Select Committee on Environment, Transport and Regional Affairs Twelfth Report


What can be done?

55. Towards the end of 1997, the Deputy Prime Minister established a Shipping Working Group, consisting of representatives of the Chamber of Shipping, Trades Unions, and Government Departments.[121] The Working Group's report formed the basis of the Government's daughter document, British Shipping: Charting a new course. Given the membership of the Working Group it is inevitable that most of the suggestions made by our witnesses of actions that should now be taken to stem the decline of the shipping industry, and particularly to boost the UK register and the number of British seafarers, supported the recommendations of the daughter document.


56. The daughter document makes thirty-three recommendations, which it calls 'Actions', which are intended to increase the skills of British seafarers, encourage employment, increase the UK's attractiveness to shipping enterprises, and to gain safety and environmental benefits from shipping.[122] We have considered each recommendation in turn.


57. Exactly one third of the Government's Actions refer to training. Their combined objective is to increase the funding of, and the places available for, training, primarily of officer cadets. Given the need to train cadets which we have already described, we welcome the Government's commitment to training, and support the measures proposed in British Shipping: Charting a new course which are intended to increase the number of cadets recruited each year, as well as that intended to promote the training of ratings.

58. We note that the daughter document claims that "there is clear evidence of market failure in seafarer training ... there is a far greater 'free-rider' effect than in [other] industries".[123] The Government says that this failure is a feature of the fact that whilst training must be carried out by shipping companies, the ultimate end-user of maritime skills are the shore-based industries. It also identifies a large number of British shipping companies, particularly the smaller ones, which "continue to seek (or passively enjoy) short-term competitive cost advantage by opting not to train seafarers",[124] and instead to 'poach' trained staff from companies which operate training programmes. The daughter document points out that 45 per cent of British officers work for foreign companies which benefit from the skilled pool of British seafarers without contributing to training.[125]

59. Whilst we agree with the Government's analysis of the problem, we note with some concern that training levies on UK shipping industries,[126] on foreign shipowners,[127] and on the shore-based industries,[128] which will provide much of the funding needed for new cadets, are proposed to be voluntary. We believe that responsible companies and industries already contribute to cadet training: the Baltic Exchange, for example, told us that it provided three bursaries at maritime universities, as well as other financial support, in spite of the fact that it used only "a small number of trained seafarers in [its] business".[129] We doubt that many companies, if they do not already contribute to training, particularly those based abroad, will respond favourably to attempts to raise a training levy on a voluntary basis. We recommend that the Government, in conjunction with the Chamber of Shipping and others, should monitor closely the success or otherwise of its proposed voluntary training levies and, if they prove unsuccessful, should consider what measures should be put in place to eliminate 'free-riding'. This is a subject to which we return when we consider the proposed tonnage tax.

60. The Government has announced that it is committed to provide long-term support to its Support for Maritime Training (SMarT) scheme. Between 1999 and 2002, the Government has allocated £18.6 million to the scheme.[130] As a result of that funding, and that provided by the voluntary training levies, if successful, as well as the recommendations of the daughter document intended to make more training berths available,[131] there will be a greater number of places for cadets. We are mindful of the Government's response to the Transport Committee's report in 1988, which said, in response to the Committee's recommendation that the sum made available for training should be doubled, that "there can be no guarantees that recruits will come forward to fill all the places available".[132] NUMAST told us that the Dutch Government had spent £34 million on a promotional campaign to draw young people into the shipping industry, and had been rewarded with 17,000 applicants for jobs.[133] We recommend that, hand in hand with efforts to increase the funding for, and the availability of, training berths, the Government should take the lead in ensuring that sufficient cadets come forward to fill those berths. We recommend that the Government looks to the example set by the Netherlands, and the successful campaign mounted there to attract recruits to the industry.


61. A further seven of the Actions proposed in the daughter document are devoted to the encouragement of employment. In general we received little evidence about these proposals, so we make no comment about them here. However, two matters are of concern. Action 12 advocates the establishment of clear guidelines on off-shore contracts, and Action 18 states that the Government will examine the protection offered by the social security system to those employed on ships not registered in the United Kingdom.[134] We believe that these matters are related, and we deal with them together.

62. In recent years many British shipping companies have transferred the contracts of its employees off-shore in order to avoid paying National Insurance contributions, which make up between eight and ten per cent of total employment cost. Thus these companies are able to compete with companies based in other countries, including several within the European Union, which offer some degree of alleviation of employers' social costs to the shipping industry. There are concerns that seafarers employed on off-shore contracts do not enjoy the same employment rights as those employed within the UK. Consequently several of our witnesses argued that employers' National Insurance contributions for British seafarers should be eliminated, obviating the need for off-shore contracts.[135] The daughter document specifically rejects such a measure, whilst acknowledging that off-shore contracts may make amendment to employment rights legislation necessary.[136]

63. Those employed on off-shore contracts, and those simply employed by foreign shipping companies, also may not enjoy the same cover for social security benefits as workers in the United Kingdom. Some of our witnesses argued that such seafarers should be allowed to make voluntary payments of employees' Class 1 National Insurance contributions to ensure that their, and their families', cover is adequate.[137] We recommend that the Government should determine urgently whether any amendment to employment rights legislation is required to respond to increased use of off-shore contracts, and that it should consider the availability of social security benefits for those employed on off-shore contracts, and by foreign shipping companies. The Government should make such amendments to the law, and to the social security regime, that are necessary to safeguard the rights of seafarers.

64. The European Commission has put forward proposals to enforce minimum conditions of service, including wages, for seafarers serving aboard ferries which operate wholly within the European Union. Action 15 of the daughter document supports these proposals.[138] The objective is to create a level playing field so that ferry operators are less attracted to employing seafarers from outside the European Union who might be willing to accept lower wages or worse working conditions, thereby safe-guarding the jobs of European Union nationals.[139] In her evidence to us, Mrs Georgette Lalis, the Director for Maritime Transport in the Directorate General for Transport of the European Commission, pointed out that non-European Union nationals cannot be employed on other transport modes within the Union such as rail lines, and that intra-Community ferries should be considered as part of the internal transport market.[140] We also support the Commission's proposals on ferry manning, relating to minimum conditions of service and wages for seafarers on intra-Community ferries.

65. We were, however, surprised that Mrs Lalis felt that cargo vessels similarly operating only within the European Union should not be subject to similar conditions.[141] Although we recognise that the shipping industry may fear the imposition of further regulations, we believe that extending the ferry manning proposal to short-sea and coastal shipping should be regarded as an opportunity to ensure that seafarers operating vessels near the UK's coast are adequately paid, well-rested, and working in good conditions. They would also offer an opportunity to protect European Union nationals' jobs. In any case, we doubt that many UK-registered ships would find any difficulty in meeting reasonable standards imposed by Brussels. Nevertheless, since we also recognise that such measures might prompt an adverse reaction from States outside the Union, we recommend that the Government should further press the European Union to consider including intra-community cargo vessels within the terms of the ferry manning initiative.


66. We have found that there is a disappointing absence of clear information about the UK shipping industry. It is only through the efforts of our specialist adviser that we have been able to build up the picture of the current state of the industry included within this report. The work of London Guildhall University and the University of Wales as recently as two years ago has for the first time revealed reliable information about the number of active British seafarers. That information is, however, mainly restricted to officers: we, like the Government, observe that there is "a lack of information about the demand and supply of ratings in the industry".[142] We therefore welcome the Government's commitment to help the industry to establish a register of British ratings. We recommend that the Government should ensure that accurate data about the state of the British shipping industry continues to be gathered in future.

Careers for ratings

67. Much of our evidence focussed on the shortage of officers. Nevertheless, as we have seen, the number of British ratings employed aboard UK-registered vessels has also fallen sharply, by 62 per cent between 1980 and 1995. Action 20 supports the recommendation made by the Shipping Working Group that the industry should develop formal ratings-to-officer and ratings sea-to-shore career paths.[143] We support these objectives, not only because we believe that they will encourage people to become ratings, thereby stemming the decline in their numbers, but also because at a time when officers are in short supply, experienced ratings may prove to be valuable recruits to the officers' ranks.


68. The Government is committed to attempting to liberalise international markets,[144] by working through the World Trade Organisation and other bodies to remove barriers faced by the UK shipping industry to trade. We obviously agree with this aim. However, we believe that the best way to open up markets for the UK shipping industry may not be to try to counter restrictive practices, but instead to ensure that UK shipping companies are treated equally in terms of taxation and social costs as companies in other countries. In short, the Government has to consider fiscal measures, such as the proposed tonnage tax, to which we return below.

69. Action 26 seeks to reduce unfair competition from foreign shipping companies by campaigning against sub-standard shipping. In particular, inspections of foreign-registered ships through Port State Control serves two ends: it combats those who try to gain an unfair cost advantage over UK-registered ships by cutting corners, and it helps to ensure that the shipping around our coast is safe. We welcome the Government's commitment to fund the Maritime and Coastguard Agency adequately so that it is able to carry out its valuable programme of Port State Control inspections. We believe that if the Agency sees some benefit in increasing the number of Port State Control inspections the Government should provide it with adequate funds to do so.

Duty Free

70. The daughter document points out that large numbers of British seafarers, including a very high proportion of ratings, are employed on cross-Channel ferries. There is concern that the imminent abolition of duty free shopping might have a serious adverse impact on the ferry industry. The Department of the Environment, Transport and the Regions has found evidence that between 1,300 and 2,700 jobs will be lost, many of them in the shipping industry.[145] In that context, we are disappointed with the language of Action 22, which merely says that "the Government will work with other Member States in considering the implications for the [shipping] industry of the ending of intra-EU duty free sales and ways of responding to this".[146] The Prime Minister said, after the European Council meeting in Vienna in December 1998, that he had sought a review of plans to abolish duty free,[147] although in the end the review did not recommend retaining the existing duty free arrangements.[148] We note that the Government intends to continue to seek to retain duty free, or at least to ensure that the regime that replaces it has a less damaging effect.[149] We support the Government's efforts in respect of duty free, and recommend that they are redoubled.

The proposed tonnage tax

71. It is relatively easy for a ship-owner, operating in conditions where national boundaries are largely irrelevant, to "set up off-shore structures wherever you are in the world to operate your ships essentially in a low-tax or no-tax environment".[150] As the daughter document says, "in this situation, national fiscal and regulatory regimes can be the main residual cause of cost differentials. Shipping investment tends to be drawn to low tax regimes".[151] Those countries which place a higher tax burden on their shipping industries lose investment to other countries, and increasingly find that shipowners base themselves overseas. As a result 'flagging out' increases. To combat the problem several countries, such as the Netherlands, Norway, Germany, and Greece, have adopted tax measures for shipping which compare favourably to the lowest tax regimes to be found internationally.[152]

72. The example most frequently quoted to us was that of the Netherlands, which introduced a tonnage tax in 1996. In that country shipping companies are subject to a nominal rate of corporation tax determined by the total tonnage of the ships in their fleet. Companies which base themselves in the Netherlands to take advantage of the lower tax rate must fulfil certain criteria in exchange, such as employing a certain number of Dutch seafarers. The tonnage tax enables the Netherlands "to compete on the same sort of basis as their major competitors".[153] As a result it has attracting 120 ships to its register,[154] with a "clear reduction in the number of Dutch-managed ships under foreign flags [and] a clear increase in the number of Dutch and other European Union seamen in the Dutch fleet".[155]

73. The Shipping Working Group strongly recommended that a tonnage tax should be introduced in the United Kingdom, to provide a level playing field with countries both within and outside Europe. The tax would have benefits beyond giving incentives to shipowners to base themselves in the United Kingdom. For example, the Minister for Shipping told us that "the tonnage tax would carry with it a package of measures, the obvious one being a commitment to funding training, where it was analysed that that would increase the number of trainees, year on year, by 25 per cent".[156] Furthermore, despite the fact that it was not proposed that the tonnage tax would be linked to the registration of vessels in this country, several of our witnesses believed that it would encourage growth of the UK register. The experience of the Netherlands appears to support that belief, and we note that Lord Sterling, of P&O, believes that with a 'sensible' tonnage tax his company would be able to bring up to 55 ships back to the register.[157]

74. The tonnage tax is, however, of no benefit unless it is low enough to compete with other tax regimes. There will, therefore, be a cost to the Government of introducing such a scheme instead of corporation tax, because of reduced income from taxation. The Shipping Working Group estimated that the cost might be £40 million to £50 million per year.[158] The Chamber of Shipping told us, however, that they thought that the cost would be lower, since the figure quoted by the Working Group had been based on the overall profits of shipping companies, many of which reinvest income in investment programmes which are already tax-free, and also since the shipping industry in the UK would be stimulated, and thus pay more tax.[159] In all, the Chamber told us, the cost to the Treasury of introducing a tonnage tax would be "not more than £10 to £15 million maximum".[160]

75. In view of the condition of the shipping industry, as we have described, and the fact that our witnesses were all in favour of the introduction of a tonnage tax, we were extremely disappointed by the wording of Action 23 of the daughter document, which simply said that "the Government will discuss fiscal options with the shipping industry in the context of the pre-Budget consultation and without commitment on implementation".[161] We were further disappointed by the Budget, in which the Chancellor said that "the shipping industry has put to me the case for ... a lower rate ring-fenced tonnage tax. While I am attracted to these options, I have to be satisfied that lower tax rates will not become a vehicle for tax avoidance".[162] It was announced that Lord Alexander would conduct a study of the "national and international issues involved".[163]

76. We not do fully understand what "international issues" Lord Alexander must consider. The European Commission has told us that although the tonnage tax is a state aid, the Commission recognises that "it is a state aid that will not impede internal EU competition while promoting an EU fleet. This is why the tonnage tax is one of the measures within the guidelines that Member States can adopt if they want to help their fleet".[164] The only other relevant international matter is its obvious success in other countries, which has been illustrated by the Shipping Working Group.

77. One "national issue" is concern about tax avoidance, since companies might seek to exploit the lower tax rate.[165] Clearly such a situation would be unacceptable, but we do not believe that the Treasury would find any particular difficulty in framing such a tax, and we believe that the Treasury should have been ready at the time of the Budget to put forward proper proposals. It evidently was unable to do so: nor was it able to assist us in our inquiry.[166] One of the reasons it was unprepared was the fact that neither the Treasury nor the Inland Revenue participated in the Shipping Working Group,[167] which, given the subjects discussed in the Group, we find extraordinary. We regard the fact that the Treasury and the Inland Revenue did not participate in the Shipping Working Group deplorable, and believe that their failure so to do has unnecessarily delayed the proper consideration of the tonnage tax. We also believe that the evidence given to us by the Treasury was ill-prepared and inadequate.

78. An official from the Treasury told us that "if it is important to have a UK-owned merchant fleet and if it is possible to construct the right anti-avoidance regimes then I can see the advantage of a tonnage-based tax approach".[168] We have amply demonstrated the importance of supporting the UK shipping industry. The UK shipping industry is in a parlous condition, and radical measures are required to arrest and reverse its decline. We recommend that Lord Alexander's inquiry be brought to a close as soon as possible, and that a low rate tonnage tax, including measures to boost training of British seafarers, and to prevent tax avoidance, should be introduced without further delay, preferably as an amendment to the current Finance Bill.

The contribution of the Maritime and Coastguard Agency

79. One factor which might dissuade shipowners from registering in a country is the bureaucracy which must be satisfied to do so. In the past it has been felt that the authorities in the United Kingdom (originally the Department of Transport, then the Marine Safety Agency, now the Maritime and Coastguard Agency) have been obstructive: in its evidence to the Transport Committee in 1987, P&O complained of the "extra financial burden arising out of the pernickety requirements of Department of Transport surveyors".[169] Our witnesses cited examples, including the matter of the fire resistance of bulkheads. The international standard is that a bulkhead should be able to withstand fire for 60 minutes. In the past British regulations, rather than repeating the international standard, laid down exactly the sort of materials that must be used to meet the objective.[170] A shipowner cited another example of a vessel on which all fire-fighting equipment had to be replaced before it could be registered in the UK, simply because "they were not type-approved, although they were just as good or even better".[171] The Chief Executive of the Maritime and Coastguard Agency, Mr Storey, told us that the instructions to surveyors on how to inspect vessels were being improved and updated, in order to avoid such situations arising.[172] In some cases legislation will be required to remove superfluous regulations.[173]

80. Attempts have been made recently to make the Maritime and Coastguard Agency more helpful. The daughter document emphasises that "whilst it is clear that the maintenance of high professional standards is paramount, it is essential that the administration of the register is efficient, consistent and user-friendly".[174] Mr Storey, the Chief Executive of the Maritime and Coastguard Agency, reiterated that view, and told us about his efforts to introduce an ethos of 'customer service' to the Agency.[175] He believed that as a result approximately twenty ships had returned to the UK register.[176] Several of our witnesses applauded the Agency on its new attitude.[177] We commend efforts to improve the 'user-friendliness' of the UK register, without compromising safety, and recommend that they are continued. If necessary, we recommend that the Government should make legislative changes to assist the Maritime and Coastguard Agency, by removing unnecessary strictures from secondary legislation.

Short-sea shipping

81. As we have already observed, short-sea shipping is an important part of the function of the British merchant fleet. Nevertheless, much can be done to increase the amount of freight carried by sea, rather than by road, with its attendant environmental benefits. More could be done to increase the proportion carried on UK-registered vessels, with the positive economic impact that would have, and the certainty about the safety of the ships around our coast that it would bring. We were dismayed to learn that the proportion of 'coastwise' cargo[178] carried by UK-registered vessels had fallen from 35 per cent in 1993 to 24 per cent in 1996.[179] Since we strongly support the transfer of freight from roads to coastal and short-sea shipping routes, we are clearly in favour of Actions 27 to 33 of the daughter document which have a similar objective.

82. We raise two concerns, however, about Action 30, which commits the Government to "ask the Commission for Integrated Transport to consider the case for allowing 44 tonne lorries for general use".[180] Since the Commission for Integrated Transport has not yet met, and is only in the earliest stages of being established, we are concerned that consideration of this proposal may be delayed. We trust that the Commission for Integrated Transport will be speedily set up, and turn its attention to the subject as a matter of priority. We also note the evidence of F T Everard and Sons Limited, a shipping company engaged in the coastal and short-sea trade, which told us that the existing 44 tonne lorry concession for transport movements to railheads should be extended only to similar movements to ports.[181] F T Everard suggests "an inland mileage limit ...—as the purpose is to encourage the regional longer sea routings—in order to safeguard [against] abuse".[182] We agree. We do not believe that generally relieving existing restrictions on the use of 44 tonne lorries will encourage greater use of short-sea and coastal shipping. We therefore recommend that the 44 tonne lorry concession should be extended only to travel to and from ports.


83. We noted that most of our witnesses focussed on the recommendations of the Shipping Working Group and thus on the proposals of the daughter document, British Shipping: Charting a new course. All hopes seemed to be pinned on the tonnage tax as the only panacea for the shipping industry. We believe that the Chamber of Shipping and others should continue to formulate other policies which would assist the industry. For example, two matters were raised which were not included in the daughter document, and which we considered in detail. One was the application of the Foreign Earnings Deduction tax concession to coastal and short-sea shipping, and the other was road-user charging.

Foreign Earnings Deduction

84. The Foreign Earnings Deduction (FED) means that the income of anyone employed aboard a ship is free of income tax provided that they spend at least half of each year outside the United Kingdom, and not more than 183 consecutive days here each year. The Inland Revenue described this as a "generous relief".[183] Its purpose is to "provide support for the use of UK crew on UK-owned deep sea vessels which might be of strategic value in time of war".[184] It also obviously encourages the employment of British seafarers. As such, we support the existing system of Foreign Earnings Deduction tax relief for UK seafarers, and recommend strongly that it be retained. We do not, however, believe that it goes far enough.

85. F T Everard and Sons Limited pointed out that seafarers employed on their vessels, which are mainly engaged on coastal and short-sea routes, were not away from the United Kingdom for long enough periods to qualify for tax relief under FED. It therefore found that some of the seafarers it trained would, once qualified, take jobs with foreign companies, with whom they could obtain FED relief. This acted as a disincentive to continue to train crews. Furthermore, since foreign Governments offer similar forms of tax relief to their seafarers, it would be cheaper for companies engaged in the short-sea and coastal trades to employ foreigners, since they could be paid a lower wage which would be tax-free.[185] As a result F T Everard now flies in about twenty Canadian officers to work on its coastal tankers. The company also pointed out that many of its coastal tankers were also considered 'strategic', since they are "very sophisticated vessels and you need people to be trained to a very high standard in order to run them".[186] Nevertheless, the crews of such vessels do not qualify for FED.

86. We believe that it is absurd that a situation exists in which UK shipowners are discouraged from training British seafarers, and British officers serving on UK-owned vessels operating mainly around our coast are displaced by foreigners, particularly since, as we have seen, coastal and short-sea shipping is becoming the dominant part of the UK's shipping industry. The benefits of ending such a situation are self-evident. F T Everard suggested that a possible solution might be to extend FED to all seafarers who sleep aboard ship, whether within a UK port or not, for more than 183 days a year.[187] Whilst we acknowledge that there may be difficulties with adopting precisely that proposal, we recommend that, as a matter of urgency, the Government should consider how best to end the anomaly concerning the non-application of Foreign Earnings Deduction to British seafarers engaged in the short-sea and coastal trades. Its objective in doing so should be to encourage the employment of British seafarers in those vessels which operate close to our coasts.

Road user charging

87. F T Everard and Sons Limited also raised the subject of road user charging, although it did not recommend its introduction. It pointed out that "road transport does impose 'external costs' whilst shipping, with its unlimited highway, has the lowest external costs in relation to degrading the environment ... and it is generally much less fuel intensive".[188] We also note the study carried out by Oxford Economic Research Associates, which concluded that Heavy Goods Vehicles do not pay the full social and environmental costs, including road damage, of moving cargoes.[189] This gives road-users an unfair advantage over shipping companies. We have made comments about road user charging in our recent report on the Integrated Transport White Paper,[190] and we do not repeat them here. However, we reiterate that, particularly by comparison to road transport, short-sea and coastal shipping is an environmentally-friendly means of moving freight, and that the Government should take whatever steps are needed to encourage freight to be carried by sea. We recommend that the Commission for Integrated Transport should consider the matter as a high priority.

121   The Chamber of Shipping, NUMAST, the RMT, the Transport and General Workers Union, the Department for Education and Employment, the Department for Social Security, the Department for Trade and Industry, the Foreign and Commonwealth Office, and the Ministry of Defence. Back

122   British Shipping: Charting a new course, pp.25, 29, 34 and 36. Back

123   British Shipping: Charting a new course, para.87. Back

124   British Shipping: Charting a new course, para.89.. Back

125   See British Shipping: Charting a new course, para.90. Back

126   British Shipping: Charting a new course, Action 4, p.26. Back

127   Action 5, p.27. Back

128   Action 3, p.26. Back

129   Q.229; see also QQ.221 to 228. Back

130   See British Shipping: Charting a new course, para.91. Back

131   See British Shipping: Charting a new course, Actions 8 and 9, p.28. Back

132   Government Observations on the First Report of the Committee, Session 1987-88, Second Special Report of the Transport Committee, HC (1987-88) 681, p.vii; see also Q.184. Back

133   Q.90. Back

134   British Shipping: Charting a new course, Action 12, p.30. Back

135   See, for example, FUS21, p.5, FUS 1, p.8, and FUS 17, para.5. Back

136   See British Shipping: Charting a new course, para.104. Back

137   See FUS21, p.8. Back

138   See British Shipping: Charting a new course, Action 15, p.32. Back

139   See Q.372. Back

140   See Q.377. Back

141   See Q.383. Back

142   British Shipping: Charting a new course, para.117. Back

143   British Shipping: Charting a new course, Action 20, p.34. Back

144   As stated in British Shipping: Charting a new course, Action 21, p.34. Back

145   See Q.491. Back

146   British Shipping: Charting a new course, Action 22, p.34. Back

147   See HC Deb, 14 December 1998, col.606. Back

148   See Q.492. Back

149   See Q.496. Back

150   Q.164. Back

151   British Shipping: Charting a new course, para.121. Back

152   See British Shipping: Charting a new course, Chart 5. Back

153   Q.165. Back

154   Figure taken from FUS 21, p.3. Back

155   Q.354. Back

156   Q.443. Back

157   Q.264. Back

158   FUS 21B, p.5. Back

159   FUS 21B, p.5. Back

160   Q.680. Back

161   British Shipping: Charting a new course, Action 23, p.35. Back

162   HC Deb, 9 March 1999, col.177. Back

163   HC Deb, 9 March 1999, col.177. Back

164   Q.353. Back

165   See, implicitly, Q.610. Back

166   See Q.601. Back

167   Q.598. Back

168   Q.611. Back

169   Decline in the UK-Registered Merchant Fleet, HC (1987-88) 303-I, evidence, p.292. Back

170   See Q.531. Back

171   Q.278. Back

172   See Q.534. Back

173   See Q.534. Back

174   British Shipping: Charting a new course, para.127. Back

175   See Q.520 ff. Back

176   See Q.538. Back

177   See, for example, Q.274 and Q.278. Back

178   That carried from one UK port to another. Back

179   HC Deb, 26 April 1999, col.4wBack

180   British Shipping: Charting a new course, Action 30, p.38. Back

181   FUS 32, p.8. Back

182   FUS 32, p.8. Back

183   FUS 36. Back

184   FUS 36. Back

185   See FUS 32, p.9. Back

186   FUS 32A. Back

187   See FUS 32, p.10. Back

188   FUS 32, p.6. Back

189   Environmental and Social Costs of Heavy Goods Vehicles and Options for Reforming the Fiscal Regime, Oxford Economic Research Associates, 28 January 1999. Back

190   Integrated Transport White Paper, Ninth Report of the Environment, Transport and Regional Affairs Committee, HC (1998-99) 32. Back

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