APPENDIX 3
Memorandum submitted by the Freight Transport
Association
INTRODUCTION
Freight Transport Association (FTA) represents
the freight transport interests of businesses throughout the UK.
Its members range from small and medium size enterprises to multi-national
public companies and are involved in all modes of transport. FTA
members operate over 200,000 heavy goods vehicles, about half
the UK fleet, responsible for 90% of freight moved by rail and
70% of goods shipped by sea and air. This unique multi modal mandate
enables FTA to speak authoritatively about all aspects of freight
based on the broader transport needs of industry in the economy.
The relationship between delivery of an efficient
infrastructure for freight transport and the land use planning
system is one of the key challenges for industry, which FTA believes
impacts overall growth, productivity and prosperity of the economy.
According to Department for Transport statistics, road transport
accounts for approximately 81% of all inland freight movement,
and this over-whelming dependence on roads for freight movement
reflects a number of unique advantages for road transport over
alternative modes. This includes direct access to and from collection
and delivery points: namely door to door movement, flexibility
and freedom for the supplier to match fleet capacity (number and
size of vehicles) to demand (volume/weight of goods to be moved),
and the ability to operate "just in time" delivery systems
(ie when stock has declined to a pre-determined minimum level).
For industry to fully exploit these advantages, the road network
must provide a reliable and predictable level of service, as well
as optimum journey times: speed and reliability are of paramount
importance.
Industry, however, believes the current system
is too slow and unresponsive with the existing policies and procedures
resulting in lengthy delays in the delivery of new transport infrastructure.
Lengthy delays in the planning process negatively impacts productivity
and stifles economic growth, creating unnecessary regulatory burdens
and costs for businesses. As expressed in our submission to the
Barker Review for Land Use Planning and the Eddington
Transport Study, it is imperative for businesses that the
planning process is as streamlined and efficient as possible.
FTA welcomes the Select Transport Committee's
review of local transport planning and funding and are pleased
to have the opportunity to provide the industry's views on the
important issue. Specifically, our response outlines the industry's
views regarding:
— freight transport infrastructure;
— transport planning; and
Freight transport infrastructure
Efficient freight transport that delivers to
consumers and business is vital to the economy, and road transport
plays a key role in achieving this. The freight sector, however,
has to rely on a transport network over which it has no control,
with congestion creating the biggest challenge and cost for the
industry. To remain competitive and generate economic growth there
is a need for high quality, reliable transport infrastructure.
Increasingly, transport infrastructure is under pressure from
rising traffic levels both on road and rail, which means delays
to journey times with the number of unplanned incidents of congestion
are rising and overall reliability falling.
We take the opportunity of the Select Committee's
inquiry to reiterate the views of industry that have recently
been presented to the Barker Review for Land Use Planning
and the Eddington Transport Study. As pointed out in both
submissions, modern logistics practices and efficient supply chain
management lie at the heart of recent economic growth fuelled
by consumer spending. Logistics allow universal availability of
retail products with short lead times for replenishment and rapid
availability of out of stock items whilst avoiding the high costs
of inventory. Efficient logistics and freight distribution have
also allowed the benefits of globalisation and outsourcing to
be achieved by providing reliable links between new low cost centres
of production and traditional consumer markets.
Inefficient freight transport constrains economic
growth by adding to the overall costs of production and sale.
A major source of additional cost is congestion, manifested as
a deterioration of journey time reliability. This results in more
vehicles being required in supply chains adding to the overall
costs of doing business. Reliability of journey times is the critical
issue for freight transport.
Furthermore, transport is a secondary activity
in the economy and its future intensity will be a product of multiple
macroeconomic factors. Predicting future demand for freight transport
requires the basic dynamics in society and the economy to be anticipated,
as these will ultimately determine demand for goods and services,
and hence the nature of logistics systems to meet that demand.
Society is poor at acknowledging the link between its demand for
goods and services and the activities that are required to provide
them. Intolerance of goods vehicles in city centres, resistance
to night time and weekend deliveries and complaints about numbers
of goods vehicles on the roads are evidence of this phenomenon.
Future planning decisions must avoid the false
impression that transport can somehow be controlled independent
from the rest of the economy. Consumer demands are increasingly
requiring the continuous replenishment of retail outlets, and
this in turn requires deliveries at night and at weekends so as
to avoid congested peak periods. For more freight to be carried
by rail, to reduce road congestion, then sufficient capacity must
be created to provide adequate rail services. For distribution
activities to be carried out at night when infrastructure is less
congested then social and employment legislation must be flexible
enough to allow for these working arrangements. All these factors
are important considerations for economic growth and the planning
system needs to be flexible and responsive to the changing priorities
and demands of the economy.
The strategic road network forms the backbone
of freight activity, and while it accounts for only 2.5% of all
roads, it carries two-thirds of freight traffic and a third of
all other traffic. The performance of this network is critical
to an efficient supply chain and, therefore, key to maintaining
economic competitiveness. This efficiency cannot continue to depend
on the coordination of policies and procedures among the dozens
of different agencies and organisations that play a role in the
operation of transport infrastructure on the strategic network.
As external influences can constrain the planning
process, industry's view is that Government needs to take control
of road delivery and highway performance and provide leadership
and vision, rather than seek consensus between disparate groups
of organisations. One consideration to achieve this is to develop
a transport hierarchy that seeks to make more sustainable and
transparent decisions. This will create less debate in the planning
process, requiring local planning policies to respect the hierarchy.
Transport planning
An important problem perceived by the industry,
with the relationship between the planning system and transport
infrastructure is the overall impact of the regional land use
planning process. Regionally, we have seen the emergence of Regional
Spatial Strategies with associated transport strategies and, where
available, freight strategies. While these strategies all require
Government approval there appears to be a lack of Government action
to carry the strategies through.
There is a need for more Government action to
ensure that the strategies provide a forward planning framework
for local authorities and reduce the "clash" of local
aspirations that very often lead to uncertainty and delays in
the planning process. For example, Transport Board decisions as
they relate to regional funding allocations, often encounter difficulties
in setting priorities and this could be directly related to local
affiliations. If the Regional Spatial Strategies are what sets
the framework for planning there needs to be clear direction from
Government that local authorities must work towards achieving
a framework which will help to eliminate conflict in prioritisation
and aid the overall planning process.
FTA has committed major resources, not least
at the regional level, to establishing the necessary consultative
links with all local authorities who have produced Local Transport
Plans (LTPs). Every authority has received advice from FTA regarding
the freight content of LTPs. FTA experience in relation to consultation
by local authorities has varied widely from no meaningful consultation
in a small minority of cases to models of excellence from other
authorities. This reinforces our view that advice to local authorities,
whether in the form of Best Practice Guidance or Department for
Transport (DfT) Guidance, must emphasise the importance of freight
within an LTP and consultation with bodies such as FTA to ensure
that freight policies assist industry develop sustainable distribution
systems and practices.
It is noticeable that there was a distinct change
in focus between the initial Guidance issued by DfT and the second
round. The first LTP Guidance encouraged local authorities to
consider a wide variety of transport modes, including freight
transport, types of transport policy and methods for achieving
integration between transport and other areas of activity. The
second round of Guidance signifies a marked change in Government
policy as local authorities are now asked to focus on delivering
a smaller set of key outcomes, reflecting the shared priorities
agreed between central and local government (ie tackling congestion,
delivering accessibility, safer roads, and better air quality).
While freight issues can still be addressed through these shared
priorities; there is however, no direct Guidance to do so as was
the case with the initial documentation from DfT. FTA, therefore,
encourages Government to ensure future Guidance does not move
further away from the current focus to omit freight issues entirely.
There are two specific industry concerns regarding
the transport planning process in relation to LTPs. Firstly, as
there is a clear lack of a specific freight section contained
in LTPs, it is often difficult to locate such references in the
overall document. This information is of importance not just for
industry, but it may also be of value to local businesses or the
community itself. For a clearer understanding of freight issues
contained in LTPs, FTA recommends that there needs to be a method
of cross referencing or identifying those issues that relate to
freight. Secondly, there is a lack of any transparent method to
assess the effects of any LTP initiative and the process could
be vastly improved with a requirement for including a mechanism
to assess initiatives against their proposed goals.
Transport funding
It is vital for all levels of government to
recognise that industry needs a high quality, reliable transport
infrastructure to remain competitive and generate economic growth.
There has, however, been a dramatic under investment in the road
and rail networks over many decades, during which time the economy
has grown steadily and people's mobility has increased. This has,
in turn, placed transport infrastructure under strain. For example,
FTA believes that there is £12.4 billion of widening urgently
needed on key motorway routes including the M1, M4, M6, M62, M60
and M25. At the Highways Agency's planned spending levels of £1.9
billion between 2005 and 2008, this is equivalent to 19 years
of work to improve the freight transport industry's trade routes.
With regard to local transport funding, there
is a need to ensure prioritisation of spending on freight related
initiatives is concentrated on maintaining strategic routes—generally
accepted to be the primary route network—used by the freight
transport industry. It is important to keep major transport arteries
open and a lack of investment in these roads will continue to
clog the existing infrastructure, increasing congestion and reducing
reliability of the delivery of goods.
FTA believes that any approach to local transport
funding should be designed to require LTPs to not only provide
solutions to transport problems identified, but also provide a
mechanism to assess results. Furthermore, industry is concerned
that while revenue funding is sufficient to address transport
issues, such as road maintenance, this money is not in anyway
ring fenced for transport and can, therefore, be siphoned to other
politically advantageous spending initiatives at anytime.
CONCLUSION
Freight transport touches every aspect of society
and the UK economy. Efficient supply chains bring consumers year
round product availability and rapid response times to orders
placed in the comfort of homes. Industry's availability to compete
in a world market for goods and services relies on freight transport
to supply what is needed and deliver what is produced at the right
time, in the right condition and in the right quantities.
Congestion is the single biggest challenge and
cost facing the UK logistics industry, with the problem of network
reliability most acute in urban areas. FTA recognises that Government
focus is aimed at making best use of the transport network to
facilitate movement. Schemes and initiatives to improve accessibility
are important to local transport planning, however, they should
not just be attributed to securing improvements to the punctuality
and reliability of public transport—freight transport has
an equally important role to play. We do encourage Government
at all levels to recognise that transport planning and funding
is not simply about moving people; the movement of freight is
as vital to local economies. The delivery of goods to retail and
business premises in town centres is an essential part of commercial
life.
As previously indicated, FTA enjoys an excellent
working relationship with most local authorities throughout the
UK, including ongoing dialogue with authorities across the whole
spectrum of freight related issues. FTA will continue to set out
a clear and comprehensive industry vision for future investment
and we are determined to ensure that the UK freight industry's
interests are heard and acted upon. In order to achieve this,
we need the support and assistance of all levels of Government,
including the recognition of the role of freight in transport
planning, including DfT Guidance. This would then ensure that
local authorities are accountable and responsible for supporting
an efficient, cost effective logistics sector which is a significant
contributor to the development and growth of local economies.
RECOMMENDATIONS
In order to improve land use planning policy,
the freight transport industry recommends Government consider:
— Implementing a system that is
more responsive to business needs, by reducing administrative
burdens and making decisions quickly.
— Ensuring future planning decisions
avoid the misconception that transport can be controlled independently
from of the rest of the economy.
— Taking control of road delivery
and highway performance, and providing leadership and vision rather
than seeking consensus between numerous groups of organisations
with competing needs.
— Developing a transport hierarchy
that seeks to make more sustainable and transparent decisions
and ensuring local planning policies respect this hierarchy.
— Advising local authorities of
the importance of freight within an LTP and consultation with
key stakeholders to ensure that freight policies aid the development
of sustainable distribution systems and practices.
— Ensuring all future LTP Guidance
does not focus on broader transport issues and omits consideration
of the importance of addressing freight specific issues.
— Requiring LTPs to contain a
method of cross referencing or identifying those issues that relate
to freight to enable clearer understanding by stakeholders.
— Implementing a transparent mechanism
to assess the effects of any LTP initiative.
— Ensuring prioritisation of spending
on freight related initiatives is concentrated on maintaining
strategic routes—generally accepted to be the primary route
network.
25 April 2006
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