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Flawed report uses out-of-date figures to falsely claim HGVs pay for the damage they cause

20 March 2018

Campaigner for Better Transport has criticised a report which falsely claimed heavy good vehicles (HGVs) cover the costs of the damage they cause to roads, pavements and street furniture.

Heavy Goods Vehicles: Do they pay their way? - impacts on road surfaces, produced by RepGraph for FTA (Freight Trade Association), found HGVs pay three times more than their estimated damage costs to infrastructure. But campaigners say the report is flawed, based on out-of-date figures and incorrect assumptions, and in fact HGVs only cover one tenth (11 per cent) of their road damage costs.

The criticism comes on the same day that the ALARM Survey found it will now cost an estimated £9.31 billion and 14 years to clear the backlog of road repairs across England and Wales.

Philippa Edmunds, Freight on Rail Manager for Campaign for Better Transport, said: “The RepGraph report conflates two different and recognised costing methods to come to these grossly inaccurate conclusions about road damage. Furthermore, the RepGraph report ignores all the other costs HGVs impose on society in terms of road congestion, collisions and pollution. Our latest report shows that HGVs only cover a third of their overall costs and are being subsidised by the taxpayer to the tune of £6 billion a year.

“The Government needs to introduce distance-based charging, instead of the existing time-based system, in its current review of the Lorry Road User Levy to better reflect HGV costs, encourage more efficient lorry use of the road network and reduce unnecessary lorry miles. Government figures show that only a third (34 per cent) of HGVs are full in terms of load volume, and another third (30 per cent) are driving around completely empty, figures which have been growing for some years.

“If lorries start to pay their way, putting rail and road are on an equal footing, more freight can be transferred to rail, the safer, cleaner alternative which reduces road congestion and road damage.”

Campaign for Better Transport highlighted four fundamental flaws in the RepGraph report:

  • Using fuel duty from HGVs to offset HGV infrastructure costs when fuel duty income is not used in this way and there are no Government plans to do so
  • Halving HGV infrastructure per mile costs by using the  Government 2009 value of nine pence per mile instead of the latest figure from 2015 of 18 pence per mile
  • Omitting any external costs other than infrastructure, such as congestion, collisions, carbon and air pollution  
  • Not distinguishing between different types and weights of HGVs. The largest and heaviest HGVs cause a great deal more damage to foundations and structures of roads than cars - the standard six-axle 44 tonne 16.5 metre truck is 100,000 times more damaging to road surfaces than a Ford Focus - therefore some of the heaviest road repair costs are almost exclusively attributable to the heaviest vehicles.


For further information please contact Alice Ridley on 020 7566 6495 / 07984 773 468 or alice.ridley@bettertransport.org.uk

Notes to Editors

  1. RepGraph Heavy Goods Vehicles: Do they pay their way? - impacts on road surfaces, is available from the FTA website.
  2. So, rather than paying three times their costs as claimed in the RepGraph report, with the corrected damage figure of £3 billion, HGVs are in fact only paying 11 per cent (£340 million ) through Vehicle excise duty (VED) and the Road User Levy. This is calculated by adding £50 million from foreign vehicles paying the Road User Levy to the VED total for 2016.
  3. The RepGraph report conflates two different and recognised costing methods. The first is the marginal external cost, which includes additional congestion and road maintenance as costs, but assumes the road network has been built and does not include an allowance for this. This approach seeks to match the marginal cost per mile of the external impacts of HGVs to the perceived cost per mile of using a particular HGV. Obviously, the impacts of a 44 tonne articulated vehicle are much greater than a 7.5 tonne rigid HGV. The second is the fully allocated cost model, which similarly identifies costs according to HGV characteristics, but includes the capital cost of the road network. This can be either as a notional depreciation and/or cost of capital, or on the basis of the typical annual spend on road construction. In the fully allocated cost model case, congestion is often left out of the cost side since it is borne by road users as a group. However, it should be noted that strictly speaking a significant amount of the congestion costs are borne by cars and are not part of the road freight user group.
  4. An MTRU report and the Department for Transport (DfT) table below shows that two thirds of marginal costs of the large HGVs are not being met by the haulage operators. In 2016, 9 billion vehicle miles were run by articulated HGVs alone (this figure does not include rigid HGVs (source: TRA3105)) implying a marginal cost shortfall of about £6 billion. In 2014 the figure was £6.5 billion. These numbers vary a little from year to year according to traffic and the severity of impacts such as pollution or casualties. However, they remain substantial and completely unmet. The issue of all the congestion, road damage, collision and pollution costs is discussed fully in this Freight on Rail report, Read the full research here.  


DfT marginal external cost tables

For articulated HGVs DfT produce Mode Shift Benefit (MSB) tables, most recently updated in 2015 with estimates for 2020 values at 2015 prices. These calculate the marginal costs so that investment in alternatives which reduce articulated vehicle miles can be tested for value for money. These showed a rise in costs from the original 2009 estimates, in particular those for road infrastructure and for carbon.The tables below show the comparative values.

Table 1Mode Shift Benefits 2015 and 2009

Pence per articulated HGV mile


(by level of congestion)

  High Low A Other Weighted Average 2015 Weighted Average 2009 report
Congestion 99 24 72 78 57 52.4
Accidents 0.5 0.5 5.6 5.5 2.7 2.8
Noise 9 7 8 14 8 7.0
Pollution 0 0 0.1 0.2 0.1 2.5
Greenhouse Gases 6 6 7 9 7 3.8
Infrastructure 7 7 24 171 18 9.0



6 6 6 6 6 6.4
Gross Total 127.5 50.5 122.7 283.7 98.8 83.9
Taxation -31 -31 -32 -40 -32 -34.1
Marginal cost gap 96.5 19.5 90.7 243.7 66.8 49.8
Road Tax as % Gross marginal cost 24% 61% 26% 14% 32% 41%


  1. Inclusion of fuel duty from HGVs (£4,093 million) as though it is hypothecated income which can be counted against HGV infrastructure costs when there are no Government plans for this. The actual hypothecated figures from HGVs is £291 million from the DfT tax income (Vehicle excise duty (VED) plus £50 million estimated from the Road User Levy = £340 million. With reference to the RepGraph report using the latest MSB values, and Road User Levy from all HGVs (£340 million) would not even meet the infrastructure costs for articulated vehicles alone (£1.62 billion), which are only part of the HGV fleet as rigids are excluded from this figure.
  2. Empty running figure tables are available from the Department for Transport (RFS0117 July 2017).
  3. The largest and heaviest HGVs, (mostly but not entirely articulated), cause a great deal more damage to foundations and structures of roads than cars. This is because the damaging power rises exponentially as weight increases. This is called the Generalized Fourth Power Law. Motorways are constructed to a higher specification than local-authority-run roads to cater for heavy goods vehicles, but it is the latter which make up almost 98 per cent of our network which explains the poor repair of many local authority-controlled roads.
  4. Freight on Rail is a partnership of the transport trade unions, the rail freight industry and Campaign for Better Transport.
  5. Campaign for Better Transport is the UK's leading authority on sustainable transport. We champion transport solutions that improve people's lives and reduce environmental damage. Our campaigns push innovative, practical policies at local and national levels. Campaign for Better Transport Charitable Trust is a registered charity (1101929).