage are expected in terms of changes to water resources or water quality. Therefore, Jacobs recommend that this topic is not scoped into the Environmental Assessment.

Cultural heritage: Due to the nature of the scheme proposals, no measurable impacts on cultural heritage are expected in terms of changes to water resources or water quality. Therefore, Jacobs recommend that this topic is not scoped into the Environmental Assessment.

Materials and waste: The impact in terms of Waste would mainly be focused on the vehicles used to collect the various waste materials. These are generally Refuse Collection Vehicles (RCVs) and would fall under consideration for the Standard restrictions due to their size and large blind spots. The main impact in waste generation would be relating to any scrappage that would have to take place within Waste management fleets/HGVs in order to meet any future scenarios. In terms of scrappage, the impact would not likely be significant due to the ‘musical chairs’ effect, whereby most older or unsuitable vehicles aren’t scrapped but instead are sold on the second hand market, leading to a low scrappage %. Most vehicles that would be swapped by owners for newer models would find their way into the logistics system via another avenue. Also this process could happen within haulage firms, whereby they swap older vehicles out to be used on routes outside of the Standard zone and purchase compliant vehicles for use where required. The same process would have to take place for RCVs operating within the new area but again the impact on scrappage for these would be reduced. One additional consideration for RCV vehicles is that it is much harder to remove the need for these to enter the DVS area, as could be possible via a consolidation centre for logistics vehicles, due to the nature of waste needing to be collected from all properties and the difficulties in transferring waste in terms of permits and practicalities. Any that did end up being scrapped would need to be sent to an approved End of Life Vehicle facility to be disposed of in the proper manner due to the hazardous materials within vehicles such as battery acid and other oils. Therefore, it is not anticipated that there would be any waste impacts and Jacobs recommend that this topic is not scoped into the Environmental Assessment.

It was also assumed that:

• Waste disposal (refuse) trucks use low entry cabs with good direct vision and are up to 5 star rated

and therefore waste collection and disposal services will not be affected by the scheme; and

• Vehicle operators will not be replacing fleet with older more polluting and noisy vehicles.

C.3 Equality Impact Assessment

The Equality Act 2010 (Equality Act) requires public authorities to work to eliminate discrimination and promote

equality in all their activities. Under Section 149 of the Equality Act the Mayor of London is subject to the Public

Sector Equality Duty (PSED).

The duty requires the Mayor (and TfL) to have due regard to the need to eliminate unlawful discrimination,

harassment and victimisation as well as to advance equality of opportunity and foster good relations between

people who share a protected characteristic and those who do not under section 149 of the Equality Act


2010. This may involve, in particular, removing or minimising any disadvantage suffered by those who share a

relevant protected characteristic, taking steps to meet the needs of such people; and encouraging them to

participate in public life or in any other activity where their participation is disproportionately low, including

tackling prejudice and promoting understanding. (The protected characteristics and groups are: age, disability,

gender reassignment, pregnancy and maternity, race, gender, religion or belief, sexual orientation and

marriage/ civil partnership status) Compliance with the duty may involve treating people with a protected

characteristic more favourably than those without the characteristic. The Equal Life Chances for All framework

(2014) highlights the Mayor’s commitment to tackling inequality, improving life chances and removing barriers

that prevent people from reaching their full potential.

EQIA Methodology

The objective of the equality assessment is to assess the equalities impacts, both positive and negative, of

implementing the scheme proposals.

The IIA objectives for equality are shown in the table below:

IIA Equality Objectives

7. To reduce the number of casualties from protected groups as a result of HGV related

accidents

8. To advance equality of opportunity or small and medium enterprise owned by protected

and disadvantaged groups.11

Equalities Groups

The impacts of the implementation of the scheme Options on equalities have been considered in relation to the

impact on people with protected characteristics, as defined by the Equalities Act 2010 (‘the Act’). The Act

consolidated previous legislation designed to prohibit discrimination on the grounds of protected characteristics

and identifies nine protected characteristics. They are defined in Table below:

Group Definition

Age Where this is referred to, it refers to a person belonging to a particular age (for

example 32 year olds) or range of ages (for example 18 to 30 year olds).

Disability A person has a disability if she or he has a physical or mental impairment which has

a substantial and long-term adverse effect on that person's ability to carry out

normal day-to-day activities.

Sex A man or a woman.

Race This refers to the protected characteristic of Race. It refers to a group of people

defined by their race, colour, and nationality (including citizenship) ethnic or national

origins.

Pregnancy

and Maternity

Pregnancy is the condition of being pregnant or expecting a baby. Maternity refers

to the period after the birth, and is linked to maternity leave in the employment

context. In the non-work context, protection against maternity discrimination is for 26

weeks after giving birth.



Group Definition

Gender

Reassignment

The process of transitioning from one gender to another.

Religion or

belief

Religion has the meaning usually given to it but belief includes religious and

philosophical beliefs including lack of belief (such as Atheism). Generally, a belief

should affect your life choices or the way you live for it to be included in the

definition.

Sexual

Orientation

Whether a person's sexual attraction is towards their own sex, the opposite sex or to

both sexes.

Marriage and

civil

partnership

Marriage is no longer restricted to a union between a man and a woman but now

includes a marriage between same-sex couples. Same-sex couples can also have

their relationships legally recognised as 'civil partnerships'.

Table 3.1: Protected Characteristics as defined in the Equality Act 2010

The Equality Act 2010, as adopted, does not specify socioeconomic status as a protected characteristic. TfL

has identified seven groups of Londoners12

who experience a variety of barriers when accessing public

transport when producing its baseline data sets further to the characteristics protected by the Act. The first six of

these broadly correspond to Protected Characteristics. The last group refers to those in low income groups.

Lesbian, gay, bisexual and transgender Londoners covered under Sexual orientation and Gender reassignment

will be scoped out of the assessment on the basis that there will be no differential or disproportionate impact on

this group.

The groups that have therefore been considered within the IIA are:

Older Londoners (aged 65 and over) covered under Age;

Younger Londoners (aged 24 and under) also covered under Age;

Disabled Londoners covered under Disability;

Black, Asian and minority ethnic groups covered under Race/ethnicity/nationality and

Religion/belief in the Act;

Women covered under Gender and Pregnancy and maternity in the Act;

Londoners living in deprived areas.

Baseline

Baseline data has been compiled from a wide range of sources including Census 2011, IMD2010, and TfL

surveys and research. These data have been collected to provide an understanding of:

the distribution of people with protected characteristics and socio-economically deprived

communities – across Greater London;

the current use of different modes of transport, by people with protected characteristics and on low

incomes, with a particular focus on attitudes to cycling;

representation of sensitive equality groups at risk of HGV accidents.

The EQIA has identified disproportionate and differential impacts on Equality Groups defined as follows:

a differential equality impact is one which affects members of a protected group differently from the

rest of the general population because of specific needs or a recognised sensitivity or vulnerability

associated with their protected characteristic; and

12 Transport for London (2015) – Travel in London: Understanding Our Diverse Communities – A Summary of Existing Research –pp.5.


a disproportionate impact is one which has a proportionately greater impact on members of an equality group

than on other members of the general population at a particular location (area).

For the equality impact assessment, the scale of impact has been defined as positive, negative or neutral and

disproportionate or differential, based on best-practice guidance and professional judgement.

The scale of the impact has been determined by:

magnitude of change – the spatial extent (i.e. how large an area, or number of people) of the

impact and if they will be disproportionately impacted. For the purposes of the IIA, each impact has

been scaled as minor, moderate or major; and

sensitivity to change – how sensitive is the population group to the impact being considered? For

example, is there an affordable / accessible alternative; does that group have specific needs which

would otherwise be difficult to meet; does the group have a particular susceptibility to the impact

due to their characteristics (e.g. disability; age etc.).

The potential impacts arising from implementation of the scheme has been determined using a combination of

data outputs from traffic modelling, Geographical Information Systems (GIS) mapping and technical

professional judgement. The EQIA has been directly informed by the outputs of technical work informing the

environmental, health and economic and business assessments, and cross references to these studies included

where relevant, to enable the reader to explore the methodologies employed in further detail. Baseline

information used to identify potential equality impacts will include:

HGV accident data for non-motorised users (NMUs) (by protected characteristic).

Use of (and barriers to the use of) cycling and walking by equality groups within Greater London,

including the particular needs of disabled people in respect of public, community and private

transport;

BAME ownership of businesses that are operating HGV fleets.

Baseline Data required

Area Data required Notes Source

Social

Inclusion

Indices of deprivation IMD2015, the Income

Deprivation Affecting

Children Index (IDACI); Income

Deprivation Affecting Older

People Index (IDAOPI)

TfL analysis of the co-incidence

of deprivation and HGC related

accidents.

English Indices of

Deprivation 2015

(available at:

https://www.gov.uk/gover

nment/statistics/english-

indices-of-deprivation-

2015).

Travel

behaviour

Travel behaviour by

groups including the

equalities groups

Travel needs of London’s

diverse communities (2015) –

various data sets e.g. how

different equality groups

(including low income) use

transport (e.g. cycling)

differently.

TfL London Travel

Demand Survey.

Road Safety Accident data

(pedestrians and

Breakdown of HGV/NMU

accident statistics for different

groups (by age, sex, ethnicity,

TfL

https://www.gov.uk/government/statistics/english-indices-of-deprivation-2015





Area Data required Notes Source

cyclists) disabled) in London

Business

owners

Ethnicity of business

owners with HGVs.

Results from the business

survey conducted as part of the

ULEZ IIA can be used to inform

this.

To speak with the

Construction/Freight

Industry Association and

other relevant bodies.

C.4 Health Impact Assessment

HIA methodology

This methodology note describes the approach to the assessment of the health impacts associated with the

proposed scheme.

In 2007 the Greater London Authority Act gave the Mayor a statutory duty and power to lead on health

inequalities in London. TfL already have a strong health action plan – Improving the Health of Londoners:

Transport Action Plan (2014). This will provide the framework for the relevant derivation of the health related IIA

Objectives against which the scheme Options will be evaluated.

The enforcement of the scheme would not only lead to a reduction in the number of casualties in Greater

London, but the scheme would expect to induce cycling as a result of improved safety perception.

A recent survey conducted by TfL have shown among the number of deterrents to increased cycling, 44% of

respondents (September 2016) picked the “fear of being involved in a collision”, the most common deterrent to

cycling more. Similarly, 55% of respondents (September 2016) picked the same deterrent to taking up cycling.

Additionally, induced cycling leads to an increase in potential health benefits associated with more cycling. The

health benefit of the increased cycling has been calculated using the World Health Organisation’s Health

Economic Assessment Tools (HEAT) for cycling. This tool is designed to help conduct an economic assessment

of the health benefits of cycling be estimating the value of reduced mortality that results from specified amounts

of cycling. The tool is designed for habitual behaviour, such as cycling for commuting, or regular leisure time

activities.

The assessment of the health impacts of the scheme Options against the health related IIA Objective has been

informed by the EBIA study which identified and quantify health benefits and induced cyclist benefit using the

‘HEAT’ tool as part of their study.

To calculate the induced demand of cycling, forecast cycling km for the year 2021 and 2031 were modelled

using TfL’s Cycling Network Model for London (Cynemon), which estimates cycling routes, journey times and

flows at a strategic level across London for scheme and policy appraisal. Forecast of the cycling km travelled

between 2021 and 2031 is extrapolated. Once the forecast of the cycling km travelled is estimated, a proportion

of the cycle km travelled would assume to be attributed to increased safety perception, subsequently to the

scheme.

An HIA has been integrated into the IIA framework through identification and inclusion of relevant health

relevant IIA Objectives in the IIA framework and the assessment has been informed by the findings of the EBIA.

The IIA objective for health is shown in the table below:

Topic IIA objective

Health and well-

being

9. To contribute to enhanced health and wellbeing for all within London


Topic IIA objective

The assessment contains quantitative and qualitative analysis of health impacts:

o The quantitative analysis focused on the following elements:

Reduced fatalities and injuries as a result of the scheme; and

Monetised value of increased physical activity due to changes in cyclist demand as a result of

the scheme.

o The qualitative analysis focused on the following:

Increase in active travel (cycling) due to improvements in perceptions of road safety

Assessment of health benefits (quantitative assessment)

The expected reduction in fatalities and injuries has been estimated by TRL as part of the CIA; the methodology

is explained in the Community Safety Impact Assessment Section.

According to TfL’s Attitudes towards Cycling (AtC), September 2016 report one of the main reasons for cycling

less is fears about safety. It was expected that DVS would provide a safer environment for cyclist as assessed

through the CIA and this would induce an increase in cycling demand. This increase has been estimated using

perception statistics in the AtC combined with cycling modelling results provided by TfL. This information has

been used to calculate health benefits using the World’s Health Organisation (WHO) Heat Tool. This tool has

provided monetised values of health benefits of increased physical activity due to increase in cycling demand in

London.

Increase in active travel (cycling and walking) due to improvements in perceptions of road safety

(qualitative assessment)

This section provided further details of the expected impact of the increase in cycling through a qualitative

assessment. The qualitative aspects of the HIA provided the overall health context for the proposed scheme.

The section also examined whether the scheme would make pedestrians more at ease as well, particularly

vulnerable ones who felt intimidated crossing roads, e.g. older people, children and disabled people and was

reported as non-quantified benefits.

Outline of approach

The assessment has considered the results of the Environment Assessment (EA), the Equality Impact

Assessment (EqIA) and the Economic and Business Impact Assessment (EBIA). These results have been

considered at a high level.

The HUDU Rapid HIA self-completion form (NHS Healthy Urban Development Unit, 2013), which is TfL’s

standard methodology, has formed the basis of scoping and assessment. The form posed questions about the

ways in which a proposal might affect health and wellbeing. It provided a structure for working through the

determinants of health and identifying topics that should be included in an assessment. The following table

identifies the topics that will be assessed by the HIA.

Topic Assessment Description

Active travel The way in which people are able to move about the city and to access goods


Topic Assessment Description

and services is important for health & wellbeing.

Population-level efforts to increase non-leisure physical activity, particularly

active transport, are important means of promoting and maintaining active

lifestyles. Walking to and from public transport stops can help physically

inactive populations attain the recommended level of daily physical activity.

The implementation of the scheme may have an impact on the mode of

transport chosen for travel and may influence the level of active transport.

As the modal shifts resulting from the scheme have not been modelled,

results of the EqIA and a literature will be form the basis of the assessment.

Safety Road safety, specifically vehicle safety, involves many factors such as driver

behaviour and education, law enforcement, roadway engineering, traffic

patterns and environmental attributes all working in unison to affect the overall

health of the public. This HIA considers the potential effects of the scheme of

changes in traffic volume and driver behaviour.

Assumptions

All assumptions have been clearly documented.

Participatory requirements

Due to a high level of uncertainties during the initial development of the scheme, it was considered to be

appropriate to seek views from the Directors of Public Health during the public consultation on the proposed

draft Consultation Report and the accompanying IIA report that is to be held in autumn 2017 as well as other

statutory consultees.

Recommendations for further assessment

Consideration has been given to how the analysis might be extended.

Key data sources

Health Economic Assessment Tool (HEAT), available from http://www.heatwalkingcycling.org/index.php?pg=cycling&cs=q2a&m=pre

Cycling modelling output provided by TfL

TfL (September 2016), Attitudes towards Cycling, September 2016 Report.

C.5 Community Safety Impact Assessment

The Crime and Disorder Act 1998 (as amended) and the Police and Justice Act 2006 (as amended) make

provision for preventing and combatting crime and disorder. The GLA and TfL have a statutory duty under

http://www.heatwalkingcycling.org/index.php?pg=cycling&cs=q2a&m=pre


section 17 of the Crime and Disorder Act to take community safety into consideration in all of its decision-

making. Other statutory duties that TfL will need to consider are: Road Traffic Act Duties and other legal

considerations, i.e.: Traffic movement duty under Road Traffic Act 1984; and Network management duty under

Traffic Management Act 2004. These have been subject to a scoping exercise to identify relevant IIA Objectives

for the inclusion in the IIA framework.

The DVS scheme is concerned with the design of the HGVs and thus will not have direct impacts on the crime

and disorder. These issues as well other Road Traffic Act duties have been streamlined through the selection of

the road safety IIA objectives 5 and 6 to ensure the overall conformity with the above mentioned duties.

The Community Safety Impact Assessment (CSIA) has been based and informed by the Casualty Impact

Assessment (CIA) studies conducted by the TRL aiming to answer the following questions:

1) What is the quantity of casualties that could be affected by the scheme?

2) Who are the casualties involved, and will these help to reduce inequalities?

3) What are the associated cost, congestion and emissions savings associated with the reduced

casualties?

The primary objective of the Standard CIA requirement was to identify and objectively assess the impact in

terms of reducing the numbers of people killed and seriously injured associated with the proposal to use the

DVS for HGVs to ban or restrict those HGVs with poor standards of direct visibility from London. The CIA has

measured the benefits for London deriving from the implementation of the Standard by quantifying expected

casualty changes from current and future baselines. A London-specific CIA of the Scheme has informed the IIA

and development of the final scheme.

CSIA Methodology

A CSIA has been integrated into the IIA framework through identification and inclusion of relevant road safety

relevant IIA Objectives in the IIA framework and the IIA assessment has been informed by the findings of the

CIA studies. The IIA objectives for road safety is shown in the table below:

IIA CSIA Objectives

5.To contribute to safety and security and the perceptions of safety13

6. To contribute to the avoidance, elimination or reduction of road congestion or other

disruption of the movement of traffic

Casualty Impacts

TRL has defined the target population of collisions that may be influence by the proposed policies as those

where a pedestrian or cyclists is injured in collision with the front of an HGV that is moving off from rest or the

side of an HGV that is turning. Data relating to the number and severity of such casualties has been derived

from Stats 19 records over several years. Any trends will be identified and a forecast of the expected numbers

made over an evaluation period, on the basis of no new policies being implemented (Do Nothing).

Vehicles at all levels of direct vision performance already exist. The effectiveness of direct vision in improving

outcomes has been assessed by considering the risk posed by different vehicle types with different vision

capabilities in terms of the number of relevant casualties per unit of exposure (per registered vehicle or per

vehicle km). This has been combined with experimental research considering the benefits of direct vision and

the benefits of other technologies capable of influencing the same collision types. In this way the effect of direct

vision can be directly linked to the exposure (registered vehicles entering London, or vehicle km in London)

such that the casualty effect is directly proportional to the changes brought about in the vehicle fleet by each

13 The DVS scheme is concerned with the design of the HGVs and thus will not have direct impacts on the crime and disorder. These issues as well

other Road Traffic Act duties have been streamlined through the selection of the road safety related IIA objective 6 and the EBIA related IIA objective 4 to ensure the overall conformity.


policy option. This change in the fleet is a common element directly linked to both casualty reduction and

business impact.

Congestion Effects

Stats19 accident data was merged with traffic data from TfL’s Automatic Traffic Counter networks. The

Automatic Traffic Counters report flow and average speed for each hour. Where an accident had occurred

within 500m of a traffic counter the data was analysed to see how much the speed in the area dropped

compared to the same hour the previous week.

It was found that generally only traffic counters on the same road as the accident saw a drop in speed (parallel

roads did not generally see a significant speed drop). As a result, only detectors on the same road as the

accident were considered for further analysis. It was also found that only detectors within around 300m of an

accident saw a significant drop in speed. Therefore, it was assumed that the range of an accidents impact is

around 300m.

The hours containing and following each accident were looked at to see how long each road was disrupted for.

An average vehicle delay was calculated from this data by multiplying the average difference in speed from the

previous week to this week (averaged over all lanes/directions of travel and all affected hours) and multiplying

by 300m (the distance the data suggests is affected by an accident on average). The total delay was calculated

by multiplying this by the number of vehicles which passed the detectors. The total delay was turned into a

monetary value using the values of time from WebTAG.

The average cost for fatal, serious accidents and slight accidents was calculated from this for the final output.

Emissions Effects

A road traffic accident is likely to lead to an increase in emissions due to:

• Congestion: The accident will lead to congestion and start/stop traffic. This will increase the

emissions relative to normal traffic conditions

• Diverting: Drivers might choose to avoid the area or be directed by the police around the area (in

a case of the police closing the road). This will lead to an increase in the distance covered, resulting in

higher emissions than normal.

In addition, there may also be other vehicles required to attend the incident – police, ambulance, fire, vehicle

recovery etc. However, their impact will be small in comparison to the congestion and diversion effects, so these

will not be included in the analysis.

Traffic data

To analyse the effect, the London accident traffic data (as above) has been used. The emissions then have

been determined for the incident period and the standard period.

Emissions calculations

Defra’s Emission Factors Toolkit (EFT) has been used to calculate the emissions from the traffic. The input to

this is the vehicle flows and speeds. Normally, AADT (annual average daily traffic) are used, but for this work

TRL has used the hourly flows and speeds, collated over all the lanes for each direction. The input also requires

the light-duty: heavy-duty split, which is not available from the accident traffic database. This has either been

determined separately from existing traffic data sources or a default value of 10% heavy-duty vehicles (trucks

and buses) has been used. The emissions of NOx, PM and CO2 has been determined as follows:

Congestion:


1. The emissions with the accident have been calculated using the EFT based on the flows &

speeds from the accident day; over all the hours the incident appears to affect flow.

2. The emissions without the accident have been calculated using the EFT based on the flows &

speeds from non-accident days; over the same hours as the incident.

3. The total emissions from (2) has been subtracted from (1) to give the change in emissions in

g/km

4. The length of road disruption will be estimated, based on the changes if flows and speeds in the

traffic data. A small change has indicated a short length (e.g. 200m) whereas a large change affected

a greater length (e.g. 1 km). This then has been used to determine to total change in emissions in g or

kg.

Diversion:

1. This has been determined when there appears to be a reduction in the flows at the incident.

2. The reduction in flow has assumed to divert around the incident (alternatively: a fixed percentage

of the total flow has assumed to divert).

3. As the distance would not be known, an assumed value for the additional distance has been

assumed (e.g. 0.5 km).

4. The emissions have been calculated using the EFT using typical non-accident speeds.

5. As buses are unlikely to divert from their route unless the road is completely closed, the

percentage of heavy-duty vehicles in the diverted fleet has been reduced from that used above.

The two then have been combined to give the total increase in emissions in g or kg. These has been compiled

together into a live spreadsheet that included some of the assumptions above (e.g. length or road affected) so

that these could have been modified at a later date if required.

Fleet composition and modelled years

The composition of the local fleet plays an important role in the resulting emissions. As the year’s progress, old

dirty vehicles get scrapped and newer clean vehicles are introduced into the fleet. The EFT includes the year,

which defines the fleet composition to use for the calculations. As the year will affect the overall emissions, it

has been proposed that the emissions are calculated for a base year (2015) plus future years: 2020 and 2025.


Appendix D. Cost and Business Impact Assessment (CBIA) Report


Appendix E. Casualty Impact Assessment (CIA) Report


Appendix F. Detailed IIA of the Shortlisted Scheme Options

Scheme Options Assessment – Do Minimum – Baseline

Assessment of Benefits


EA Topic: Air Quality

IIA Objective 1: 1. To contribute to a reduction in air pollutant emissions and compliance with EU limit values

The assessment focused on the reduction in NOx, PM10 and PM2.5 emissions as a result of the reduced congestion and diversion from collisions avoided and has been informed by the findings of the CIA report that can be found in Appendix E of this IIA report.

Baseline

The effect on traffic flow on routes around a collision between an HGV and a VRU was studied for a small sample of 21 collisions where traffic data was available. The duration of disruption on the affected and surrounding roads was measured and Defra’s emissions factors toolkit was used to calculate additional emissions as a consequence of both start stop traffic and diversion around the incident.

Effects of the scheme

The sample suggested that on average each collision avoided in 2020 would reduce emissions of NOx by around 150g and PM10 by around 14g. In total in 2020 this would translate to a reduction in NOx of between around 0g and 150g and in PM10 of between 0 and 14g.

The benefits per avoided collision attributable to the scheme are expected to be smaller in later years as the vehicle parc gets cleaner such that the benefit diminishes over time.

Assessment results for this IIA Objective:

Duration of Impact Scale of Impact

Positive short-term Minor +

EA Topic: Climate change mitigation

IIA Objective 2: To reduce CO2 emissions and contribute to the mitigation of climate change

The assessment focused on the impacts associated with the reduction in CO2 emissions as a result of the reduced congestion and diversion from collisions avoided and has been informed by the findings of the CIA report that can be found in Appendix E of this IIA report.

Baseline

The effect on traffic flow on routes around a collision between an HGV and a VRU was studied for a small sample of 21 collisions where traffic data was available. The duration of disruption on the affected and surrounding roads was measured and Defra’s emissions factors toolkit was used to calculate additional emissions as a consequence of both start stop traffic and diversion around the incident.



In 2020 the analysis suggested a reduction per collision avoided of around 121kg CO2 for a total reduction in 2020 of between around 0 and 121kg.





HIA Topic: Health and well-being

IIA Objective 9: To contribute to enhanced health and wellbeing for all within London

The assessment focused on:

Reduced fatalities and injuries as a result of the scheme;

Monetised value of increased physical activity due to changes in cyclist demand as a result of the scheme;


Baseline Assessment

The non-mandated Standard is not expected to have a significant impact on cyclists unless businesses opt to switch to higher-rated vehicles when replacing older vehicles. Businesses are most likely to take the Standard into account for purchasing decisions, and depending on whether there is a cost premium of higher-rated vehicles, the number of the Standard-compliant vehicles is expected to grow. However, whether the Standard would encourage more cycle trips is uncertain due to the non-mandate, and cyclists may not be convinced the road is safer unless the Government intervenes.

Non-Quantified Benefits

Pedestrians

Studies have shown that although safety perception (fear of collision) of travelling is one of the main factors taken into consideration by cyclists, the same magnitude of consideration is less for pedestrians. There is little evidence to show that a road safety scheme such as DVS would have altered the perception of safety for pedestrians and therefore, would induce a significant number of pedestrians to quantify.



EqIA Topic: Population and Equality


Uncertain in the short to long-term

Uncertain?


IIA Objective 7: To reduce the number of casualties from protected groups as a result of HGV related accidents

IIA Objective 8: To advance equality of opportunity or small and medium enterprise owned by protected and disadvantaged groups.


Reduction in casualty rates of protected groups and disadvantaged communities from HGV related accidents

Improvement in the perception of safety for cyclists leading to an increase in active travel

Disproportionate impacts of the scheme costs for Small and Medium Enterprises and specific sectors

Baseline

Data from 2011 to 2015 as provided by TRL indicates that more than 300 road users were involved with a collision with HGVs during this period. 60% of these were male and 40% were female. More than 50% of the casualties were between the ages of 21 and 45. Those above 65 (i.e. Older Londoners) accounted for 20% of the casualties and those under 25 (i.e. Younger Londoners) accounted for 23% of the casualties. These two groups account for approximately 40% of the casualties. 51% of the casualties were Pedal Cyclist followed by Pedestrians at 26% and Motorcyclist at 24%.

It should also be noted that Londoners in lower household income brackets tend to be less engaged with cycling as a mode of transport. Londoners with low incomes are most likely to use the bus as a key mode of transport. BAME and white Londoners have similar walking frequencies with over 90% walking at least once a week. No other data sets on the other protected groups are available.


This Option involves using the Standard to inform purchasing decision but it will not be mandated and no restrictions will be put in place.

This is unlikely to have any positive effect in the short term for any of the protected groups as the zero star rated HGVs will likely remain in service until it is due for renewal which could be a few years later. The scheme may encourage the purchase of safer vehicles when the fleet is due for renewal but does not completely remove unsafe zero star HGVs from the roads. Therefore, any benefits are likely to be minor and realised only in the medium to long term.



medium to long-term

Minor +


CSIA Topic: Road Safety

IIA Objective 5: To contribute to safety and security and the perceptions of safety

The assessment focused on the potential impacts associated with the reduction of the number of collision casualties and has been informed by the findings of the CIA report that can be found in Appendix E of this IIA report.

Baseline


Baseline data was a forecast of the number of collisions recorded in Stats 19 as occurring in London and involving an HGV>7.5t and a VRU where the HGV was turning left or moving off from rest. Consideration of under-reporting, mis-coding of vehicles and the recording of a blind spot was considered within a range. Forecasts for ‘do nothing’ were based on constant casualty risk and DfT forecast changes in London HGV traffic as a measure of exposure to risk.


A reduction of the number of casualties from road traffic collisions (cumulatively, 2-9 fatal; 1-9 serious and 3 to 36 slight by 2030);

The benefits would be likely to accrue disproportionately to elderly pedestrians and younger cyclists. These may represent protected groups and disadvantaged communities.

The same low base numbers and minimum voluntary actions constrain the total benefit of this option.

In the medium term, this will have a minor positive impact on perception of safety.




CSIA Topic: Connectivity

IIA Objective 6: To contribute to the avoidance, elimination or reduction of road congestion or other disruption of the movement of traffic

The assessment focused on the reduction in the total delay in monetary values and has been informed by the findings of the CIA report that can be found in Appendix E of this IIA report.

Baseline data

The effect on traffic flow on routes around a collision between an HGV and a VRU was studied for a small sample of 21 collisions where traffic data was available. The duration of delay as a consequence of reduced speed and/or diversion was quantified and valued.


The analysis suggested an average total delay associated with collisions of 22 hours. This can be considered, for example, in terms of a few minutes delay for many drivers or a more significant delay for a few drivers. This has been assumed to remain constant over time such that the total benefit in 2020 for example would be between around 0 and 22 hours.




Assessment of Impacts



EBIA Topic: Economic competitiveness and employment

IIA objective 3: Provide high quality environment will help to attract and retain internationally mobile businesses

The assessment has focused on the analysis of the increased costs of doing business in London due to a requirement to replace non-compliant vehicles and has been informed by the findings of the CBIA report that can be found in Appendix D of this IIA report.

Baseline assessment

The baseline scenario assessed against all options is the “Do Minimum” scenario, whereby the Standard ratings are used to inform purchasing decisions, but compliance with the Standard is not mandated. The Do Minimum does not require intervention from TfL or the Local Authorities, therefore no cost is incurred by the public sector. Additionally, businesses are not required to adjust their fleet to meet the Standard, therefore no induced cost as a result of the scheme is incurred. No detrimental cost to the wider economy is expected, as well as employment and economic competitiveness as there is little evidence the presence of DVS would attract more businesses to operate in London.

Although businesses are not required to comply with the Standard, stakeholder engagement with key businesses showed strong evidence that businesses approve of the concept of the Standard and would be take the Standard into account for purchasing decisions. However, this is dependent on two factors:

Availability of highly rated vehicles on the market

Cost premium

If there is a limited supply of three star or above rated vehicles on the market, the price of the latter may increase as a result of demand surplus. Additionally, if there is a lower demand for lower-rated vehicles (0 star-2 star), the price of these vehicles may reduce on the market. In both cases, price conscious businesses do not have the incentive to purchase the higher-rated vehicles and may not switch to 3 star or above rated vehicles as a result of the cost premium.



Neutral short-term to long-term

Neutral 0

EBIA Topic: Small to Medium Sized Enterprises (SMEs)

IIA Objective 4: Encourage the development of new businesses in new and growth sectors

The assessment against this IIA Objective focused on significant increase in costs to operate HGVs for Small and Medium Enterprises and has been informed by the findings of the CBIA report that can be found in Appendix D of this IIA report.

Baseline assumptions


For “Do Minimum” Option is assumed that the natural replacement of vehicles will take place, whereby only old vehicles will be replaced by the three star rated vehicles in due course.

Baseline Assessment

The “Do Minimum” scenario would have little impact on SMEs; the non-mandate of the Standard does not impose a cost to SMEs and therefore does not detract or encourage any development of new businesses in all sectors. However, SME’s are less likely to take the Standard into account when purchasing/leasing new vehicles; SME’s do not have the capital or flexibility to adjust their fleet as quickly as larger, most established businesses and if the introduction of the Standard reduces the value of lower rated vehicles (0* to 2*), then SME’s are very likely to purchase/lease the latter. SME’s, like all businesses, do not have the required incentive to switch to a higher-rated vehicle, unless there is no cost reduction of lower rated vehicles and no cost premium is incurred for higher rated vehicles.



Neutral short-term to long-term

Neutral 0

Option 1 “Outright Restriction”






Baseline

The effect on traffic flow on routes around a collision between an HGV and a VRU was studied for a small sample of 21 collisions where traffic data was available. The duration of disruption on the affected and surrounding roads was measured and DEFRA’s emissions factors toolkit was used to calculate additional emissions as a consequence of both start stop traffic and diversion around the incident.


The sample suggested that on average each collision avoided in 2020 would reduce emissions of NOx by around 150g and PM10 by around 14g. In total in 2020 this would translate to a total reduction in NOx of between around 0.15kg and 1.2kg and in PM10 of between 14g and 112g. The benefits per avoided collision attributable to DVS are expected to be smaller in later years as the vehicle parc gets cleaner such that the benefit diminishes over time.






IIA Objective 2: To reduce CO2 emissions and contribute to the mitigation of climate change.


Baseline



In 2020 the analysis suggested a reduction per collision avoided of around 121kg CO2 for a total reduction in 2020 of between around 121 and 968kg.



Positive short-term to long-term

Minor +



IIA Objective 9: To contribute to enhanced health and wellbeing for all within London.


Reduced fatalities and injuries as a result of the scheme (See section on CSIA).

Monetised value of increased physical activity due to changes in cyclist demand as a result of the scheme.

Increase in active travel due to improvements in perceptions of road safety.


Reduced fatalities

Option 1 would likely prevent a total of 8-16 fatalities and 4-14 serious injuries by 2030, at a value of £7m-£40m as estimated in CIA and assessed in the previous CSIA.

Cycling


Cycling health benefits are expected as a result of the scheme as the ban on the most dangerous HGVs are likely to improve the safety perception of the roads for cyclists. A recent survey14 conducted by TfL have shown among the number of deterrents to increased cycling, 44% of respondents (September 2016) picked the “fear of being involved in a collision”, the most common deterrent to cycling more. Similarly, 55% of respondents (September 2016) picked the same deterrent to taking up cycling. An assumption (verified by TfL) that of the 85% of the growth estimated by 2031, 14% of the 85% would be attributed to improved safety perception, and of the 14% increase, 10% is attributed to the scheme itself. This assumption is applied for the Option 1.

Table 7.1 presents the induced number of cyclists estimated by 2031 as a result of the enforcement of each option.

Table 7.1: Induced cycle demand as a result of the scheme

Option No. of Cyclists (per year)

Option 1 53,770

The induced demand estimated was used as input to calculate the associated health benefits using the WHO’s HEAT tool. Table 7.2 presents the total value of the health benefits over the appraisal period (2017 prices).

Table 7.2: Total Health Benefits, £ 000s (2017 prices)

Option Health Benefits, £ 000s

Option 1 92,000

Creating a sense of a safer environment of banning the most dangerous HGVs would encourage more cyclists and/or existing cyclists to cycle more, improving the health of those impacted and well-being.


Pedestrians

Studies have shown that although safety perception (fear of collision) of travelling is one of the main factors taken into consideration by cyclists, the same magnitude of consideration is less for pedestrians. There is little evidence to show that a road safety scheme such as DVS would have altered the perception of safety for pedestrians and therefore, would induce a significant number of pedestrians to quantify. However, the scheme may encourage existing pedestrians to walk more or take longer trips, increasing active travel and subsequently inducing health benefits.



Positive long-term Moderate ++



14 Attitudes to Cycling, TfL, Autumn 2016


IIA Objective 7: To reduce the number of casualties from protected groups as a result of HGV related accidents



Reduction in casualty rates of protected groups and disadvantaged communities from HGV related accidents.

Improvement in the perception of safety for cyclists leading to an increase in active travel.

Disproportionate impacts of the DVS scheme costs for Small and Medium Enterprises and specific sectors.

Baseline




The restriction of zero star HGVs along with the requirement for all N3 HGVs to have a permit to enter London is expected to reduce the number of HGVs on the streets of London as soon as it is in effect. It is expected that this will reduce the number of casualties in the short to long term and have a major positive impact on vulnerable road users especially those with protected characteristics (i.e. the Younger and Older Londoners).

The ban on HGVs with less than three stars from the roads (by 2020) will also improve the perception of safety for vulnerable road users such as cyclists. This will have a disproportionate impact on women who are more likely to view risk of accidents as a barrier to using public transport. Overall, this will have major positive impact on perception of safety in the short to long term, especially when HGVs with less than three stars will be banned from the roads by 2024.




Major +++



IIA Objective 5: To contribute to safety, security, and the perceptions of safety

The assessment focused on the potential impacts associated with the reduction of the number of collision casualties has been informed by the findings of the CIA report that can be found in Appendix E of this IIA report.

Baseline


Baseline data was a forecast of the number of collisions recorded in Stats 19 as occurring in London and involving an HGV>7.5t 15and a VRU where the HGV was turning left or moving off from rest. Consideration of under-reporting, mis-coding of vehicles and the recording of a blind spot was considered within a range. Forecasts for ‘do nothing’ were based on constant casualty risk and DfT forecast changes in London HGV traffic as a measure of exposure to risk.

Effects of the DVS

A reduction of the number of casualties from road traffic collisions (8-16 fatal; 4-14 serious and 11 to 58 slight by 2030);

The benefits would be likely to accrue disproportionately to elderly pedestrians and younger cyclists. These may represent protected groups and disadvantaged communities

Although high profile and highly variable in number such that some years the numbers may be much higher than others, on average, the total number of collisions of this type that occur in London is relatively low and although Direct Vision is expected to be an effective counter measure it will not eliminate collisions, merely reduce their frequency. Also, as a minimum, the Standard will be used in existing best practice schemes such that some of the maximum benefit cannot be directly attributable to this option.





IIA Objective 6: To contribute to the avoidance, elimination or reduction of road congestion or other disruption of the movement of traffic


Baseline data

The effect on traffic flow on routes around a collision between an HGV and a VRU was studied for a small sample of 21 collisions where traffic data was available. The duration of delay as a consequence of reduced speed and/or diversion was quantified and valued.





15 Note that many different categorisation systems exist, for example, in type approval goods vehicles are classified as light below 3.5 tonnes and

heavy above 3.5 tonnes and there is an additional sub-division at 12 tonnes. For driver licensing purposes, any goods vehicle in excess of 3.5 tonnes is referred to as a Large Goods Vehicle or LGV. Many regulations refer to maximum authorised mass or maximum permitted mass. The categories chosen here are based on the definitions used in the stats 19 database,






IIA objective 3: To provide a high quality environment that will help to attract and retain internationally

mobile businesses.



The total cost to businesses for Option 1, whereby the biggest cost businesses are expected to incur are the

impact of withdrawing their non-compliant vehicles from operation, ranging from £8 billion to £31 billion.

The high estimate of vehicles expected to be non-compliant with the Standard forecasts a “knock on” effect on the economy as a whole, especially for the construction sector. As a result of this negative impact, a cost to the economy of the equivalent of the Construction Gross Value Added (GVA) for 2020 is accounted for in the “high” estimate cost of withdrawal as an indicative estimation of the impact on the wider economy. Additionally, non-quantified costs to businesses include the loss of business time as a result of certification and proving compliance of vehicles, the potential loss of residual value and the cost of switching manufacturers.



Negative short-term Major ---


IIA Objective 4: Encourage the development of new businesses in new and growth sectors

The assessment against this IIA Objective focused on the significant increase in costs to operate HGVs for Small and Medium Enterprises and has been informed by the findings of the CBIA report that can be found in Appendix D of this IIA report.


Option 1, would have the same impact described under objective 3, however the magnitude of the detrimental impact would be larger. SMEs are expected to have less financial flexibility to adjust their fleet to meet compliance, or the capital to replace their vehicles earlier and on what the sector may consider short notice (DVS ratings will be announced in 2018 and the scheme opens in 2020). The withdrawal of vehicles for SMEs would not only cost businesses their revenue, but may put them out of business altogether. The economic environment for SME’s and potential new business start-up would become less attractive.




Negative long-term Major ---

3.1 Option 5 HGV safe system scheme






Baseline data



The sample suggested that on average each collision avoided in 2020 would reduce emissions of NOx by around 150g and PM10 by around 14g. In total in 2020, this would translate to a reduction in NOx of between around 75g and 600g and in PM10 of between 7 and 56g.

The benefits per avoided collision attributable to the scheme are expected to be smaller in later years as the vehicle parc gets cleaner such that the benefit diminishes over time.





IIA Objective 2: To reduce CO2 emissions and contribute to the mitigation of climate change


Baseline




In 2020, the analysis suggested a reduction per collision avoided of around 121kg CO2 for a total reduction in 2020 of between around 60 and 484kg.






IIA Objective 9: To contribute to enhanced health and wellbeing for all within London.


Reduced fatalities and injuries as a result of the scheme (see CSIA section);

Monetised value of increased physical activity due to changes in cyclist demand as a result of the scheme;


Effects of the DVS

Reduced fatalities

Option 5 would prevent 3-15 fatalities and 2-15 serious injuries by 2030 at a value of £7m to £40m as estimated

in CIA and assessed in the previous CSIA Section.

Cycling

Cycling health benefits are expected as a result of the scheme as the ban on the most dangerous HGVs are likely to improve the safety perception of the roads for cyclists. A recent survey16 conducted by TfL have shown among the number of deterrents to increased cycling, 44% of respondents (September 2016) picked the “fear of being involved in a collision”, the most common deterrent to cycling more. Similarly, 55% of respondents (September 2016) picked the same deterrent to taking up cycling. An assumption (verified by TfL) that of the 85% of the growth estimated by 2031, 14% of the 85% would be attributed to improved safety perception, and of the 14% increase, 10% is attributed to the DVS scheme itself. This assumption is applied for the Option 1. However, the full benefit realisation of Option 5 is assumed to take longer than Option 5 as HGVs are not required to switch to three stars if non-compliant with immediate effect.

Table 7.3 presents the induced number of cyclists estimated by 2031 as a result of the enforcement of each option.

16 Attitudes to Cycling, TfL, Autumn 2016


Table 7.3: Induced cycle demand as a result of the scheme

No. of Cyclists (per year)

Option 5 42,451

The induced demand estimated was used as input to calculate the associated health benefits using the WHO’s HEAT tool. Table 7.4 presents the total value of the health benefits over the appraisal period (2017 prices).

Table7.4: Total Health Benefits, £ 000s (2017 prices)

Option Health Benefits, £ 000s

Option 5 73,000

Creating a sense of a safer environment of banning the most dangerous HGVs would encourage more cyclists and/or existing cyclists to cycle more, improving the health of those impacted and well-being.


Pedestrians

Studies have shown that although safety perception (fear of collision) of travelling is one of the main factors taken into consideration by cyclists, the same magnitude of consideration is less for pedestrians. There is little evidence to show that a road safety scheme such as DVS would have altered the perception of safety for pedestrians and therefore, would induce a significant number of pedestrians to quantify. However, the scheme may encourage existing pedestrians to walk more or take longer trips, increasing active travel and subsequently inducing health benefits.



Positive long-term Moderate ++



IIA Objective 7: To reduce the number of casualties from protected groups as a result of HGV related accidents.



Reduction in casualty rates of protected groups and disadvantaged communities from HGV related accidents.

Improvement in the perception of safety for cyclists leading to an increase in active travel.


Disproportionate impacts of the DVS scheme costs for Small and Medium Enterprises and specific sectors.

Baseline




The restriction of zero star HGVs along with the requirement for all N3 HGVs to have a permit to enter London is expected to reduce the number of HGVs on the streets of London as soon as it is in effect. It is expected that this will reduce the number of casualties in the short to long term and have a major positive impact on vulnerable road users especially those with protected characteristics (i.e. the Younger and Older Londoners).

The ban on HGVs with less than three stars from the roads (by 2020) will also improve the perception of safety for vulnerable road users such as cyclists. This will have a disproportionate impact on women who are more likely to view risk of accidents as a barrier to using public transport. Overall this will have major positive impact on perception of safety in the short to long term, especially when HGVs with less than three stars will be banned from the roads by 2024.




Major +++



IIA Objective 5: To contribute to safety, security, and the perceptions of safety

The assessment focused on the potential impacts associated with the reduction of the number of collision casualties and has been informed by the findings of the CIA report that can be found in Appendix E of this IIA report.

Baseline data

Baseline data was a forecast of the number of collisions recorded in Stats 19 as occurring in London and involving an HGV>7.5t and a VRU where the HGV was turning left or moving off from rest. Consideration of under-reporting, mis-coding of vehicles and the recording of a blind spot was considered within a range. Forecasts for ‘do nothing’ were based on constant casualty risk and DfT forecast changes in London HGV traffic as a measure of exposure to risk.



A reduction of the number of casualties from road traffic collisions (cumulatively, 3-15 fatal; 2-15 serious and 5 to slight by 2030);

The benefits would be likely to accrue disproportionately to elderly pedestrians and younger cyclists. These may represent protected groups and disadvantaged communities.

The same low base numbers and minimum voluntary actions constrain the total benefit of this option.





IIA Objective 6: To contribute to the avoidance, elimination or reduction of road congestion or other disruption of the movement of traffic.


Baseline data

The effect on traffic flow on routes around a collision between an HGV and a VRU was studied for a small sample of 21 collisions where traffic data was available. Instance the duration of delay as a consequence of reduced speed and/or diversion was quantified and valued.










IIA objective 3: To provide a high quality environment that will help to attract and retain internationally

mobile businesses.


Effects of the DVS

The total cost to businesses for Option 5, whereby the biggest cost businesses are expected to incur is the cost of retrofitting the non-compliant vehicles with additional safety mitigation measures, ranging from £381m to £403m. Some of these costs may be transferred as revenue to other sectors in the economy. No vehicles are forecasted to be replaced earlier than planned or withdrawn from operating in London. Other non-quantified cost to businesses include the loss of business time a result of certification and proving compliance of vehicles, as well the annual safety assessment of non-compliant vehicles opting to retrofit with extra safety equipment. The Option 5 has been assessed to have a minor negative effect against this IIA objective.



Negative short-term Minor -


IIA Objective 4: Encourage the development of new businesses in new and growth sectors.

The assessment against this IIA Objective focused on significant increase in costs to operate HGVs for Small and Medium Enterprises and has been informed by the findings of the CBIA report that can be found in Appendix D of this IIA report.


Option 5 would have the same impact described under Objective 3, however, for SME’s the cost of retrofitting vehicles with safety equipment and the downtime costs of the accompanying annual safety tests would be relative larger when compared to the size of their operations. The economic environment for SME’s and potential new business start-up would become less attractive.



Negative short-term Minor -

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