Summary of Responses to Consultation

From 8 March 2010 until 30 June 2010, the Department for Transport (DfT) ran a consultation on options for increasing the uptake of eco-driving training for drivers of Large Goods Vehicles (LGVs) and Passenger Carrying Vehicles (PCVs). The consultation document is available at: http://www.dft.gov.uk/consultations/closed/2010-11/

Consultation Options
The consultation considered three options to achieve a 90 per cent uptake of eco-driving training for LGV drivers. These were: Option 1: No change. This is the baseline against which other options are assessed. Under this option, eco-driving training would continue to be undertaken on a voluntary basis, and the commercial pressure to reduce fuel costs would be the primary driver for change. Option 2: A non-regulatory approach: maintain current regulations but increase levels of uptake through promotion of the benefits of eco-driving training, led by industry or Government. Option 3: Regulatory change: This option proposed that eco-driving training become a mandatory part of Driver Certificate of Professional Competence periodic training.

Responses Received
46 responses to the consultation were received. The respondents fell into the following categories:
Trade Associations (Freight, passenger transport, training etc). Training Accreditors and Providers Hauliers Local Authorities and Local Authority Groups Bus Operators (including coaches) Consultants Safety Groups Vehicle Manufacturers Traffic Commissioners (Senior and Scottish) Environmental organisations Individual Drivers Office of Rail Regulation The Scottish Government Trade Unions (Freight/Passenger Transport) 9 9 7 4 3 3 2 2 2 1 1 1 1 1

Consultation Questions The consultation consisted of 25 questions. These questions were organised into the following chapters, and summaries of the responses to them are found at the pages listed.
Questions 13 45 68 9 15 16 18 19 24 25 Chapters Definition of Eco-Driving Training Option 1: No Change Option 2: Increased Promotion of the Benefits Option 3: Driver CPC General Impact Assessment Consultation Criteria Chapter Eight Department for Transport Conclusions and Statement of Intent Pages 3 6 8 10 15 17 20 21

Chapter One Definition of Eco-Driving Training

The definition of eco-driving training proposed in the consultation document was: training that includes some or all of the following elements: o o o o o how to improve aerodynamic performance; how to drive at efficient speeds; fuel efficiency and choice of gear; best practice for acceleration and braking; and anticipation of traffic and driving conditions.

1. Do you agree with the proposed definition of eco-driving training and, if not, why not? What changes do you propose? Is there anything else that should be included in the definition? Around a third of those who responded agreed with the proposed definition. Of those who did not agree with the definition or did so only in part, many (including freight and bus trade associations and safety groups) expressed reservations about the element how to improve aerodynamic performance. It was said that such measures are often outside the control of drivers, and are instead the responsibility of those managing fleets. Some respondents disagreed with the definition on the grounds that it did not sufficiently reflect the importance of driver management in sustaining and implementing good eco-driving practice, and this was felt to be a critical element of eco-driving training. A number of respondents suggested further elements for inclusion in the definition of eco-driving training. Many felt that a specific safety element was crucial; others mentioned the importance of training on tyre maintenance, vehicle loading and the use of cruise control. The benefits of practical, on-thejob training were also raised. A number of trade associations cautioned that, whilst a definition of ecodriving training would be critical if Government were to mandate eco-driving training as part of the Driver CPC, being too specific could reduce the flexibility of operators to tailor training requirements to individual driver needs. 2. How important a role do you think management of driver behaviour has in maintaining eco-driving training benefits and reducing carbon emissions more generally? Nearly all respondents said that management of driver behaviour plays an important role in maintaining the benefits of eco-driving training, many highlighting concerns about drivers reverting to type once training sessions are completed. Respondents also emphasised that management of driver behaviour is critical for establishing a fuel efficient culture within a business. A number of respondents also mentioned the value of telematics technology for managing driver behaviour. 3

A few respondents suggested that the Transport Managers CPC should contain elements designed to promote the benefits of eco-driving training. Department for Transport Comment Transport Managers CPC The Transport Managers CPC is an exam-based qualification required by individuals who have responsibility for LGV and PCV vehicles operated for hire or reward. The minimum CPC knowledge required of transport managers is set out in EU Directive 96/26/EC. This Directive will be replaced in December 2011 by EU Regulation 1071/2009, which came into force in late 2009 and will apply from December 2011. Since this EU Regulation is already in force, another EC Regulation would be needed if it was to be amended. 3. What can Government and non-Government organisations do to promote the improved management of driver behaviour? The majority of those responding said that Government support for any promotional initiative was needed at some level from setting a clear and stable policy on eco-driving training through to financial incentives for good driving practice. A number said that a public awareness campaign, perhaps with the Department for Transport acting in partnership with relevant trade associations and public bodies to promote a consistent message, would prove effective in promoting improved management of driver behaviour. Other ideas included Department for Transport endorsement of industry-led carbon reduction schemes believing this would encourage higher levels of take-up of such schemes. A few respondents said that Government should encourage good practice through financial incentives, for example through enhanced Bus Service Operators' Grants for PCV drivers, funding for smaller operators to undertake eco-driving training or fiscal incentives. Only two respondents said that promotional activity would not prove effective, stating that the benefits of eco-driving are already well understood. Some respondents also highlighted the importance of better management of the road network, including modification of road lay-out to help reduce congestion-related carbon emissions. Specific suggested measures included implementing control measures to ease traffic flows and reduce congestion; better motorway demand management schemes; and greater investment in public transport schemes, including Park and Ride, to reduce private car dependency.

Department for Transport Comment Road Management as an Emissions-Lowering Strategy There are a range of street and junction design techniques that help and encourage people to accelerate and brake more gently, and so drive safely, efficiently and comfortably. The Department for Transport already produces comprehensive advice on those techniques for highways professionals. Local highway authorities have a statutory duty, under the Traffic Management Act 2004, to facilitate the journeys of road users on their road networks, and we think the adoption of smarter street and junction designs is an excellent way to deliver this duty. It is, though, for individual local authorities to decide on their local priorities and programmes. There is nothing to stop drivers in any urban street from accelerating and decelerating gently and efficiently, if they wish to problems arise not from the design of infrastructure, but from the habits and expectations of road users. Advanced street design techniques work, in the same way as ecodriving techniques, by influencing those habits and expectations.

Chapter Two Option 1: No Change

4. To what extent do you believe eco-driving training is currently being undertaken and to what extent does this vary across small, medium and large firms? Please justify your answer, explaining why you believe this is the case.

Responses to this question suggest that the extent to which eco-driving training is currently being undertaken across the sector is not generally known. The Freight Transport Association conducted a survey of business opinion within the logistics sector, based on a sample of around 120 companies who together operate over 45,000 LGVs and 53,000 vans. The responses indicated that: o 71% of operators had not put any drivers through eco-driving training before the start of Driver CPC (Sep 2009). o 60% have not put any drivers through eco-driving training since the start of Driver CPC. o 79% of operators do intend to put drivers through eco-driving training by the end of the first cycle of Driver CPC in 2014. Many respondents expressed the view that smaller firms are investing in ecodriving to a lesser degree than larger firms, with a number of training provider explaining that no small operators had requested or undertaking eco-driving training, despite this being a core offering in their sales portfolios. The reason for this was generally believed to be because drivers with smaller firms tend not to be eco-driving trained because the firm does not normally pay for their CPC training. Drivers choose not to take eco-driving training because they do not directly gain from the resulting financial benefits. Larger firms, who have the resources to pay for driver training, will direct drivers to eco-driving training because doing so results in a direct financial benefit to the company. 5. To what extent do you believe that the rate of eco-driving training uptake will increase across small, medium and large firms in the future without additional action being taken by Government? Please justify your answer, explaining why you believe this is the case. The majority of respondents to this question predicted that the rate of ecodriving training would increase either not at all or by an insignificant extent without additional Government action (in the form of financial incentives or regulation). Respondents from the bus and coach industry and a few freight trade associations, however, predicted that there would be a significant increase in the uptake of eco-driving training without further Government action. This predicted increase was either attributed to commercial pressure, perhaps resulting from rising fuel prices, or to smaller operators moving from courses providing basic regulatory compliance to eco-driving courses with longer-term benefits. 6

Department for Transport Comment Current levels of uptake as part of Driver CPC Recent figures from the Driving Standards Agency database of CPC training courses show that 8% of courses undertaken by LGV drivers have been ecodriving in nature. Assuming a constant uptake rate of 8% a year, this suggests that we can expect around 40% of drivers to have taken an eco-driving course by the end of the first period of CPC. This figure is used as a new baseline in the updated Impact Assessment.

Chapter Three Option 2: Non-regulatory approach involving measures to increase promotion of the benefits (led by industry or Government)
6. If Option 2 is pursued, what promotional strategies do you suggest Government should consider, with particular focus on strategies aiming to reach smaller firms? The majority of respondents believed that promotional strategies were important. Many felt that such activities should focus on the business case for ecodriving training, with a few suggesting the use of case studies. A number of respondents, particularly those from the bus and coach industry, stated that any promotion should be conducted with the close involvement of trade associations. Some respondents highlighted again their belief that financial incentives were needed, particularly those targeted at smaller operators. One respondent suggested that the incentive need not be provided by Government but could, for example, be offered by insurance companies. 7. If Option 2 is pursued, what role do you think voluntary industry action, alone or in partnership with Government, should play in promoting the benefits? A number of the ideas previously put forward in response to questions 5 and 6 were re-iterated in response to this question, including the key role of trade associations in promoting voluntary industry action. Additional suggestions included the publicisation by industry of examples of good practice, or the promotion of eco-driving training through marketing of products such as telematics equipment. It was noted that promotional activities had the advantage of potential for knock-on benefits in other areas of businesses, encouraging eco-driver training to also be used across a businesss van and company car fleets. A few respondents again re-iterated that voluntary industry action of the required level is unlikely without some level of Government support or backing. Doubts about voluntary industry action were largely attributed to slim profit margins concentrating management attention on day-to-day operations rather than on investing in training for long-term savings. This scenario was judged to be particularly prevalent for smaller operators. 8. To what extent do you think elements of Option 2 would be required should Option 3 be the accepted approach? Around a third of those responding said that either all or a significant proportion of or promotional activity would be required if Option 3 noting that such activities would be likely to shift from promoting the benefits of eco-driver training towards compliance with the Driver CPC, including clarifying the link 8

between eco-driver training and the Driver CPC. Within this context, measures targeted at smaller operators were judged to be particularly important. A few respondents felt that only a basic or significantly reduced level of promotional activity would be required if Option 3 was the accepted approach.

Chapter Four Option 3: Driver CPC

9. Do you agree that eco-safe driving training should be included as an eligible substitute for eco-driving training and, if not, why not? The majority of respondents agreed that eco-safe driving training should be included as an eligible substitute for eco-driving training, providing two broad reasons for this: the fundamental similarities between eco-driving and safe driving; and the significant environmental and social impacts of road accidents, ranging from serious road congestion following an accident to waste of resources resulting from damaged vehicles and infrastructure, and therefore a critical need to maintain safety of drivers and passengers. 10. Do you agree with the inclusion and/or substance of the recommended structure proposed in relation to eco-driving training and, if not, why not? The proposed structure of the eco-driving training was: Training that would: a) apply equally to LGV and PCV drivers; b) consist of practical and in-vehicle training, with theoretical training a subset of the practical training; c) include the following features: improved aerodynamic performance; efficient speeds; choice of gear; acceleration and braking; and anticipation of traffic and driving conditions; d) consist of seven hours and be undertaken in one training day; e) apply to periodic training only; f) be retaken each five year period; and g) be consistent with all other features of the Driver CPC regulations, including in relation to enforcement, exemptions and penalties. The majority of respondents generally agreed with the proposed structure of the eco-driving training course, although on-the-job training was considered by some to be an important, missing element. A number of respondents, however, disagreed, believing there should be greater scope for flexibility, saying that drivers (and companies) would benefit from training that can be tailored to driver and operational needs. A training trade association said that the requirement to retake the course every five years ignored technological developments that enable more effective management of drivers (for example, telematics technology).

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One freight trade association said that in-cab training added cost, and that good classroom training could be effective particularly if it allowed for peer pressure and discussion during the course. 11. If Option 3 is pursued, do you agree with the proposed elements that eco-driving training should consist of and, if not, why not? The recommended elements included the definition of eco-driving training, and the structure of the training. Additional elements to those already quoted in question 10 (above) are: a) The trainee receives theoretical training; b) The trainee is assessed on his/her driving abilities by the instructor; c) The trainee receives a debrief on his/her performance and driving style; d) The instructor delivers a demonstration drive tailored to the trainees training objectives; and, e) The trainee is given the opportunity to demonstrate the techniques learned, along the original assessment route with ongoing input and guidance from the instructor, where necessary. The majority of those responding generally agreed with the proposed elements, with the caveats that the points raised in their response to Question 1 (on the definition of eco-driving training) still stood, including concerns around inclusion of aerodynamic performance; and the importance of on-thejob training. Those who disagreed with the proposed elements of the eco-driving training course were largely those from the bus and coach industry, who emphasised that different skills were required for eco-driving in a PCV, and that these skills were not reflected in the proposed elements. The freight trade associations again highlighted their belief that training should not require a practical, in-vehicle driving element as this raises the costs of training to industry. Other respondents emphasised that the training course needed to be flexible enough to meet the requirements of operators and their circumstances. 12. If Option 3 is pursued, do you agree that eco-driving training should consist of seven hours and be undertaken in one training day and, if not, why not? Around a third of respondents (including a number of hauliers) agreed with the proposal that, if Option 3 is pursued, eco-driving training should consist of seven hours and be undertaken in one training day, or at least be compliant with the requirements of the Driver CPC Directive. Many respondents, however, disagreed with the proposal that eco-driving training should consist of seven hours and be undertaken in one training day. The majority of these (including all respondents from the bus and coach 11

industry as well as freight trade associations and representatives from the training industry), did so because they believed there should be an option to split the seven hour training session over more than one day. A few respondents noted that the CPC framework allows for training to be delivered in 2 x 3.5 hour sessions, with the second session commencing within twentyfour hours of the first, and that this should be allowed to continue if eco-driving training were to be made mandatory. Some respondents, however, said that releasing drivers for one day was more cost effective for the operator than releasing for two half-days. Department for Transport Comment Splitting the Driver CPC It is correct that, under the current Driver CPC framework, it is possible to split the Driver CPC. The EU Directive requires that Driver CPC training is taken in minimum blocks of seven hours. However, in the UK we have allowed a concession and agreed that where a course of seven hours is split into two parts the second part must start within twenty-four hours of the completion of the first part. 13. If Option 3 is pursued, do you agree that eco-driving training should only be mandated for periodic training, or should it be extended to the initial Driver CPC qualification? Around a third of respondents, including representatives from all sectors from which we received responses to the consultation, agreed that eco-driving training should be mandated for periodic training. It was expressed that the initial Driver CPC qualification already includes elements of eco-driving training, and that periodic training should be used to build on this through development of more in-depth skills. A few of respondents also said that to extend eco-driving training specifically to the initial Driver CPC qualification would create additional costs for industry. A further third of respondents, again including representatives from all sectors from which we received responses to the consultation, said that eco-driving training should be extended to the initial Driver CPC qualification. Respondents said that this would ensure that all new drivers are schooled in eco-driving principles, ensuring a quicker uptake of eco-driving training across the sector. A few respondents indicated that they were undecided. While they recognised the benefits of embedding a good practice in new drivers, they also recognised the benefits of flexible training for specific operational requirements. 14. If Option 3 is pursued, do you agree that eco-driving training should be mandated to include PCV drivers and, if not, why not? The majority of respondents (including a respondent from the bus and coach industry as well as a number of training organisations and hauliers) agreed that, if Option 3 were pursued, eco-driving training should be mandated to include PCV drivers. These respondents said that such a move would be necessary to ensure that training standards across the sectors are consistent.

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In general, respondents from the bus and coach industry, and one training organisation, disagreed that eco-driving training should be mandated to include PCV drivers. It was stated that the two industries had different needs and that mandating would lead to inappropriate one size fits all legislation. These respondents also felt that mandating would exclude a significant number of PCV vehicle operators in the community transport sector who operate under different legislation. A few respondents commented that the bus industry is responsible for less carbon emission than the haulage industry, and that there is therefore less of a need to operate in a fuel efficient manner. One respondent also queried what the link to or impact of mandating ecodriver training would be on the Bus Service Operators Grant. Department for Transport Comment Emissions from Buses In 2008, domestic transport emissions of CO2e emissions totalled 131.9 Mt. Of these, buses accounted for 4.9 MtCO2e, which is 3.7% of the total. In the same year, LGVs accounted for 23.8 MtCO2e, which is 18.0% of the total. These figures indicate that, as a total, domestic freight operations are responsible for a higher proportion of CO2 emissions than buses. However, comparing 1990 emissions figures with 2007 figures, bus emissions increased by 28%, while LGV emissions decreased by 0.4%. The most recent statistics suggest that both bus and LGV CO2 emissions have decreased since 2007. The Bus Service Operators Grant (BSOG) has been reformed such that, since 2008, the BSOG has not been up-rated in line with fuel duty changes. Instead, operators receive 3% above the basic rate where they deliver a fuel efficiency saving of at least 6%. Measures such as eco-driving can help improve an operators fuel efficiency and hence meet the 6% efficiency target. This can be achieved whether or not eco-driver training has been mandated. 15. If Option 3 is pursued, would you consider an enforced price cap on the amount charged for eco-driving training, or periodic training generally, to be appropriate and, if so, why? The majority of respondents, from each of sectors that responded to the consultation, said that an enforced price cap would not be appropriate, stating that this would restrict competition within the market and reduce the quality and value for money of training courses. A few respondents also commented that an enforced price cap for eco-driving training but not for other elements of the Driver CPC would create inconsistency. A few respondents, including some hauliers, were in favour of an enforced price cap if eco-driving was made mandatory, stating that this would prevent costs becoming an excessive burden, particularly for smaller operators.

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One respondent suggested monitoring the market and only regulating prices if necessary.

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Chapter Five General Questions

16. Which is your preferred option: Option 1 (baseline do nothing), Option 2 (increased promotional strategies), Option 3 (make ecodriving training a mandatory part of the driver CPC), or none of these options?

Option 1

Option 1 or 2

Option 2

1 Individual LGV driver 1 Trade association

2 Trade associations 1 Haulier 1 Bus operator

4 Trade associations 3 Training related organisations 2 Bus operators 1 Local government organisations 1 Haulier 1 Safety group 1 Trade union Total: 13

Option 2, perhaps followed by 3 2 Hauliers

Option 3

6 Training related organisations 3 Hauliers 2 Consultancies 2 Local government organisations 2 Trade associations 2 Vehicle manufacturers 1 Environment organisation 1 Safety group Total: 19

Total: 2

Total: 4

Total: 2

Those in favour of Option 3 said that this option would ensure 90% of LGV and PCV drivers receive eco-driving training, and that maximum carbon savings and benefits to industry (in the form of reduced fuel costs, improved road safety, reduced wear and tear) would be obtained. They also felt that this was the most effective way to ensure that small and medium sized operators receive eco-driver training. Those who preferred Option 2 said that Option 3 would remove the flexibility that operators need to target training to drivers and operations; and would thus create unnecessary additional financial and regulatory burdens. Two hauliers preferred Option 2, followed by Option 3 at a later date if uptake of eco-driver training does not rise sufficiently. These respondents suggested that Driving Standards Agency and the Joint Approvals Unit for Periodic Training report to Government on the uptake of courses being undertaken as part of the Driver CPC and, if levels remain low, consideration could be given to making eco-driving a mandatory part of the driver Certificate of Professional Competence for the 2014 2019 cycle. 17. If none of the options proposed in the consultation document is your preferred option, what alternative option(s) should we consider and, if so, why? Only a few respondents provided answers to this question, with suggestions for alternative options including: Use of carbon accreditation schemes to monitor and record outcomes, including potential for Government to set reward criteria for low carbon solutions. 15

Use of financial incentives to promote uptake of eco-driving training, including consideration of using fuel duty to support eco-driving training for small operators. Incentivisation of active management of drivers. Development of an effective classroom-based eco-driving solution to reduce the cost of training to industry.

18. Do any of these options have an impact on the competitiveness of UK industry and, if so, why? A quarter of respondents, in particular those from the bus and coach industry and the bus and freight industry trade associations, said that Option 3 would impact negatively on the competitiveness of UK industry. Concerns were expressed that it would create an imbalance with those EU countries that had not mandated eco-driving training as part of the Driver CPC. Bus and coach industry representatives also said it would create an imbalance between PCV drivers and Community Transport Operators, who act under different legislation. A further quarter of respondents, including a number of hauliers, training organisations and consultancies, said that Option 3 would impact positively on the competitiveness of UK industry. They said that it would make the UK haulage industry a global leader in fuel efficiency. They also said that the longer-term fuel and safety savings outweighed the short-term costs to industry. Other respondents said that none of the options were likely to impact on UK competitiveness.

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Chapter Six Impact Assessment

19. Do you agree with the draft Impact Assessment at Annex A and/or can you help us to quantify more precisely the estimated costs and benefits? Half of those responding disagreed with the draft Impact Assessment or elements of it, with key reasons being that the baseline figures and key underlying estimates provided for the PCV industry do not align with industry figures; that the cost of eco-driving training to industry is higher than stated; that the cost of upgrading the existing CPC IT system had not been taken into account; and, that the long-term benefits of eco-driving are lower than those estimated. One respondent said that no attempt had been made to estimate the impact of casual drivers, staff turnover (those entering and leaving the industry), drivers moving between companies (including those moving between freight and passenger transport), and the need to maintain records and ensure internal training compliance. Doubts were raised about the use of the National Transport Model as a tool for estimating distance travelled, saying that it included foreign operators and those exempt from driver CPC. Department for Transport Comment - Use of the National Transport Model The criticism of using the NTM figures for distance travelled has been accepted, and the figures in the updated Impact Assessment now exclude foreign drivers. The real-world benefits of eco-driving are a subject of a study that the DfT is undertaking, and emerging results from this study have been used in updating the impact assessment. This study so far shows that on average drivers achieve around 5% fuel reduction over the 6 months following training. However, we acknowledge there is significant uncertainty over this figure and how long the benefits persist for, so the updated Impact Assessment illustrates this large range of uncertainty. 20. Do you agree with the estimates provided for average distance driven and fuel used for LGV and PCV drivers? Please note that the estimates used are annual averages for drivers across all types of vehicles. Respondents from the bus and coach industry disagreed with the estimates for PCV drivers stating that their own estimates were lower than those stated in the draft Impact Assessment. One respondent said that averaged figures should be corrected for variations in vehicle size and fuel consumption, and another said that the estimates for full savings are higher than they would be in operation, since drivers of smaller vehicles on urban routes will do considerably less mileage. The driver population figure included was also queried, with one freight trade association stating that its own estimates were twice as high. 17

Department for Transport Comment Driver Population We have continued to use the ONS labour force survey as our main source for figures relating to the driver population, because this is the main labour survey in the UK. However, we acknowledge that this number may be an underestimate given the number of registered vehicles. Hence we have assessed how the analysis of the impacts would change with a larger number of drivers and included sensitivity analysis within the updated Impact Assessment. 21. Do you agree that eco-driving training has not been widely taken up by small firms in the past and/or can you help us to quantify the number of small firms that have undertaken eco-driving training? The majority of those responding agreed that eco-driving training has not been widely taken up by small firms in the past Those who disagreed tended to be from the bus and coach industry, with one training-related organisation drawing attention to the Joint Approvals Unit for Periodic Training as a source of information on eco-driving training uptake, saying that the evidence showed that bus operators are already delivering a significant volume of eco-driving training to drivers as part of the CPC programmes. 22. Does your organisation operate any driver management systems? What costs/benefits have resulted in driver management systems? The majority of operators responding to this question stated that they do operate driver management systems. A few stated that they do not operate driver management systems.

Other organisations, particularly training providers, expressed support for driver management systems, including telematics technologies, believing they played a key role in improving fuel efficiency. A training provider reported an example where clients had saved over 2m in 12 months owing to effective driver training and support mechanisms. 23. What impact do you think Option 2 would have on the uptake of eco-driving training? Is it feasible that additional promotion would attract small operators and we would reach our 90 per cent target if so, by when? Half of those responding to this question, from across a range of organisations, felt that Option 2 would have a positive impact on the uptake of eco-driving training (including among small operators). The other half believed Option 2 would not have a significant impact on the uptake of eco-driving training; with many believing this would be the case unless Government played some role or provided incentives. One respondent said that an uptake of 90% was unlikely in the short term but feasible in the long term. 18

24. Are there alternative approaches for smaller firms, which would not materially affect the potential benefits from the policy? Many of those responding to this question said that fiscal incentives for smaller firms would be important. A few training providers recommended encouraging larger companies to form a Service Level Agreement with smaller subcontractors, according to which they have to lower fuel consumption through eco-driving training.

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Chapter Seven Consultation Criteria

25. Do you consider this consultation has been conducted in accordance with the Code of Practice on Consultation (Annex C)? Most respondents said they thought the consultation had been conducted in accordance with the Code of Practice on Consultation. A few respondents said they thought the consultation had not been conducted in accordance with the Code of Practice on Consultation, expressing concerns that the expected costs and benefits and associated figures in the Impact Assessment were based on inaccurate figures. Department for Transport Comment Impact Assessment The Impact Assessment which accompanied the consultation was an initial stage assessment. As such there were significant uncertainties which were highlighted in the text, and the assessment only fully covered one option as the consultation sought to elicit further suggestions for non-regulatory measures. Any pursuit of Option 3, the regulatory option, would have been subject to a further consultation exercise with significantly updated estimates for costs and benefits reflecting respondents comments and emerging evidence from DfTs ongoing study into the long-term benefits of eco-driving. Option 2 within the original assessment was not fully analysed as the consultation sought to elicit suggestions for non-regulatory measures from respondents, and did not want to prescribe what these might be. However, the Department recognises that the analysis of Option 3 on its own did not allow respondents to compare the option against alternatives. An updated Impact Assessment has been prepared for this response and will be further improved to reflect the evidence of the DfT study. This updated Impact Assessment reflects the valuable comments given by respondents and has allowed the Department to develop its approach in this area.

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Chapter Eight Department for Transport Conclusions

Table of Responses Received

Option 1

Option 1 or 2

Option 2

1 Individual LGV driver 1 Trade association

2 Trade associations 1 Haulier 1 Bus operator

4 Trade associations 3 Training related organisations 2 Bus operators 1 Local government organisations 1 Haulier 1 Safety group 1 Trade union Total: 13

Option 2, perhaps followed by 3 2 Hauliers

Option 3

6 Training related organisations 3 Hauliers 2 Consultancies 2 Local government organisations 2 Trade associations 2 Vehicle manufacturers 1 Environment organisation 1 Safety group Total: 19

Total: 2

Total: 4

Total: 2

Statement of Intent
The Climate Change Act 2008 obliges the UK Government to reduce its greenhouse gas emissions by 34% on 1990 levels by 2020, and 80% by 2050. Under the Act carbon budgets have also been set, requiring the UK to reduce emissions by 22% in the first budget period (2008 2012), 28% in the second period (2013 17) and 34% in the third period (2018 2022). The Government recently announced its commitment to reduce the UK greenhouse gas emissions by 34% by 2020 in line with the climate change act and to push for higher ambition at EU level. Large Goods Vehicles are responsible for 18% of domestic transport greenhouse gas emissions; and preliminary estimates suggest that increasing the uptake of eco-driving training could save up to 3m tonnes of CO2 over a five year carbon budgetary period. Within this context, the majority of respondents to the consultation believed that Option 1 do nothing should not be the selected option following consultation. The Government has also made clear its commitment to reducing regulation on industry wherever appropriate to do so and to instead find ways to encourage, support and enable better choices. A significant number of respondents from the freight transport and bus and coach industry expressed concerns that the proposal within Option 3 - to make eco-driving training mandatory - would reduce the ability of industry to choose training tailored to their needs, and therefore stifle the opportunity to make better choices for their business. Some operators said that they preferred to target eco-driving training at particular drivers who needed the training, rather than the workforce as a whole. Others preferred to target training at managers, fostering a fuel-efficiency culture across the business. All felt that a centrally prescribed training course risked hampering initiatives of these kinds, and therefore the majority of the freight transport and bus and 21

coach industry were in favour of Option 2 a non regulatory approach to increasing uptake through measures to promote the benefits of eco-driving training, led by industry or Government Emerging results from the Departments SAFED longevity of benefits study support the view that proper management of drivers is likely to significantly increase the CO2 benefits of eco-driver training, and the subsequent maintenance of these benefits. Given industry preferences, the emerging evidence from this study, and the wider context of the Governments deregulation agenda, the Department has decided not to select Option 3 - making eco-driving training a mandatory part of the Driver CPC - at this time. We will instead respond to industry assurances that they have the will to increase uptake of eco-driving training without direct Government intervention. We will encourage and support industry-led initiatives to improve fuel efficiency and tackle carbon emissions, of which a number have emerged as a result of this consultation. Examples include trade association-led campaigns to promote the benefits of eco-driver training; working with businesses to promulgate current industry examples of fuel saving measures; carbon accreditation schemes or Government-set reward criteria for low carbon solutions; or, financial incentives to increase uptake of eco-driver training. The Department will do this by working with the freight transport industry and trade associations through the Departments Logistics Sounding Board and Low Carbon Transport Supply Chain Steering Group; and will also hold discussions with the bus industry on how we can best encourage and promote eco-driving training among drivers of Passenger Carrying Vehicles. In 2012 we will review the level of uptake of eco-driving training and fuel savings resulting both from these industry-led initiatives and from voluntary uptake as part of the Driver CPC and will re-consider the case for Government intervention.

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