Memorandum by the Road Haulage Association
Ltd (IT 17)
THE INTEGRATED TRANSPORT WHITE PAPER
The Road Haulage Association (RHA) was formed
in 1945 to look after the interests of haulage contractors in
various areas of the country, in effect, amalgamating local organisations
that had been established. The Association has subsequently developed
to become the primary trade association representing the hire-or-reward
sector of the road transport industry. There are now some 10,000
companies in membership varying from major companies with over
5,000 vehicles down to owner-drivers.
The RHA welcomed the Government's announcement
that, following an extensive consultation exercise, it intended
to produce an "Integrated Transport White Paper". The
Association considered this to be an extremely valuable opportunity
for the Government to draw together and expand upon the policies
that had developed under the previous administration and to set
the policy framework for the next 20 or so years. As such the
exercise presented an ideal opportunity for interested parties,
such as ourselves, to submit their views on the full range of
issues. A copy of the summary of the RHA's response to the consultation
is attached for reference.
There is much in the White Paper that the RHA
welcomes: indeed many of the new commitments mirror the recommendations
the Association made in its response to the consultation. For
example, the greater emphasis on road maintenance and making better
use of existing infrastructure, the introduction of impounding
for illegally operated goods vehicles, and giving priority to
certain types of traffic in specific locations.
Despite this, however, the RHA remains concerned
that ultimately the White Paper will not live up to expectations
and may prove to be little more than "fine words and good
intentions". The primary reason behind this view is the apparent
lack of new resources for spending on transport. At the time of
the Comprehensive Spending Review (CSR) there was much debate
within the transport world about whether or not the revised plans
did actually result in any increase in resources available for
investment in transport. In reality, it seems that there is actually
very little new money, most of the increase coming from a reduction
in the funds drawn by rail operators. DETR is however to be allowed
to keep the revenue raised from the various privatisation initiativesthat
in itself is a welcome development. But overall the RHA believes
this situation will mean that the transport budget is far short
of being able to fund the infrastructure projects and other measures
that will be necessary to develop a truly integrated system capable
of accommodating the transport needs of the UK for the coming
In addition to the comments on investment, the
RHA has been concerned by recent suggestions in the media that
legislation to enact the policies outlined in the White Paper
has been put on hold for the foreseeable future. Obviously there
are a number of measures that can be developed relatively easily
without the need for legislation. However, the policies which
are expected to have the greatest impact on transport usefor
example powers to introduce road user charges, the establishment
of a Single Rail Authoritydo indeed require new legislation.
Whilst the smaller scale policies may have a positive impact,
the true benefits of the White Paper can only be brought about
by a combination of a number of new policy measures. Without legislation
therefore, the demand for and use of the transport system within
the UK is unlikely to be influenced to any great extent. Thus
the White Paper will have changed the transport situation within
the UK very little.
The key achievement of the White Paper in this
area was the final abandonment of the "predict and provide"
approach to road transport which had been pursued since the Department
of Transport was first established and which reached its zenith
with Cecil Parkinson's "Roads to Prosperity" wish list
in 1990. Policies are now focussed much more on managing demand
and making better use of existing infrastructurean approach
which is welcomed by the RHA.
We are concerned however that at a more detailed
level, the Government's approach leaves some issues unaddressed
and that problems will arise when the policies are put into practice.
For example, it is entirely sensible that we should not automatically
assume that congestion problems should always be solved by provision
of new road infrastructure and that other solutions (e.g., public
transport alternatives) should be considered at the same time.
Therefore we understand the Government's decision (as outlined
in "A New Deal For Trunk Roads in England") to accept
37 road schemes but to reject a large number of the others on
the basis that local authorities should consider alternative solutions.
This decision carried with it the added benefit to Government
of allowing a reduction in the financial resources allocated within
the DETR budget.
However, the RHA believes that there is a fatal
flaw in the approach. It has been assumed that because certain
road schemes have been removed from the roads programme, the funds
can be taken out of DETR's spending commitments. But simply dropping
a road project does not obviate the need for a solutionthe
problem does not simply disappear. The local authorities that
are required to re-examine the problems will inevitably need resources
to fund whatever alternative solution they identify as being most
suitable. In some cases, an alternative non road-based solution
may well be identified, although we suspect that in many cases
the result will be the reinstatement of a road scheme. But in
either situation, the solution will require additional financial
resources. In the absence of funds from central Government, such
solutions are unlikely to be brought forward very quickly. The
result will be worsening congestion in areas already identified
as having a significant problem.
The RHA has taken the view that some form of
road user charging is perhaps the only policy tool with the potential
to discourage "unnecessary" road journeys to any significant
extent. Since the RHA believes that ultimately it will be necessary
to ration road space (giving priority to essential users) we are
disappointed that the decisions in this area seem to have been
pushed into the next Parliament.
In the White Paper, the Government clearly re-stated
its commitment to pricing and announced that it would issue a
consultation document with proposals for how road user charging
schemes should operate; introduce legislation to give powers to
local authorities to develop schemes for their areas; and develop
pilot schemes for monitoring purposes. No timetable was given
for the consultation and legislation appears now to be some considerable
time away. With a much smaller road building programme and the
prospect of few alternative solutions coming on line (due to lack
of funds as outlined above) congestion will inevitably increase
across the country. This carries serious implications both for
the UK economy and the environment and is a major cause of concern
for the RHA and its members.
The RHA is pleased that the Government avoided
the many pitfalls associated with allowing a maximum weight of
40 tonnes on five axles only for vehicles involved in international
journeys. Such a decision would have been impossible to enforce
effectively and would have put UK operators at a distinct disadvantage
compared to EU operators.
We were however, disappointed that the Government
decided only to allow 41 tonnes on six axles rather than 44 tonnes.
Whilst we understand the Government's rationale for the decision,
the RHA believes that the case for 44 tonnes is very strong. It
is important to recognise that it is not the haulage industry
that determines the volumes of goods that are carriedindustry
and consumers decide. Therefore we do not believe that increasing
the maximum weight would lead to an increase in lorry journeys
as some have suggested. Indeed, it is likely to be quite the opposite.
For bulk carriers (e.g., grains, aggregates, waste, liquids, etc.)
which "weigh out" before they "bulk out",
the introduction of 44 tonnes on six axles with road friendly
suspensions would allow them to carry more goods per journey.
Less lorry journeys therefore would be needed and because the
vehicle would be no bigger and would have road friendly suspension,
the impact on the environment would be less than if the same amount
of goods were carried in 38 tonne (or 40 tonne) vehicles with
five axles. In view of this, the RHA believes that not
allowing 44 tonnes makes no sense in environmental terms. We are
pleased therefore that the issue will be considered further by
the newly created Commission for Integrated Transport.
However, equally as important to our members
as the decision on maximum weights, is the Vehicle Excise Duty
(VED) rates that will apply to the new categories. RHA members
have been waiting for some time for these decisions to be takenthe
original consultation concerning maximum lorry weights was conducted
prior to the General Election. In the absence of a decision, many
hauliers have simply put their purchasing decisions on hold. The
Government's announcement in the White Paper goes some way towards
solving the hauliers' dilemma, but until the VED rates have been
announced our members are still unable to take decisions about
which vehicles will make the most commercial sense.
In the White Paper the Government stated clearly
that it wished to encourage the use of six axled vehicles (based
on the argument that they are more environmentally friendly) and
would set VED rates to reflect this position. If rates for the
new categories are calculated using the current system (based
on axle loadings) this implies that the rate for a 40 tonne vehicle
on five axles will be extremely high. Estimates have ranged from
£7,500 to £9,500 per annumsome 10 to 12 times
the rates that apply in many other EU countries.
The prospect of such uncompetitive rates in
addition to by far the highest diesel duty rates in the EU is
alarming UK hauliers. Their concern is at such a level that many
are considering "Flagging out"i.e., registering
their vehicles abroad whilst operating within the UK under cabotage
arrangementsto enable them to take advantage of lower costs.
In response to members' concerns, the RHA is actively researching
the practicalities/legalities of "flagging out" and
although our inquiries are at a relatively early stage, we do
believe that it will be a practical proposition for certain operators.
Such action is likely to be most attractive to companies whose
operations attract costs that are significantly higher in the
UK than would be the case elsewhere in the EU (for example companies
operating 40 tonne, five axled vehicles). Clearly if this were
to occur on a large scale, the implications for the UK businesses
and the economy as a whole would be very significant.
As outlined at the beginning of this Memorandum,
the RHA welcomes the fact that the Government has produced the
first Transport White Paper for nearly 20 years. We believe also
that the exercise has been very valuable in encouraging interested
parties to think more broadly about the transport problems and
solutions within the UK. The resulting document should be commended
for many things, including the fact that finally we have a comprehensive
statement of the Government's views on various policies and measures
set out in a straightforward manner.
However, the RHA cannot help but feel that overall,
a great opportunity has been missed. We share the view of many
other organisations in believing that in order to bring about
a real improvement to the transport situation in the UK, or to
exert significant influence on the ever increasing demand for
travel, a truly radical approach would be required. Sadly, we
do not believe that "A New Deal For Transport: Better
For Everyone" delivered such an approach.