In the north of Germany there is an impressive remnant of the Nazi regime, called the Colossus of Prora. It was intended to be a seaside resort for the working class. The building complex has a total length of 4.5km consisting of 5 blocks each with a length of 500m. It has the capacity to accommodate 20.000 people, but was never used as originally intended. In the times of the German Democratic Republic (GDR) the building was used by the military. For the current authorities it is a major challenge to find a purpose for development. The concrete Moloch is too expensive to demolish and too large for an appropriate use. However it can be considered as a monument. Nowadays cultural entrepreneurs and a youth hostel inhabit some parts of the building. Getting back to IFRTT newsletter tradition: I suppose that in the wooded area surrounding the Colossus of Prora, like in the rest of Europe, the first signs of autumn can be seen. It brings falling acorns and other forest fruits such as chestnuts.
Although not made of concrete, the sum of all EU-regulations for the design of trucks appears as a Colossus of Prora. Definitely arising from good intentions to improve safety, and fuel consumption and to create a level playing field, the complexity of the rules have become inflexible for adaptations. During the past decade the European Commission has attempted to develop a revision of the Directive 96/53 that regulates the weights and dimensions of trucks. Transport efficiency and the reduction of CO2 are the main drivers for this revision. However the debate is being held hostage by the fear of a modal shift from inland waterways and rail to road. In particular, the rail lobbyists are very active in attempting to prevent any modernization in truck design that could make road freight transport more competitive.
The most recent attempt of the European Commission to reopen the debate was in April this year. According to Erik Dahlberg at Scania, the proposal puts Europe at a crossroad of truck weights and dimensions and Performance-Based Standards (PBS).
In his words:
At first sight, the proposal appears to be very promising since it intends to introduce a form of PBS, giving manufacturers and hauliers a degree of freedom in designing and operating more efficient vehicle combinations. The main objective is fuel efficiency improvement. The flexibility introduced allows the introduction of aerodynamic features “outside the box”. The current Directive, dating back to the 1980’s, regulates totally “boxy” trucks, with cab over engine design. If properly implemented, the proposed changes will enable substantial reductions in fuel consumption and CO2 emissions.
A possible length extension of up to two meters for the vehicle combination is in discussion, divided between the (tractor) front end and the (semitrailer) rear end. The additional length may only be used for aerodynamic and safety purposes; no increase in the load capacity will be permitted. Vehicle manufacturers have calculated potential fuel savings of between 1 and 3 % by extending the cab front, making the vehicle more optimised with respect to air flow. The corresponding saving at the rear, by introducing flaps at the trailer end, constituting a so-called boat tail, is 5 to 6%.
The proposal, if properly implemented, will be a clear improvement in the existing legislation by allowing more flexibility in the design for improved aerodynamics. However, the purpose of aerodynamic improvements may be lost if the new, unclear demands for increased safety, a regulatory area for which standards already exist in the type approval Directives, are implemented. Flexibility may also be reduced if the proposed new certification for aerodynamics improvements is introduced, since it is a complex area that is not well suited for regulations. In real life, there is no clear relation between a more aerodynamic cab and a more aerodynamic vehicle; the complete vehicle, including body and trailer and its operation, must be understood. In addition, the proposal requires a relative rather than absolute comparison for these requirements, which complicates the procedure further. PBS as well as any type approval requirement needs to be stated in absolute terms in order to be legally secure.
Moreover, the proposal adds requirements on national type approvals, unexpected in a Directive that is intended to set the demands on the use of already type-approved vehicles. Once adopted it also adds far-reaching possibilities for the European Commission to make derogations on the technical demands without political approval, i.e. no formal legislative procedure for timeline and stakeholder consultation for changes to the PBS in the future.
If these proposed demands reach the final directive, the benefits of the revision would unfortunately be overshadowed by new, duplicating and unclear administrative requirements, meaning simply that nothing will be left for the manufacturers or the hauliers to reach for. The costs will be far higher than the advantages from reduced aerodynamic drag and the uncertainties for derogations will make investments in the cab structure uneconomical. Design changes may thus never become reality.
Europe is at a crossroad in this matter: If the revised Directive supports the development of the truck of the future, it will pave the way for continued fair competition between vehicle manufacturers regarding fuel efficiency. The correct way for Europe is therefore to remove the current cab and vehicle combination length restrictions, without necessarily allowing for increased loading capacity, thereby providing freedom to the manufacturers in developing the most beneficial, fuel efficient, design for all stakeholders. In addition, the EU turning circle requirement should apply, relating to the safe use of the vehicle and the interaction with the infrastructure. The removed length restriction will thereby be utilised to improvements in vehicle aerodynamics. This would be the right PBS approach for Europe, all existing requirements, such as under-run protection, lighting, indirect field of vision and the turning circle, combined with the freedom to optimise the design without the constraints of the “box” in the current directive.
While Europe took the road of fixed maximums for weights and dimensions, PBS appears to be more elegant and flexible. There are several questions that can be posed regarding both systems. Is there a risk within PBS for becoming a Colossus of Prora? Is there a future, at least to a certain degree, for a PBS approach being integrated in the EU-regulations for trucks? These will be interesting issues to discuss at the next HVTT Conference in San Luis, Argentina in 2014. The theme fits well: expanding horizons.
Loes Aarts, IFRTT Vice-President: Europe, and
Erik Dahlberg, Head of Vehicle Regulations at Scania.
Met vriendelijke groet,
Senior adviseur, Programma Goederenvervoer over de Weg