Summary Report - Assessment of a Heavy Truck Speed Limiter Requirement in Canada

TP14808 E

Executive Summary

Rationale

In late 2005, the Canadian Trucking Alliance (CTA) called on the federal and provincial governments to mandate the activation of speed limiters on all heavy trucks traveling into or within Canada at no more than 105 kilometres per hour (kph).

At their September 2006 meeting, the Council of Deputy Ministers Responsible for Transportation and Highway Safety (CODMT) reviewed a Discussion Paper on Speed Limiters For Trucks Operating in Canada that contained preliminary environmental and truck safety benefits of a speed limiter mandate. However, it was also noted that further analysis concerning the national implications of such a mandate was necessary. Deputy Ministers and subsequently Ministers discussed the issue and agreed to work together to assess outstanding issues. Transport Canada (TC) offered to lead this effort with assistance from several of the provinces and territories.

The issue of a speed limiter mandate within the Canadian context is complex and a thorough and impartial assessment of the potential implications of such a requirement in the Canadian context, particularly relating to highway safety and economic impacts, had never been undertaken. It is noteworthy that based on TC's examination, this is the first time that such a holistic, multi-dimensional review of the potential national implications of a speed limiter mandate has ever been conducted in Canada or elsewhere in the world.

With the assistance of a federal-provincial steering committee, TC commissioned a number of studies and assessments in 2007 to review the implications of a national speed limiter requirement from a safety, environmental, economic and operational perspective. This report, containing a synthesis of the key results from these studies and assessments, is intended to inform Canadian provincial and territorial governments on key aspects concerning speed limiters for heavy trucks.

The analysis completed is timely, as two Canadian provinces (Ontario and Quebec) have passed speed limiter legislation. There is also a petition before the U.S. government by the American Trucking Associations for a national speed limiter mandate. The studies and assessments, summarized below, examined the potential highway safety impacts of speed limiters through traffic modeling, the trade and competitiveness impacts, the environmental benefits via fuel savings and greenhouse gas reduction, the experience of speed-limited carriers through a case study, the experience of other countries with speed limiter legislation and technical considerations.

Overview of Speed Limiter Usage

Prior to summarizing results from the studies and assessments, the following section provides an overview of heavy truck speed limiter usage in North America.

Speed limiters electronically limit the maximum attainable road speed and have been standard equipment on the majority of heavy trucks built since mid-1990.

Hence, these trucks come enabled with the requisite hardware that the truck purchaser is free to activate or not. The activation of speed limiters through the truck's electronic control module (ECM) is relatively simple but requires manufacturer's software and is password-protected.

A common theme emanating from this work is that speed limiters are already heavily integrated into the Canadian and U.S. trucking industry. For many fleets, it is just “good business” to activate speed limiters in most, if not all, of their trucks. The larger the fleet, the greater the likelihood that speed limiters will be activated. Some fleet operators also require owner-operators (sub-contracted truckers) to activate their speed limiters, or if not, they must follow their corporate speed policy. Although smaller fleets are less likely to activate speed limiters, most operators follow a speed policy to reduce fuel costs.

It is estimated that at least 60% of heavy truck fleets in North America use speed limiters. As larger fleets are more likely to be speed limited, the percentage of trucks that are speed limited is higher at an estimated 77%. While speed limiter settings within Canada are in the 100-112 kilometer per hour (kph) range, settings on U.S. fleets may be somewhat higher to account for some higher state speed limits. The average setting across Canadian and U.S. fleets was found to be 105 kph. Main reasons cited for using speed limiters include reducing the top speed of the vehicle, reducing crash risk and increasing fuel economy. The main reasons for not using speed limiters are car-truck speed differentials, inability of the vehicle to pass, and refusal by non-company drivers to comply.

Safety Implications of Mandating Speed Limiters

This study assessed the safety implications of mandating speed limiters through a traffic simulation model that estimates crash potential and how this may be impacted by different road and traffic conditions.

Several highway scenarios are modeled in this study: freeway off-ramps segments, freeway on-ramps segments, combined on-off ramp segments, and straight freeway segments. A case study of a straight Canadian freeway section along the Queensway Express Way (QEW) in the Greater Toronto Area was also performed. Each scenario is modeled using experimental traffic characteristics such as: varying traffic volumes and truck ratios in the traffic stream; speed limiter compliance rates, and; several maximum speed limiter settings.

The relevant traffic scenarios considered in this study are:

  • High (2000 vehicles per hour per lane) and low (500 vehicles per hour per lane) freeway volumes
  • High (15) and low (2.5) percentage trucks in traffic stream
  • Mandatory truck speed limiter compliance rates (75%, 100%)
  • Non-mandated speed limiter application (35% of truck population set at 105 kph)
  • Maximum speed limiter settings of 110, 105, 100, 90 and 80 kph.

A Crash Potential Index (CPI) was used to evaluate the safety impacts as it captures speed differential, vehicle spacing and vehicle/driver braking capabilities. The CPI can distinguish dangerous vehicular interactions that could result in a collision.

The key results of this study are:

  • The introduction of speed limiters set at 105 kph increases safety in the uncongested region of traffic flow for all geometric configurations considered, especially for the straight segment. As maximum speed is set at 110 kph the safety gains from the introduction of speed limiters becomes less pronounced. Maximum safety gains were obtained when the maximum speed limiter setting was at 90 kph for the uncongested traffic volumes under consideration.
  • As traffic volume and percentage trucks in the traffic stream are increased, the safety gains associated with mandatory limiters set at 105 kph become less pronounced. As the volume is set close to capacity (2000 vehicles per hour per lane - vphpl), more vehicle interactions are expected to take place which can lead to reductions in safety especially for those segments with increased merging and lane-change activity (such as, on and off ramps). In these instances the introduction of truck speed limiters can actually reduce the level of safety when compared to the non-speed limiter base case.
  • As compliance is increased, there is a small corresponding increase in safety for the mandatory speed limiter case. It should also be noted that as volume and percent of trucks increase, the safety gains associated with the full compliance are offset by the additional traffic turbulence caused by higher volume and percentage trucks.
  • The QEW case study application confirms the findings obtained from the sensitivity analysis of different traffic scenarios and speed control strategies. When the limiter speed is set at 105 kph, its introduction yields statistically significant safety gains along the case study corridor as compared to the base case (no mandatory limiters). A total of 30 simulation runs were performed, and in 21 cases the introduction of limiters yielded positive safety gains.

Subsequent to the modeling work undertaken, a cursory investigation of the safety implications of speed limiters for two lane rural highways was carried out, based on a review of previous studies supplemented by an analysis of speed profiles for large trucks from Alberta and Saskatchewan and a review of provincial/territorial policies on setting speed limits on highways. The results show:

  • Typical speed limits on two-lane undivided rural highways are in the range of 80 to 90 kph but highways can have posted speed limits of 100 kph.
  • Data from several two-lane rural undivided highways in Alberta and Saskatchewan with a posted speed limit of 100 kph showed approximately 40% of truck drivers achieve speeds exceeding 105 kph on these highways. This has safety implications for mandated truck speed limiters set at 105 kph, especially as it relates to the possibility of unsafe overtaking manoeuvres.
  • The possibility for increased unsafe passing maneuvers poses special safety challenges where trucks are subject to a maximum speed set by limiters for two lane undivided rural highways. Further study of this situation is required before a more definitive statement can be made concerning the safety implications of truck speed limiters for this type of highway.

Trade and Competitiveness Assessment

This study assessed the potential trade and competitiveness impacts of mandating speed limiters under two scenarios: (1) speed limiter mandates only implemented in Ontario and Quebec and (2) a national speed limiter mandate implemented throughout Canada. Under both scenarios, all heavy trucks operating in the speed-limited jurisdiction would have to have their speed limiter electronically activated at 105 kph. This study also considered the potential economic impacts on the trucking sector and industry competitiveness issues relating to jurisdictions with and without speed limiter mandates.

The analysis conducted was based largely on several speed limiter surveys and a survey of Canadian and U.S. trucking operations by the project team.

This study concluded that there would likely be very few competitiveness issues from implementing a speed limiter mandate at 105 kph under either scenario. However, smaller fleet operators and owner-operators who feel that safety could be compromised may avoid operating in those speed-limited jurisdictions1.

Based on the survey results, the majority of freight in North America transported by large fleets is moved in trucks that are speed-limited around 105 kph. For those fleets already speed-limited at or below this speed, there would likely be no competitive impact operating under a speed limiter mandate. Canadian fleets operating in the 106-110 kph range would be able to operate under a 105 kph mandate with limited difficulty. In addition, those fleets operating at higher speed settings, or without the speed limiter set, noted that they typically travel at or below 105 kph to save on fuel costs.

Under both scenarios, larger U.S.-based fleets would likely be impacted minimally as most operate at or below 105 kph. By contrast, owner-operators were concerned with being speed limited at 105 kph. Many owner-operators operate in U.S. states with higher speed limits and they believe that safety would be compromised by increased car-truck interactions (limited passing ability and increased speed differentials). Most U.S.-based owner-operators interviewed noted that they would stop operating into Canada because of these safety concerns.

Under an Ontario/Quebec speed limiter mandate, a higher portion of Atlantic Canada-based trucking would be impacted than Western Canada-based fleets. It is estimated that about 30% of Atlantic Canada's heavy trucks operate into Ontario and Quebec and would potentially be impacted. However, many large fleets are already speed limited at 105 kph. Based on similar truck traffic patterns (e.g. operations into Ontario and Quebec), an estimated 10% of Western Canada's heavy truck fleet would be impacted by such a mandate. Similar to the position noted by U.S.-based owner-operators, western owner-operators indicated that they would avoid operating into Ontario and Quebec.

From an economic perspective, the main impact on the trucking industry from a speed limiter mandate would be savings in fuel and other vehicle operating costs. Based on an estimated annual fuel savings of 228 million litres (Environmental Benefits study), a national speed limiter mandate could save the trucking industry up to $200 million annually. In addition, there would likely be very little impact on shippers as the majority of freight is already being moved by fleets speed limited at 105 kph or less. A costing analysis was also performed to illustrate the potential trade-off between productivity benefits and increased costs. Results demonstrated that the increased fuel costs of operating at speeds higher than 105 kph outweigh any productivity gains.

The owner-operators interviewed stated that speed-limited fleets would be placed at a disadvantage when recruiting drivers. This view was not shared by the majority of large and small fleet managers, who noted that it is the overall pay package that drivers consider such as mileage rates, quality of equipment and fringe benefits. It was their opinion that the lack of a speed limiter policy would not be an incentive in terms of driver recruitment and retention.

TC also requested an assessment by the Trade Law Bureau of the Department of Justice (DOJ) of the trade agreement implications. DOJ counsel concluded that any proposed national speed limiter mandate would be generally consistent with Canada's international trade law obligations and the potential for a successful challenge was viewed to be minimal.

Environmental Benefits Study

This study assessed the potential national diesel fuel savings and corresponding greenhouse gas (GHG) reductions from a national speed limiter mandate. It updated preliminary estimates provided in the 2006 Discussion Paper on Speed Limiters for Trucks Operating in Canada based on more detailed truck speed distribution and truck traffic volume data obtained from the provinces / territories.

Annual truck traffic volume data for provincial highways with posted speed limits of 100 kph and 110 kph was collected at various data collection sites and applied against provincial speed distribution data to produce estimated annual totals of truck travel above 105 kph. Nationally, it was found that about 62% of heavy trucks travel at 105 kph or lower, 23% were in the 105-110 kph range and 15% were at 110 kph or above.

British Columbia and Manitoba represented the lowest proportion of truck traffic potentially impacted by a speed limiter requirement with only about 3% and 25% respectively of vehicles traveling above 105 kph. The Alberta (110 kph location) and Ontario (100 kph location) represented the highest proportion of truck traffic potentially impacted by the requirement with about 55% and 59% respectively. Most other locations would potentially see 35% to 50% of trucks impacted by a speed limiter requirement.

A national mandate would potentially result in fuel savings of 228.6 million litres of on-road diesel. This represents 1.4% of the total on-road diesel consumed in 2006. Annual GHG savings are estimated at 0.64 megatonnes. Ontario and Quebec combined would account for 64% of the estimated national savings.

Of the estimated annual fuel savings of 228.6 million litres, three provinces - Ontario, Quebec, Alberta - would account for 83% of the savings.

Case Study

A case study was conducted to investigate the actual benefits and experience of speed limiter usage by carriers. Two large carriers participated, one from the for-hire sector and one private trucking firm. Together, these carriers operate about 400 power units. For confidentiality reasons, the carriers who participated in the study could not be named. Attempts were made to include an owner-operator; however, a participant could not be confirmed within the project schedule.

The study collected both quantitative and qualitative information from the carriers with a focus on operational cost savings and safety. Improved fuel efficiency and fleet safety was stated as the motivation behind the introduction of speed controls in both firms and these policies have been in place for at least 20 years. Although it was not possible to collect data for both pre and post speed limiter implementation, both carriers believed that their speed control policies have had a significant impact on reducing fleet fuel consumption. They also reported that maintenance costs were also kept in check by operating their vehicles at reduced speeds.

Although drivers interviewed noted some concerns about driving speed-limited trucks, overall they did not believe that the speed control policies within their companies have created any significant operational or safety concerns. Each carrier initially experienced some tension in terms of drivers' acceptance of speed limiters. However, drivers have generally accepted speed controls and expressed satisfaction with their jobs.

The study also found that both fleets did not perceive any market disadvantage compared to their competitors as a result of their speed control policies, and in fact their policies support the ability to retain good drivers.

From a safety perspective, both fleet operators believed that lower speeds have resulted in an improved safety record. Based on the collision data reviewed, there was no evidence that speed limiters are contributing to the occurrence of collisions. In fact, there were no rear-end collisions attributed to operating under a speed control policy in which another vehicle hit one of their trucks at highway speed.

International Assessment

An assessment was conducted to learn from the experiences of three countries-Australia, the United Kingdom, and Sweden-which have implemented speed limiter legislation. Australia and the European Union2 (EU) have legislated the use of heavy truck speed limiters since the early 1990s. Legislative approaches, impact on road safety, enforcement and compliance issues were researched.

Australia implemented speed limiter legislation to address rising traffic fatalities involving heavy trucks and has noted a decrease in the number of collisions since its implementation.

EU directives legislated the use of speed limiters in heavy trucks and buses for road safety and environmental reasons. However, the extent to which speed limiters have contributed to improved road safety and decreased heavy truck collisions is difficult to determine as no studies were completed to quantifiably draw this conclusion.

Best available data comes from the U.K., which showed a 26% decrease in heavy truck accidents since the legislation was enacted in 1992. Furthermore, government officials interviewed in all three countries believe that speed limiters have had a positive impact on road safety.

Australia and the EU require speed limiters for trucks over 12 tonnes to be set at no more than 100 kph and 90 kph respectively. The EU also limits the speed of buses over 10 tonnes at 100 kph, and legislation was extended to medium-duty trucks over 3.5 tonnes in 2002. However, EU directives do not apply to foreign trucks. A report was prepared for the European Parliament in 2001 that estimated the total cost savings of speed-limiting all EU trucks in the 3.5-12 tonne range at 3 billion euros.

In all three countries, officials noted that compliance and enforcement efforts were integral to the effectiveness of the speed limiter policy. Roadside inspections, targeted enforcement of high-risk offenders, highway data collection camera networks, and annual inspections were used towards speed limiter compliance. However, the lack of sufficient enforcement personnel was noted as a consistent problem.

Tampering was identified as a significant problem in all countries. Australian officials estimated a 10-30% speed limiter tampering rate and data from Sweden suggested that 40% of heavy trucks were exceeding their maximum allowable speed. Tampering methods included unauthorized changes to the electronic control module (ECM) settings. Operators would also adjust the tire size or transmission gear ratios to allow the true vehicle speed to exceed the speed limiter setting.

Road safety concerns identified by officials and industry stakeholders included increased highway congestion and difficulty accessing on and off-ramps resulting from bunching of speed-limited trucks. In an effort to limit the impact of increased highway congestion from speed-limited trucks overtaking one another, U.K. officials restricted heavy vehicles to the inside lane of motorways.

The importance of a consistent national approach to speed limiter compliance was stressed by a number of officials and stakeholders interviewed. Australian states and territories are provided flexibility with respect to legislative approaches towards compliance and enforcement. Similarly, the European Commission (EC) allows EU member states flexibility with specific regulatory provisions and implementation dates. However, the core legislative objectives (e.g. speed limiter set at 100 kph for all trucks over 12 tonnes) must be maintained.

In the case of Australia of Sweden, regulations and policies proposed at the national level are not always adopted at the state, territorial or county level and this has led to inconsistencies in regulatory approaches toward enforcement and compliance.

Technical Considerations Assessment

This report, based on survey responses from the Truck Manufacturers Association and Engine Manufacturers Association, summarizes technical issues and limitations of electronic speed limiters with respect to compliance, enforcement, and tampering. These issues should be considered in the context of a speed limiter mandate as they may influence the effectiveness of a jurisdiction's enforcement efforts to ensure compliance.

It is important to note that a heavy truck's speed limiter setting itself does not control the vehicle's top speed. Other variables, such as the tire-rolling radius and rear axle gear ratio, are essential for the ECM to calculate an accurate top speed. The customer specifies these variables when the truck is ordered and the ECM cannot be calibrated until final assembly. Both truck and engine manufacturers believe that the speed limiter setting should be a customer-configurable feature and pre-programming a particular setting is unrealistic and ignores the realities of customized production for the global market.

The speed limiter setting can only be accessed with manufacturer software, ECM password and computer equipment. Many fleets set the speed limiter once upon delivery of a new truck according to the company's speed control policy. The setting could conceivably be adjusted from within the truck cab assuming the necessary hardware/software and password were available. However, only vehicle owners and service personnel typically have access to the necessary equipment and passwords.

There are also technical challenges with respect to interfacing with all truck (ECM) makes and models on a uniform basis in order to access the speed limiter setting. Each engine manufacturer may have multiple hardware and software configurations and regularly update proprietary engine software. This may present challenges for enforcement personnel to access and verify the speed limiter settings in a uniform manner. However, reading tools are available that allow strictly read-only access to all major engine types.

1 Many owner-operators sub-contract to large fleets with speed control policies in place.

2 The United Kingdom and Sweden are member states of the European Union.