Memorandum by Chemical Industries Association
"A NEW DEAL FOR TRANSPORT:
BETTER FOR EVERYONE"
The Government's White Paper on the Future
1. In August 1998, following the publication
of the Transport White Paper in July, the Chemical Industries
Association (CIA) formed a small working group to look at the
issues it raised. The purpose of this ad hoc group has
been to seek an industry consensus on the main matters that affect
the chemical industry in particular, so as not merely to duplicate,
for example, the work of the CBI or Freight Transport Association.
2. Participation in this group included representatives
from the following range of British (or UK-based) chemical companies:
BP Chemicals; Shell UK; AH Marks (Bradford):
Solutia (Newport, Wales); Carless (Romford); Dow Chemical (Kings
Lynn); Ciba Speciality Chemicals (Manchester).
3. The CIA hopes that the Committee will find
the following comments useful. It offers them on the basis of
the policy set out in the White Paper itself, as, of the so-called
daughter documents, only the roads reviews for England and Wales
have so far been published.
4. The chemical industry is one of the UK's
most successful manufacturing industries with:
11.5 per cent of manufacturing output;
an average, annual trade surplus
of £4 billion;
240,000 direct employeesand
three times that number indirectly.
5. The Chemical Industries Association is the
predominant trade and employers' association for the industry,
with 200 members operating from 700 sites nationwide. The CIA
has close links with related organisations in the UK and co-operates
extensively with the pan European chemical industry federation,
6. To put our interest in transport into some
perspective, in 1997, 80 per cent of our members' manufacturing
sites reported distribution data to us, accounting for some 48
million tonnes of products distributed. In tonnage terms, 49 per
cent of this was distributed by road, 25 per cent by pipeline,
23 per cent by sea, 3 per cent by rail and 0.06 per cent by air.
7. We support the urgent need to reduce traffic
congestion, which would help industry by reducing delivery times,
but urge that this be done by taking steps to increase the attractiveness
of rail first, as an option for transporting freight, rather
than simply by penalising commercial road users per se
via motorway (and other road) tolls. Moreover, we believe that
road charges should be framed in such a way as to encourage free
use of the national road network at night, when it is currently
8. The industry recognises and welcomes the
importance of the emphasis placed by the White Paper on the role
of local debate and influence on local transport plans. However,
we are concerned by the degree of influence that local authorities
will have over the management of so much of the national road
network given the Government's substantial proposals for "detrunking"
large parts of it. We believe this may give rise to some strange
distortions in a country so relatively small as the UK. Broadly-speaking,
strategic traffic management should be dealt with at national
9. We welcome the requirement on the proposed
Strategic Rail Authority to ensure that the railway meets the
needs of freight customers, and that the role of rail freight
be promoted. Although investment in rail facilities currently
attracts grant assistance from the public purse, no allowance
is made for operating costs. Rail operators need a certain critical
level of volume before routes allow break-even operation. A critical
start-up gap therefore exists.
10. We support the development of Trans-European
Networks where they further European and UK transport objectives
and offer an additional incentive to transfer freight from road
to rail. In particular, we endorse the concept of the Transport
European Rail Freeways (TERF) as a means of facilitating freight
movements around the EU.
11. The industry notes that, however good the
rail freight network, there is no getting away from the fact that
where chemical plants are located some miles away from a railway
that lorries will be required to at least ferry products between
the plant and the rail head concerned. In addition, where the
potential rail leg of any distribution system is relatively short,
the economics of road haulage are always going to prove more attractive.
12. The intention to integrate ports with wider
transport networks makes good sense; it would make the choice
to transfer more freight from road to rail more attractive. In
the industry's experience, there are already good rail facilities
at the likes of Immingham, Felixstowe, Teesport and Thamesport.
On the other hand, facilities at Dartford, Purfleet, Tilbury,
Harwich, Hull and Dover are far less advanced. Given the traditional
concentration of the British chemical industry either side of
the Pennines, better rail links from west to east and the ports
on both sides could remove a considerable amount of traffic from
the overburdened cross Pennines motorway, the M62.
Canals, Inland Waterways and Coastal Freight
13. Generally, British inland waterways are
too small to facilitate freight traffic and many chemical plants
are physically a long way from the 200-year-old canal network.
Nonetheless, there are some areas where customers and suppliers
are linked by inland waterway and where use is already made of
this facility. The industry urges the Government to consider extending
its system of grants for rail freight facilities to the canal
and inland waterway system. Ship fees and dock dues have long
disadvantaged coastal freighters in favour of the ubiquitous lorry.
14. The industry is extremely concerned by the
ongoing increases in fuel duty, particularly on diesel, where
costs are already higher than on continental Europe. These trends
threaten to make the UK less competitive, especially as we are
at the western edge of an trade area growing to the east. We therefore
urge that Government give serious consideration to concessions
for the commercial use of petrol and diesel fuel.
15. The White Paper makes reference to the potential
for parking restraint strategies, including a local authority
levy on parking at the workplace. Such a move could have a serious
impact on the chemical industry, many of whose sites are, by nature,
located away from urban centres of population and include work
forces drawn from a wide area, with a significant number of shift
workers. These factors make chemical industry employees particularly
dependent on their own, private transport. In this regard, the
industry notes the exception already made for customer parking
at out-of-town shopping centres.
16. We can find no reference in the report to
the potential of additional pipelines for the transport of bulk
products, including chemicals. Has the Government considered this,
particularly the possible provision of incentives to companies
to construct pipelines as an alternative to road use?
Heavy Goods Vehicles
17. The continuing delay in the introduction
of 44 tonne HGVs is disappointing. We are sceptical, whatever
the new and attractive VED incentive, that the industry will wish
to move to six axle, 41 tonne vehicles, when they can currently
retain five axle, 40 tonne equivalents. Although we understand
the desire to see freight switched to rail, there is no need to
do this at the expense of the volume of traffic that will inevitably
remain road-based. In any case, the likely growth in the total
freight market over the next decade is about the same as that
segment aspired to by the rail freight operators.
18. In addition, some chemical industry products
are inevitably hazardous and, as such, debarred from transport
through the Channel Tunnel. We believe that for the more efficient
and safer transportation of such goods, a dispensation should
be given for 44 tonne lorries carrying such cargo overseas to
use roads throughout their journey, just as a dispensation already
exists for their use in combined rail/road application.
19. As the above comments indicate, the chemical
industry is broadly supportive of the proposals set out in the
Government's Transport White Paper. The industry's main transport
goals might be summarised as cost effectiveness, timeliness and
safety. In theory, the White Paper meets all those goals.
20. In practice, what concerns us is the news
that the legislation to implement some of these proposals may
be delayed until 1999-2000. This risks increasing short to medium
term congestion and upsetting the balance of the Government's
aim to balance its broader social, environmental and economic
objectives, bearing in mind that the former are absolutely dependent
on the latter.
Chemical Industries Association
24 September 1998