Memorandum by the British Retail Consortium
INTEGRATED TRANSPORT WHITE PAPER INQUIRY
BRC, in responding to the Environment, Transport
and Regional Affairs Committee's invitation for evidence for the
Integrated Transport White Paper Inquiry, would like to highlight
the following key issues:
BRC would like to emphasise that
retailers want to be involved in quality partnerships to reduce
the environmental impacts of retail transport issues; involving
customers to stores, employees to stores and freight movements.
The key to the success of congestion
charging and a work place parking tax will lie with the local
authorities. Business input is essential, from all the different
sectors, so that their concerns are taken onboard at an early
stage and they are able to deliver the policies set out in the
transport plan in partnership with the local authorities.
The majority of congestion is created
by non-shopping trips, commuters, work-related driving and school
runs. A recent Lex Report (Lex Report on Motoring) stated that
shopping is a minor element in the cost of congestion with the
overall cost of congestion at around £10.4 billion. This
figure is broken down as such, with work driving accounting for
£8.3 billion, commuting £1 billion, school runs £0.6
billion and shopping only £0.5 billion. BRC believes that
measures which attempt to alter travel behaviour will only be
successful if there is alternative public transport provision
in place. In order to avoid damage to the vitality and viability
of town and city centres, road charging schemes must be time sensitive,
so as not to penalise the user, (for example a short stay visitor
or shopper) outside of the peak hours of congestion, in the morning,
and at the end of the working day.
There have only been limited pilot
schemes on congestion charging. One such example took place in
Leicester. Any future pilots must be on a larger scale and the
social, environmental and economic impacts of these pilots must
be measured to assess their success. The retail sector would welcome
appropriate involvement in further pilot work.
Support for work place parking taxes
will be greater if all the money raised is hypothecated for transport
matters, with no exemptions, including the public sector. While
this new tax will result in additional revenue to invest in transport
provision, attention should be paid to the implications for employee
and employer taxation, such as disincentives built into the system
which discourage the promotion of alternatives to car use.
BRC was concerned that the White
Paper did not deal with delivery curfews. Delivery curfews currently
force freight on the road network at the peak congestion hours
Alleviation of delivery curfews (allowing night-time deliveries)
is one significant way of reducing congestion during the busiest
parts of the day. In turn, retailers will minimise disturbances
to residents. For example over 40 per cent of Safeway Stores plc
stores are affected by night-time delivery curfews of between
6 and 16 hours.
BRC is pleased that the White Paper
recognises the `Delivering the Goods', a joint initiative on urban
distribution by the Local Government Association and the Freight
Transport Association. BRC believes that this is an important
area and we are pleased that the Government will promote the development
of Quality Partnerships for freight between the road haulage
industry, local authorities and business.
The British Retail Consortium (BRC) represents
90 per cent of the total retail trade in the UK, operating in
excess of 290,000 shops and stores, occupying over 30 per cent
of commercial property portfolio by floor space and employing
about 2.9 million people, some 11 per cent of the workforce.
Membership covers all forms of retailing, from
the large multiples and department stores, through to the corner
shop, from food and drink to furniture and DIY, from centre of
town to rural, to mail order and machine vending.
Retailing is a major engine of employment growth
in the economy, creating 126,900 net new jobs in 1997.
Transport is vital to the success of the retail
industry, not only for shoppers going to the stores, but for freight
deliveries and also for the staff going to work at the stores.
Retailers accept that they have an important role, along with
certain responsibilities in the transport debate. Retailers have
specific requirements from the transport system and want to work
with Government and Local Authorities to ensure these occur. Retailers
have been extremely innovative in the transport field over the
past few years, and will continue to be so.
Retailers ensure that they use the transport
system as effectively as possible, developing innovative methods
of sustaining the environment while at the same time meeting their
essential transport needs.
This response considers the four key areas for
the retail industry mentioned in the White Paper:
Movement of shoppers to stores.
Movement of workers to stores.
BRC believes that there must be local solutions
for local problems. Transport requirements around the country
vary greatly and one prescribed solution for all will not work
in every location. We caution against applying London solutions
to areas which are totally different; London has its own distinct
transport problems. Retailers need to be involved during the formation,
refinement and operation of transport plans so as to ensure that
the plans are realistic and achievable.
Local Transport Plans
The local transport plans will be the key to
the success of the White Paper. BRC urges the Government to involve
business, including retailers in discussions on these plans. It
is essential to have a national framework for the development
of the local transport plans.
BRC believes that the Local Government Association
(LGA) should play the lead role in guiding the 400 plus Local
Authorities, disseminating best practice. BRC is, however, concerned
about the varying degrees of understanding shown by the Local
Authorities on transport issues, depending on location in the
country. We are also concerned about, how in practice, the links
will be drawn between the policies contained in local development
and county structure plans, with those set out in the local transport
plan. One example will be the timing of adoption, reviews and
Local Authorities will be involved in the implementation
of the proposed congestion charging schemes. BRC would support
the concept of congestion charging as long as it: achieves what
it was set out to achieve, namely to reduce congestion; and, was
time sensitive for the peak congestion periods, with the actual
monies raised hypothecated for transport measures. BRC would,
however, be concerned that such a scheme would affect the vitality
and viability of a town centre if it were not time sensitive.
Through such a scheme, town centres would suffer, in direct contravention
of Government policy (as set out in PPG 6).
Congestion charging is a useful tool if there
are other alternative forms of transport available, for example
changing commuters' travel movements from car to the bus or train.
BRC believes that the congestion charging pilot schemes must be
analysed for their economic, social and environmental costs. BRC
has followed the trials on the A646 near Leeds, with the high
occupancy vehicle (HOV) lane and road pricing trial in Leicester
involving council staff. These have only been small scale studies
and the problems found with these schemes need to be taken on
board and assessed. However, such trials can be useful, for example
through the testing of IT requirements.
BRC believes that congestion charging links
in with delivery curfews. Presently retailers have no option but
to have their deliveries take place at peak times. In many cases,
this is due to the night-time and dawn delivery curfews being
in place. Retailers, therefore, are being forced to deliver at
the peak times when they would prefer not to deliver. If congestion
charging was introduced, it would directly affect these retailers.
Research recently completed by Healey &
Baker has found that Local Authorities have been doing little
to penalise motorists who have been driving into town centres.
In fact, they found that many small centres (32 per cent) were
positively encouraging cars by increasing their number of car
parking spaces. This is at odds with the White Paper, but helps
to illustrate the dilemma that Local Authorities face. They are
in a competitive situation, with neighbouring town centres vying
for business from the others. For example, a town offering free
parking should be able to attract more custom when a neighbouring
town charges for its parking.
Retailers are invariably the catalyst for regeneration
of town centres and more Local Authorities need to understand
this. The issue of parking features heavily in PPG13 (the planning
policy guidance note on transport) and we understand that this
guidance will be subject to review in due course.
Retailers are absolutely dependent for their
livelihood on shoppers being attracted to their stores, which
links in with them requiring an efficient and reliant transport
system. Shopping has a minimum effect on congestion, the Lex Report
mentioned earlier calculated that shopping only accounts for £0.5
billion of the £10.4 billion overall cost of congestion.
Invariably shopping takes place outside of the peak congestion
periods in the early morning and evening, which has been helped
by longer trading hours. The Government's own figures indicated
that shopping only accounted for 12 per cent of the distance travelled
per person between 1994 and 1996.
For a family of four, the average weight of
their week's food shopping is 80lbs (six bags of shopping) which
is very difficult to carry on public transport. This also applies
to other bulky goods. This is why most families prefer to complete
one large food shop a week, which is better for the environment,
and makes economic sense for them to use their car for such trips.
About 74 per cent of shoppers use their car to go shopping, and
for many it is a lifeline, especially true for those in remote
Park and Ride and Free Bus Services
Retailers acknowledge that they have a part
to play in reducing car movements to their stores, hence the number
of park and ride schemes and the operation of bus services to
their food stores. For example Tesco spent over £3 million
last year on 100 different free bus routes services for customers,
with a view to providing access for pensioners and people without
cars. Many of their stores have a free-phone link with local mini-cab
companies, which also helps non-drivers.
Park and Ride schemes have had varying degrees
of success, invariably being most successful in historic towns
and cities, such as York. BRC supports such schemes but admits
that there are certain limitations with them, and they are not
appropriate in every area. It is important that with such schemes
there is good practice in place and that they meet the customer's
requirements, for example sufficient shelters, regular service
and secure car parking.
Retailers acknowledge that cycles are a good
environmental option to the car, and are involved in increasing
the use of bicycles by shoppers. For example, Safeway Stores plc
has trialled cycle trailer hire schemes at selected stores across
the country; Tesco plc has introduced a bike hod trailer scheme
at its Chichester store, which is jointly run by Chichester District
Council; and J Sainsbury plc has recently launched a pedicab service
in North London. Most food retailers have secure bike racks at
their stores. However, for many customers, managing a cycle while
carrying a heavy shopping load is difficult and dangerous.
Home delivery is seriously being tested by many
of the food retailers, however, home delivery will potentially
have a limited impact on shopping trips, particularly mixed journeys,
for some time to come. Home delivery has certain disadvantages:
there will often be a mismatch between when the customer can be
at home and when the retailer can deliver. This means that deliveries
have to be time sensitive with at the most two hour slots when
the food can be delivered; if there is no-one at the house when
the food is delivered, then in most cases (certainly for perishable
items) it cannot be left on the doorstep.
Small vans have to be used due to the deliveries
being in residential areas, where larger vehicles could not operate.
The time sensitive nature of the deliveries makes it difficult
for these vans to be loaded to full capacity when delivering and
they have to make more journeys to and from the store with new
deliveries. These vans would also create extra congestion as most
deliveries are requested at the peak hours.
Many families also prefer to inspect produce
before purchasing, for example with fresh fruit to see that they
are ripe, and also to look at what new products are currently
available for them to buy.
Some of those retailers involved in home delivery
include the following: Iceland offers a free home delivery service
for customers who spend more than £25 in the store with plans
to become the first supermarket group to launch a nation-wide
home delivery service. Marks & Spencer will deliver shopping
from 20 of its stores for an additional £5. It also operates
a home delivery service for wine, flowers and Christmas hampers.
Somerfield will deliver shopping free from 38 of its stores if
the spend is over £25, and it is hoped to be extended to
more next year. Waitrose offers free home delivery for flowers.
Wine orders over £75 are also delivered free. Sainsbury's
orderline is currently on offer in 13 of their stores to Reward
cardholders. This scheme allows shopping to be ordered via the
Internet, phone or fax, with the order being collected from the
store for £3.50. Sainsbury's will also deliver it the following
day for £5.
Retailers rely on their staff being able to
get to work on time. The actual hours of work by retail staff
is no longer 9am-5pm, but has become much more complex, with some
stores now open around the clock, with shift patterns in place
and part-time workers to cover peak periods. Stores also have
night-time workers to do such things as re-stocking shelves and
carrying emergency maintenance to stores. Retailers aim to reduce
the amount of car movements created by the staff and a number
have implemented policies to deal with this. For example, The
Body Shop offers bicycle loans to its staff, at HMV music stores
employees can buy bicycles at a 10 per cent discount and spread
the payments using an interest-free loan up to £500.
Green Transport Plans
Green Transport Plans are being considered by
retailers not only at their head offices, but also at their stores.
Many currently have ad hoc plans which are being developed so
as to be extended across the country. The Boots Co. plc has introduced
a commuter plan to reduce car commuting to its Nottingham headquarters
by 10 per cent over three years and a further 10 per cent over
the subsequent five years.
With staff at stores working a number of different
shift patterns the ability for them to use the public transport
system to get to work is severely hampered. Sometimes they are
left with no alternative but to use their car, unless they are
travelling where there is a regular public transport service that
runs not only at peak periods, but also outside those times. Retail
staff are particularly concerned when travelling home at night,
the safety aspect of the public transport system is crucial to
them. There is perhaps, a need for them to pool experience with
green transport plans to promote good practice.
Work Place Parking Tax
The White Paper advocates the introduction of
work place parking taxes. BRC notes that companies already pay
rates for their car parking spaces, and so this would be a further
tax. BRC believes that such at tax would have some merit, if it
would affect all of industry and commerce. However, it is key
that all the money raised from such a tax is ring fenced
for transport matters, with no VAT going to the Treasury (VAT
exempt or refunded). BRC is adamant that the public sector lead
by example. BRC would like clarification on who would be expected
to pay for the spaces, either the car user or company. If the
company was to pay for the space, would this then be classed as
a benefit for the individual? BRC calls for greater clarification.
Deliveries are vitally important to the success
of the retail industry. Most companies use state of the art logistic
systems in order to manage vehicle scheduling and to ensure just
in time deliveries, therefore eliminating the need to have large
amounts of stock permanently held in store (enabling retailers
to operate from smaller premises) and also reducing the number
of vehicles on the road. The advent of the Regional Distribution
Centres (RDCs) has ensured that the number of deliveries by individual
suppliers direct to stores has fallen considerably. For example,
in 1985 a Safeway store received on average 250 deliveries a week.
With the arrival of RDCs the average Safeway store now receives
only two or three RDC deliveries per day. It is also worth noting
that commercial vehicles over 3.5 tonnes account for only 2 per
cent of the total vehicle population.
BRC is concerned that the White Paper although
acknowledging lifting delivery curfews would alleviate congestion
in the morning and afternoon peak hours, fails to offer practical
assistance with this major problem. Retailers want to be able
to deliver outside the curfew times, if they were able to do so
then it would alleviate congestion.
The growing number of curfew restrictions means
that essential road freight is being squeezed into the busiest
parts of the day, adding to congestion. BRC is pleased that the
Government has noted the "Delivering the Goods", a joint
initiative on urban distribution by the Local Government Association
and the Freight Transport Association.
As a consequence of these delivery curfews,
retailers have had to use more tractors and movements than actually
necessary. For example Safeway has had to increase its fleet by
up to 100 additional tractors and 170 additional trailers. The
removal of curfews would see the Safeway tractor and trailer fleets
reduced by 15 per cent. Moreover, these deliveries are having
to take place during peak travelling times, stop-start travel
during the day reduces fuel economy by about 10 per cent. Time-shifting
of freight transport is, therefore, key to the success of an integrated
Modern vehicles are much quieter than their
predecessors with technological improvements including quieter
refrigeration systems, scissor lifts instead of tail lifts, air
brake silencers, reversing alarm/automatic cut out, smoother running/rubberised
surfacing trailer floors and cab radio automatic cut out. Driver
and staff training is also carried out to ensure that noise is
kept to a minimum. The argument that retail road freight is noisy
is then somewhat lessened.
Back Haul Operations
Retailers are at the forefront of ensuring that
they are not running empty lorries back to their RDCs. Electrical
retailers, after delivering new white goods such as fridges, take
the old ones away. Safeway Stores plc is attempting to eliminate
spare capacity in its returning delivery vehicles through back
haul operations. Now after delivering to the store, a lorry may
often collect goods from nearby suppliers and bring them back
to the depot, saving suppliers a journey and supporting the local
economy. Each year 60 million cases of products are back hauled
by returning delivery vehicles from over 100 suppliers cutting
distance travelled by suppliers 13 million kilometres. Tesco plc
has recently introduced an Integrated Logistics Management campaign
which involves supplier collection. Tesco plc lorries now use
the return journey from store to depot to collect a load from
a supplier. This has cut three million miles, increased vehicle
utilisation by 20 per cent and reduced carbon dioxide emissions
by 4,600 tonnes. Boots the Chemists plc has pursued a policy of
using vehicles to backload goods from their retail outlets and
from suppliers. Currently over 80 per cent of their vehicles returning
from their Distribution Centres are being utilised.
Retailers are considering other modes of freight
transport, primarily rail. Where it is a viable alternative retailers
will consider the rail system. However, this is usually only appropriate
for long distance distribution, for example from European suppliers
to Regional Distribution Centres (RDCs). Rail freight is not suitable
for the transportation of time critical products, those with high
value and for distances of less than circa 200 miles. For example,
Tesco Stores Ltd moves around 5 per cent of its total freight
by rail. J Sainsbury plc and Safeway Stores plc have recently
committed themselves to using rail transport for the distribution
of goods within the UK. Safeway Stores plc was the first retailer
in the UK to move volume products by rail. In the last 12 months
they have taken 375 lorry movements off the road and replaced
131,000 road kilometres with rail. BRC calls on Local Authorities
to understand that rail freight is only an alternative in limited
circumstances and capacity will take time to grow.
Retailers are heavily involved in trialing and
running their vehicles on alternative fuels. In late 1997 Marks
& Spencer unveiled vehicles powered by liquefied gas, these
vehicles emit a third of the level of nitrogen oxide and offer
an 89 per cent reduction in particulates compared with a conventional
diesel truck. Boots the Chemists plc over the past three years
has trialled the use of both ultra-low sulphur diesel and LPG.
Safeway Stores plc operates one of the largest HGV Compressed
Natural Gas (CNG) fleets in Europe servicing 50 stores in London
and the Home Counties. These quieter vehicles have seen a reduction
in Carbon Monoxide (CO) by 97 per cent, Total Hydrocarbons (THC)
by 81 per cent and Particulate Matter by 94 per cent compared
to a Euro 2 diesel engine. Retailers are being hampered in their
progress in this area due to the lack of a national re-fuelling
infrastructure for any of the new fuels. BRC would like to see
the Government becoming more involved in this area, setting a
clear policy for the use of such fuels.
Retailers have invested much in reducing vehicle
use and in employing new technology, and we are sure much of this
expertise may be transferable to other sectors of industry as
part of the push for greater UK competitiveness.
The retail industry is a key component in the
national economy and is totally dependent on an efficient transport
network. Therefore, we welcome the publication of the White Paper
and we are committed to working with central and local government
to achieve improvements that will benefit all users of the system.
However, we must remain mindful of the need to develop practical
measures making the best of innovation and good practice, but,
also to avoid actions which may undermine investment opportunities
and job creation, particularly at the local level. That is why
we are so concerned about the possible adverse implications of
blanket congestion charging which may deter visitors and shoppers
from going into town and city centres, particularly where alternatives
to using the car will be some way off.