Have your say on making London's lorries safer: Direct Vision Standard (DVS)

Closed 18 Feb 2019

Opened 8 Jan 2019

Results Updated 26 Apr 2019

Between 8 January 2019 and 18 February 2019, we consulted on the final scheme proposals for our Heavy Goods Vehicle (HGV) Safety Permit scheme, including the permit application process, safe system requirements and enforcement of the scheme. This consultation was the third consultation on the Direct Vision Standard and the principles of an HGV Safety Permit.

We received 280 responses to the consultation, which included 47 responses from stakeholders.

The responses were overall in favour of the proposals as presented. A total of 61% of respondents either agreed or strongly agreed with our proposed process for obtaining a vehicle star rating. A total of 60% of respondents either strongly agreed or agreed with our permit application process proposals. 67% of the total respondents stated either strongly agree or agree with our proposed safe system mitigating measures (including cameras and mirrors). Our plans for how to enforce the scheme and deal with appeals were strongly agreed or agreed with by 57% of respondents.

Following careful consideration of the consultation responses, we made some amendments to our proposals.

Key changes in response to the consultation include:  

  • Safe System – we have provided clearer guidance on the requirements for the safe system mitigating measures
  • Progressive Safe System – we have committed to consulting on the progressive safe system in 2022 ahead of its introduction in 2024
  • Driver Training – we have clarified that driver training, while highly recommended is not a mandatory requirement for obtaining a permit. A list of providers of will be included on the permit application portal
  • HGV Safety Permit – for HGVs that meet the minimum DVS star rating (one star in 2020) Permits will be issued automatically once the online application has been completed. During the pre-compliance year (October 2019 – October 2020) Permits for HGVs that are required to fit the safe system will be issued within 28 days following approval of the safe system evidence pack. Once enforcement of the scheme begins in October 2020, the turn-around period will be shortened and a system put in place for expedited applications. Further details on this will be communicated later this year. We have also provided details on the appeals process where a permit application is refused.
  • Enforcement – we have provided further guidance on the enforcement process for the scheme
  • Appeals Process – we have provided details on the appeals process regarding any Penalty Charge Notice issued under the Scheme     

A more detailed analysis of the results can be viewed in our consultation report. We have also published our responses to the main issues raised through this report in a separate ‘Response to Issues Raised’.

Consultation report (PDF 896KB)

Appendix D - Consultation event slides (PDF 862KB)

Response to Issues Raised (PDF 340KB)

Our next steps and further consultation

It is proposed the Scheme is implemented by using an existing TRO operated by London Councils in connection with the London Lorry Control Scheme (LLCS).
We are now holding the fourth and final phase of consultation on this Scheme; the phase 2c statutory consultation on the final scheme proposals and the Traffic Regulation Order (TRO) that will be used to implement the scheme.
This includes a statutory consultation on an order (the Amendment Order) to make the necessary changes to the 1985 TRO to accommodate the HGV Safety Permit Scheme alongside the LLCS. This will not in any way change the existing LLCS. If approved, the Permit Scheme will become mandatory from 26 October 2020 and will be able to be enforced by PCN. Any objections to the Amendment Order, clearly specifying the grounds for objecting, must be made by Thursday 23 May 2019. 

From Friday 26 April 2019 you can let us know your views online at www.tfl.gov.uk/direct-vision-standardYou can also write to us at FREEPOST TFL CONSULTATIONS or by email to consultations@tfl.gov.uk.

Subject to the successful application for the TRO we plan to make permits for the scheme available in October 2019 and begin enforcement of the scheme in October 2020.


On 30 September 2016 the Mayor announced his intention to use the world's first Direct Vision Standard (DVS) for Heavy Goods Vehicles (HGVs) to improve the safety of all road users, particularly vulnerable road users like pedestrians, cyclists and motorcyclists. 

Our research shows that between 2015 and 2017, HGVs were disproportionately involved in fatal collisions with cyclists (63 per cent) and pedestrians (25 per cent) on London’s streets, despite only making up four per cent of the overall miles driven in the Capital.

The DVS forms part of the Mayor's Vision Zero approach to eliminating all deaths and serious injuries from London's roads by 2041. Using a star system, the DVS rates HGVs from zero (lowest) to five (highest) stars, based on how much a driver can see directly through their HGV cab windows.

We have now completed two rounds of consultation, firstly on the principles of a DVS and then a proposal for an HGV safety permit scheme. Listening to feedback from these consultations and working closely with industry and stakeholders, we have now further developed the scheme. The Consultation reports and Responses to Issues Raised documents from both consultations are available via the links below.

We are now seeking your views on our final scheme proposals with a particular focus on the HGV safety permit processes. This includes the process of obtaining a vehicle star rating, the safe system requirements, the permit application and administration process and the enforcement and appeals process.

The proposed scheme would require all HGVs over 12 tonnes to hold a Safety permit to enter or operate in Greater London. As part of DVS, HGVs will be rated between ‘zero-star’ (lowest) and ‘five-star’ (highest). From October 2020, zero star HGVs would be banned unless they can demonstrate they operate in compliance with other measures in a defined safe system to minimise their risk to vulnerable road users.

By 2024, zero, one and two star HGVs would be banned unless they can demonstrate compliance with an updated progressive safe system. The scheme will launch in October 2019 when operators will be able to apply for Safety Permits.

The proposed safe system includes specific industry recognised mitigating measures such as sensors, camera systems and visual warnings. The safety system would evolve over time, and be reviewed in 2024 in order to consider advances in technology.

Detailed information on the DVS rating protocol, research on the safe system proposal and a full Integrated Impact Assessment are included as part of the consultation material.

Please have your say by completing our online questionnaire below no later than Monday 18 February 2019.

The consultation process

A phased consultation approach has been taken at key stages of the development of the DVS Scheme proposals:

Phase 1 (January to April 2017) – we set out the case for HGV driver direct vision and consulted on the Mayor of London’s outline proposals to introduce a DVS for HGVs in London and the principles of the Standard itself. We have considered all of the responses and a full analysis can be found in the Consultation Report and the Responses to Issues Raised document. The responses showed that, in general, there is support for the principle of a DVS.

Phase 2a policy consultation (16 November to 24 January 2018) - we outlined how we set the proposed DVS star rating boundaries and the process by which different options for implementation were assessed and used to develop the preferred HGV safety permit scheme. We considered all of the responses and a full analysis can be found in the Consultation Report and the Responses to Issues Raised document. The responses showed support for the proposed permit scheme approach.

Phase 2b – Final scheme proposals (8 January 2019 to 18 February 2019) – the current phase consults on the final HGV safety permit scheme proposals including permit application process, safe system requirements and enforcement of the Scheme. Feedback from this phase of consultation will be used to refine the final Scheme ahead of the statutory consultation (Phase 2c) later this year.

Phase 2c – Statutory consultation - it is proposed that the Scheme is implemented by a Traffic Regulation Order (TRO). A statutory consultation is planned for later this year, ahead of the proposed permits ‘go live’ in October 2019 and scheme enforcement from 26 October 2020

Next steps

Once this consultation has closed, we will review and fully consider all of the feedback received.

We will then carry out the Phase 2c statutory consultation before submitting the final proposals for the HGV safety permit scheme and implementing the scheme.

Supporting documentation

Consultation document (this consultation – Phase 2b) (PDF 516KB)

Appendix 1 - DVS technical protocol, Loughborough Design School, 2018 (PDF 7.44MB)

Appendix 2 - HGV safety permit – guidance for operators entering London, Transport for London, 2018 (PDF 200KB)

Appendix 3 - Direct Vision Standards - Integrated Impact Assessment of the Preferred Scheme, Jacobs, 2018 (PDF 1.07MB)

Appendix 4 - Direct Vision Standard – Phase 2b Cost and Business Impact Assessment report, Jacobs, 2018 (PDF 445KB)

Appendix 5 - Heavy Goods Vehicle survey, AECOM, 2018 (PDF 1.66MB)

Appendix 6 - HGV safety permit – list of exemptions, Transport for London, 2018 (PDF 81KB)

Appendix 7 -HGV Safety Permit Evidence of Effectiveness & Candidate technical requirements for the Safe System

Appendix 8 - Consultation report (Consultation phase 1) (PDF 388KB)

Appendix 9 - Responses to Issues Raised (Consultation phase 1) (PDF 43KB)

Appendix 10 - Consultation report (Consultation phase 2a) (PDF 1.05MB)

Appendix 11 - Responses to Issues Raised (Consultation phase 2a) (PDF 113KB)

Have your say

We would like to know what you think about our proposals.

Please give us your views by completing the online survey below by Monday 18 February 2019.

Alternatively, you can:

You can also request paper copies of all the consultation materials and a response form by emailing consultations@tfl.gov.uk, or writing to FREEPOST TFL CONSULTATIONS.


  • All Areas


  • Anyone from any background


  • Safer Lorries
  • Direct Vision Standards