Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence


Memorandum by The Reed Boardall Group (RH 18)

  REED BOARDALL GROUP—ACTIVITIES

The Group's principal activity is the distribution of Frozen and Chilled Food from manufacturer to retailer with some 30 major customers and 3,500 product lines, handling 250,000 orders per year and over 100 million cases with a value in excess of £1 billion.

  We operate 150 Low Emission Vehicles and 67,000 pallet capacity -28C Cold Store on a 24-hour, 7 day week, 364-day year, with some 350 employees.

  We have the largest retail consolidation operation in the UK and are the only single site consolidating frozen supplies to all the top six supermarkets' Regional Distribution Centres. All our operations are ISO 9002 accredited.

FOOD DISTRIBUTION TO RETAILERS

  The ever-increasing cost of retail selling space has driven retailers to reduce stock holdings at point of sale to levels not much greater than the content of their cabinets and shelves. Initially this resulted in stock holdings being held at Regional Distribution Centres (RDC). However, further pressure on stock holding levels in order to reduce wastage and working capital and to meet the consumers' desire to have freshly-made product, even when frozen, has had the effect of removing much of the stock out of the supply chain altogether. Consequently this has imposed a requirement on manufacturers for more flexible production schedules with shorter runs and more deliveries of smaller quantities at specific times; a pattern of deliveries that mirrors sales at Retail Store level. Some Chilled Products are already being delivered twice per day and we expect Frozen Foods to follow within 12 months.

  Individual manufacturers cannot economically support this concept of making deliveries of small, time-specific quantities to RDCs every time Retailers' lower stock levels need replenishment. This need has been met by the growth of Companies such as ourselves, which over the last eight years has spent over £20 million on facilities and seen turnover grow from £2 million to £26 million.

  As a result of building a central facility, we are able to make frequent deliveries of a variety of products from a range of suppliers reflecting more closely daily Store sales. Day one order for day two deliveries are now commonplace; day one order for day one delivery is increasing.

  Labour and fuel represent over 50 per cent of our total costs of operations and it is these that are subject to significant change. For this reason they are the two issues on which we would like to pass comment.

GOVERNMENT POLICY—FUEL AND VEHICLE EXCISE DUTY

  Revenue raised from road users has increased 26 per cent in the last three years. Brent Crude oil price has doubled in the last year. Government spending on Transport has reduced; the structural conditions of the roads are the worst for 25 years. These are the headlines for the Road Haulage Industry.

  The present policy appears to be one of discriminating against Road Transport by increases in taxation in an attempt to increase costs and thereby decrease road use. The Policy of decreased use is not however holistic. Grant Aid to build production units in far-flung areas requiring substantial delivery journeys to markets continues apace. One is tempted to deduce therefore that fuel duties are not an instrument of Environmental Policy but a means of raising taxes.

  Nonetheless, the effect of ever-increasing taxes has been to:

    —  Keep UK Diesel Fuel prices at up to twice levels of those in other Member States of the EU.

    —  Increase continental vehicles on our roads, up 25 per cent in the first quarter of 1999. Vehicles which are not subject to our construction or inspection standards.

    —  Increase in "Flagging Out" to obtain tax cost savings.

    —  Create "Boot Legging" with diesel.

    —  Day Trips to France for a "fill-up" on cheap diesel.

    —  According to Customs & Excise traces of paraffin have been found in 25 per cent of all HGVs stopped for roadside checks.

    —  Consideration of building RCDs in Continental Europe to service stores in Southern England.

  A greater understanding of cause and effect of fuel taxes is necessary if they are to achieve their objective of reducing traffic levels.

  Road Fuel Taxes are an indiscriminate and blunt instrument of Policy. They tax equally those who use fuel in remote areas, where no alternative means of transport exist, and where base fuel costs are higher. They apply the same rate on use where lower base prices exist and where many choices of alternative forms of transport are available. Road Fuel Taxes fall on Commercial Traffic at the same rates notwithstanding whether the cargo could go by some other means or not.

  How can it ever be argued that Road Fuel Tax is a moral imperative to reduce Road Traffic?

  It is essential that the Policy Target of Reduced Road Traffic must be attained by a more effective and precise methodology.

GOVERNMENT POLICY—WORKING HOURS

  The UK Government Policy of Drivers working hours has been to give weight to road safety and avoid excessive hours. The EU on the other hand has added another dimension by reducing working hours hoping to increase numbers employed. This latter dimension has caused the recent troubles in the French Transport Industry.

  There is no distinction between employed drivers and Self Employed Owner Drivers.

  The operation of the law on drivers' hours requires a knowledge of what hours each driver has worked, had as rest periods, and driven over the past 14 days before another job may be given to him. The next job has to be considered in terms of hours and rest periods and given to the particular driver who has the working time available for its completion. One can imagine the demands of staff in a busy Traffic office with 250 drivers and 150 vehicles handling jobs being planned for same day or next day fixed delivery times. Many of the drivers are already off site making deliveries and into their working periods.

  In general terms it is now the EU that determines Working Hours Law and it is from this quarter that the proposal to further reduce hours that drivers may work has come.

  The proposal to restrict night driving and to limit the working week will have profound effect on the viability of all road transport operations and particularly those of us who are serving the Retailer with Food Products.

    —  Drivers will wish to retain the same total pay for fewer hours, more drivers will be required to complete the same tasks; a cost increase in the order of 20 per cent.

    —  As the same journeys will not be possible within a working day, this will entail more nights for vehicle and driver to be away from home. Sleeping in an £120,000 investment of vehicle and trailer that should be earning revenue will have a further effect on business efficiency. Restrictions on night driving will have a similar effect.

    —  The idea that these rules will not be applicable to Self Employed Owner Drivers will cause a considerable shift towards this method of providing tractive power. Competition will force Operators to employ Self Employed Owner Drivers at the expense of employed drivers.

  Once again the cause and effect has not been considered. The concept that road safety can be improved by reducing drivers' hours and cutting night working but excluding Self Employed Owner Drivers from those rules without competition forcing a shift towards Self Employed Owner Drivers shows a certain level of naivety. The initiative to move goods at night thereby reducing daytime traffic does not sit well with the concept of limiting drivers' hours at night.

FINAL COMMENT

  Consideration of Road Transport and the impact of Government and Regulation on Fuel Duty and Working Hours leave one with an apparent certainty.

  Any attempt at a coherent logical, consistent policy will conflict with the revenue raising opportunities created by everyone's desires and need to move or move products. The raising of taxes and transport seem to be inextricably linked. The sheer amount of tax revenue produced from this source puts the control firmly in the hands of the Treasury. Have we not increased taxation under the cloak of environmental protection?

  There is no indication that the Treasury will make sound Environmental Policy.

Keith Boardall
Group Managing Director

8 February 2000


 
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