Memorandum from Sea and Water
RESPONSE TO DEFRA'S CONSULTATION ON A MARINE
BILL
1. INTRODUCTION
1.1 Sea and Water welcomes Defra's consultation
on the principles and potential content of a Marine Bill. We support
efforts to create "clean, healthy, safe, productive and
biologically diverse oceans and seas" and outline the
views of the water freight industry in this response.
1.2 Sea and Water is the national body—sponsored
by the UK water-freight industry, the Department for Transport
and the Scottish Executive—charged with promoting transport
of freight by short sea shipping and inland waterways.
1.3 Our membership is drawn from all parts
of the UK water freight industry including ports, navigation authorities,
carriers and related services. Sea and Water was created to pursue
current Government policy and aspirations.
1.4 Water freight makes a major contribution
to the economy. More than 95% of freight by volume and around
75% by value is moved into and out of Great Britain by water.
Within the UK, 24% of freight (measured in tonne kilometres) is
moved by water. The industry employs more than 200,000 people,
and contributes at least £6.2 billion to the UK economy.
1.5 The water freight industry cares about
the environment within which it operates. Compared to alternative
transport modes, especially road transport, moving freight by
water is environmentally sustainable. Emissions generated by water
transport are considerably smaller than by road, and by switching
to water lorries are taken off the congested road network.
1.6 Yet the water freight sector faces considerable
challenges, and is not able to deliver to its full potential.
It therefore needs support from Government—both in terms
of resources, but at least as importantly, in policy terms. The
freight industry in turn will respond, as it has in the past,
by investing in wharves and craft to deliver coastal and inland
waterway services.
1.7 Sea and Water backs plans for a better
coordinated, strategic system of marine spatial planning, and
simplified regulation that is developed in a way which supports
the water freight industry. We welcome the opportunity to respond
to this consultation.
2. WATER-FREIGHT'S
CONTRIBUTION TO
THE UK
2.1 Overall, water-freight within the UK
achieved 59.4 billion tonne kilometres, 24% of total freight moved
in 2004. (DfT: "Waterborne Freight in the UK 2004").
A total of 550 million tonnes of cargo passed through GB ports,
of which 76% was international.
Table 1
VOLUME OF GOODS PASSING THROUGH GB PORTS
| Volume (million tonnes)
| Percentage |
| International | 420 | 76
|
| Of which unitised1 | 126
| 23 |
| Other dry goods | 125 | 22
|
| Bulk liquid | 169 | 31
|
| Between GB ports | 1142
| 21 |
| To/from elsewhere in UK3 | 16
| 3 |
| 550 | 100
|
| | |
1 Containers and trailers.
2 That is 57 million tonnes loaded and then discharged at
a different GB port.
3 N. Ireland, Isle of Man and Channel Isles.
(Source: Maritime Statistics)
2.2 The total value of goods shipped through UK ports
in 2004 was around £330 billion. Some 438 million tonnes
of freight was moved into and out of the UK in 2004. More than
95% by volume and around 75% by value of all international trade
goes by sea. In addition, some 130 million tonnes of goods passed
through GB ports, reflecting the movement of 73 million tonnes
of goods.
2.3 The UK handles more sea freight through its ports
than any other European country. This emphasises the vital link
between UK trade and water-freight. Without this movement by sea
the UK economy would stagnate and our way of life and standard
of living would be very different from today.
Table 2
VOLUME OF FREIGHT MOVED INTO AND OUT OF GREAT BRITAIN
BY MODE—2004
| Volume (million tonnes)
| Percentage |
| Water (ports) | 420 | 95.8
|
| Air | 2 | 0.5
|
| Road (tunnel) | 14 | 3,3
|
| Rail (tunnel) | 2 | 0.4
|
| Total international | 438 |
100.0 |
| | |
(Source: DfT, CAA, Eurotunnel. Excludes coastwise and one
port traffic through major ports).
2.7 Water-freight can be used to extend the length of
a sea voyage to make more use of regional ports. This reduces
the impact of new infrastructure on the congested south-east and
contributes to business growth in the regions.
2.8 Water transport also plays a vital role in linking
the GB mainland with island communities and Northern Ireland.
Excluding crude oil, in 2004, GB ports handled over 16 million
tonnes of cargo to and from these local economies. The more important
the role that coastal shipping plays in overall cargo distribution
within the country, the greater the effective connectivity these
relatively isolated island communities can enjoy. For example,
a port such as Aberdeen enhances the connectivity of the Shetlands
(with which it is linked by ferry) and provides good coastal shipping
links to English ports as well as to the Continent. Similarly,
coastal shipping links along the Irish Sea improve the connectivity
of other island communities through ports such as Liverpool.
Roll-on/roll-off ferries provide "lifeline"
freight and passenger services between Aberdeen and the Northern
Isles of Orkney and Shetland.
2.9 Current coastal shipping flows are illustrated in
the following maps (Fig 2 and 3) set against cargo flows on the
road and rail networks respectively, using the same scales to,
illustrate the different modes (source GB Freight Model[1]).
Coastal shipping can be seen to play a significant role already.
The volume of domestic cargo moved by sea in parallel with the
coast can be seen to be comparable with that carried on the most
heavily used railway lines and all but the busiest motorways.
2.10 Shipping offers a low cost mode of transport. Over
a distance of 250 kilometres, even a small "coastal"
container ship carrying only 100 containers offers a cost per
container of half that of road haulage before local road delivery
is taken into account. It follows that water-linked locations
offer a significant competitive advantage over inland sites for
a wide range of commercial activities. While this has been long
recognized by heavy industry such as oil refining and steel production,
it is less well understood by lighter industry and particularly
by the logistics industry. In an increasingly competitive world,
it is most important that Britain can offer locations to global
industries which not only minimize transport costs but also facilitate
low cost onward exports.
2.11 For this to be achievable requires an appropriate
environment: principally adequate development sites, to be available
to accommodate the opportunities available. Cost savings can be
significant. An inland location which both consumes (a proportion
of) imported components and exports (a high proportion) of output
will face costs of several hundreds of pounds per container load
of production in inland haulage. The average value of a container
load of goods through a GB port is around £20,000. A port
location might thereby cut overall production costs by 3 to 4%;
highly significant in a global economy where different locations
compete for business.
2.12 Water-freight already plays a key role in the economy.
A high proportion, perhaps half, of all manufacturing industry,
employing 1.75 million people and contributing £58 billion
GVA depends upon goods passing through the ports. In addition,
based on survey information from five major ports accounting for
approximately a third of the total tonnage of dry cargo, the total
direct, indirect and induced jobs in water-freight is estimated
at some 200,000, or about 0.55% of all workforce jobs, in 2004.
Assuming an average estimate of Gross Value Added (GVA) per job,
this translates to a contribution of £6.2 billion to the
GVA of UK plc. These are believed to be conservative estimates
of jobs and GVA and the true numbers may be higher by a factor
of 2 to 3.
2.13 Sea and Water supports the Government's commitment
to reform marine licensing regimes to simplify and streamline
the regulatory regime. Sea and Water calls on the Government to
ensure that changes to the licensing regime do not add unnecessary
burden and indeed are not detrimental to the water freight sector.
We hope that the Government will make a full assessment of the
impact of any new licensing system on the water freight sector,
and call on the Government to consult Sea and Water as and when
specific proposals are developed.
3. HELPING THE
ENVIRONMENT THROUGH
WATER FREIGHT
3.1 In its report into Transport and the Environment,
published in 1994, the Royal Commission on Environmental Pollution
highlighted the environmental advantages of water freight transport.
It called for action "to increase the proportion of tonne-kilometres
carried by water from 25% in 1993 to 30% by 2000, and at least
maintain that share thereafter".
3.2 The 1998 White Paper, A New Deal for Transport,
also recognised the "useful contribution" that
water freight could make to a sustainable transport system. That
position was supported in the subsequent "daughter"
document, Waterways for Tomorrow, which was centred on
the contribution waterways could make to sustainable development.
3.3 In short, it is widely acknowledged that moving freight
by short sea, coastal and inland shipping delivers a number of
environmental benefits compared to other transport modes. Principally
this is because moving freight by water uses significantly less
fossil fuel than other modes.
3.4 As a result moving freight by water reduces the amount
of carbon put into the atmosphere by up to 80%. It reduces the
volume of nitrogen oxides put into the atmosphere by about 35%.
This is vitally important when carbon emissions from transport
are growing, with road transport accounting for 22% of all of
the UK's emissions. Almost 40% of CO2 emitted by road transport
comes from lorries and buses.
3.5 Water transport is more sustainable in other ways.
The water "network" uses considerably fewer finite resources
such as aggregate. A kilometre of motorway consumes more than
100,000 tonnes of aggregate, and UK roads as a whole account for
90 million tonnes of aggregates each year. By contrast coastal
waters and rivers are naturally-occurring, and what maintenance
is required can be delivered sustainably.
3.6 If freight is switched to water the need for long
distance movement of freight by road is reduced, thereby reducing
the demand to widen existing motorways or build new trunk roads.
Enhancing water-based transport facilities instead of road infrastructure
has the great advantage of being specific to freight and will
not be taken up by unregulated growth of passenger car traffic.
3.7 The consultation proposes new measures for Marine
Nature Conservation. Sea and Water is committed to developing
sustainable, environmentally sensitive growth of the water freight
industry. It is important that any new legislation for the delivery
of a network of Marine Protected Areas (MPAs) occurs only with
full consultation with the water freight sector.
4. CREATING A
SUSTAINABLE, STRATEGIC
MARINE PLANNING
ENVIRONMENT
4.1 UK ports deliver their services to the national economy
without cost to the public purse. The absence of a UK planning
policy framework that recognises the overriding national importance
of ports makes it difficult for ports to demonstrate the need
for any port development.
4.2 In addition, the process for obtaining Harbour Revision
Orders and other approvals is too slow, too uncertain, overly
complicated and costly. As a result, port development is delayed
and frustrated—and the UK remains at a disadvantage to European
competitors.
4.3 We welcome the review of ports policy being undertaken
by the Department for Transport. It is crucially important that
the current difficulties with the planning system are urgently
resolved. It is self evident that if inland waterways and coastal
shipping are to expand their roles, ports must expand to become
distribution hubs and will therefore require the physical developable
space to fulfil that role. This approach is entirely consistent
with established planning policy.
4.4 Ports offer ideal locations for distribution activities
as they are often rail and waterway connected and well located
to serve regional markets. Regional policy guidance implies that
the demand for rail/water connected sites will be very extensive
as one million m2 of large distribution sheds (requiring around
250 hectares per annum) are built each year in the UK.
Facilitating the expansion of ports to meet demand
4.5 Ports must be allowed to physically expand if the
policy objective to locate such buildings at rail and water linked
sites is to be addressed. Water connected sites will promote coastal
shipping because the cost of a road leg to reach quayside buildings
is eliminated. Port locations can constitute the most competitive
locations for industrial development.
4.6 Sea and Water calls upon ODPM, DfT, and Regional
Assemblies to ensure that planning policy allows for the expansion
of ports in the UK.
4.7 Sea and Water also supports proposals for a system
of Marine Spatial Planning (MSP) that recognizes the importance
of the water freight industry to the UK. Any new system, whether
managed by a new Marine Management Organisation (MMO) or other
authority, must work with the water freight industry to ensure
that marine planning creates a sustainable environmental and economic
balance.
May 2006
1
GB Freight Model, developed by MDS Transmodal, audited by DfT
and used Inter alia, in National Transport Model. Back
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