APPENDIX 48
Memorandum submitted by The Freight Transport
Association
INTRODUCTION
The Freight Transport Association and its members
welcome the 2012 Olympic Games and the regeneration impacts that
it will have on the Lower Lee Valley, London and the rest of the
UK. However, in the light of the challenges already facing freight
operators in and around the capital, such as the constraints of
Loading and Unloading, the London Lorry Control Scheme and the
demands of Congestion Charging, the challenge of delivering both
the construction phase, the Olympics and the Paralympic Games
should not be underestimated. Indeed, notwithstanding the fact
that the UK freight industry is the most competitive in Europe
(with only 10.8% of GDP spent on logistics compared to around
13% for European competitors) the task of delivering the Olympics
in such a constrained location and in the context of well documented
growth pressures in the Greater South East give some cause for
concern.
Freight Transport has not historically benefited
from high levels of support—this is now improving with the
changing perspectives of the Mayor and the realisation of some
of the objectives set out in the Mayor's Transport Strategy. It
is demonstrated by the establishment of a Freight Team within
Transport for London (TfL). This shift towards more supportive
attitudes has reaped benefits with the development of strategic
frameworks, such as the London Freight Plan (initiated by the
FTA), now well underway.
It is acknowledged that the commercial success
of the Olympics and the perception of the event by participants,
spectators and the IOC are fundamentally reliant on a smooth and
seamless logistical operation to move people and goods to, from
and around the site - freight operations will form the backbone
of those operations. If even the smallest details, for example
the provision of fresh food across the site, are disrupted then
the reputation and economic performance of the whole endeavour
will be compromised.
LOADING AND
UNLOADING
At present freight operators face significant
difficulties in the loading and unloading of goods because of
a combination of poor availability of delivery spaces at the kerbside
and a punitive system of Penalty Charge Notices that places revenue-raising
before any regard for the difficulties faced by operators or the
importance of timely deliveries to the success of local businesses.
The FTA proposes to tackle some of the issues around the Loading
and Unloading of goods on the site and within the capital generally
through the implementation of its soon-to-be-launched Code of
Conduct. This is only a first step and will require considerable
work by the FTA and its partners to improve the competitiveness
of London firms by making the timely delivery of goods and materials
less difficult.
LONDON LORRY
CONTROL SYSTEM
At present freight operators are severely constrained
by the now obsolete London Lorry Control System, more commonly
known as the London Lorry Ban. Typically, an operator wishing
to travel from the Northern exit of the Blackwall tunnel to a
delivery location in Islington would be required to deviate along
a 28-mile route designated by the ALG rather than the direct 11-mile
route. This adds both environmental impacts to the local area
and economic impacts to the freight operator and the customer.
If the logistics for the Games and their preparations are to be
effective then a fundamental change of thinking is needed to reflect
the changing environmental and technical context within which
the Lorry Ban operates.
CURFEW ISSUES
This review needs to include, amongst other
things, the need to satisfy the significant "off peak"
delivery needs of not only the Olympics but also the whole of
London's 24-hour economy. It should also reflect the significant
improvements made to lorries' environmental performance in the
20 years since the ban was introduced. In as much as many of the
curfews between, for example, 7 pm and 7 am are imposed by the
London Boroughs there needs to be participation in the review
from the ALG.
RAIL FREIGHT
It is well documented, by the FTA amongst others,
that in the absence of the construction of new rail routes there
will be significant additional pressures on existing rail paths.
Incidentally these are projected to be greatest along the stretch
of rail that will be serving the Olympics sites. Whilst there
is no doubt about the commitment of the rail freight operators
the challenges facing the industry are enormous. There is an opportunity
now to make informed decisions about the necessary infrastructure
not only for the construction and delivery of the Games but also
the growth of the Thames Gateway, increased traffic to and from
ports and growth in the UK economy as a whole.
POTENTIAL USE
OF WATERWAYS
Although recent studies have examined the potential
use of the waterways running through or near the site it is unlikely
that they would be able to make a significant contribution to
freight demands without significant capital investment that would
be disproportionate to the likely environmental benefits.
ENVIRONMENTAL ISSUES
Insofar as the Mayor proposes that the 2012
games be the most environmentally friendly to date, the FTA is
pleased to note that by 2012 we shall be on the threshold of the
Euro 6 emission standard with the majority of vehicles meeting
Euro 4 or 5 standards that will come into force in 2006 and 2008
respectively. This means that the majority of vehicles will be
emitting only 40% of the currently-mandated levels of Nitrous
Oxides (NOx) and only one fifth of the current levels of particulates
(PM10). The uptake of new engine technologies, together with the
availability of sulphur-free and other alternative fuels will
largely deliver the Mayor's Air Quality objectives.
SPECIFIC PROPOSALS
A key part of meeting all of the objectives
set out above is the inclusion of freight requirements in the
scoping and planning of the overall Olympic site. The planning
for the site needs to reflect the objectives of the London Freight
Plan and identify key Designated Freight Paths to overcome the
difficulties imposed by the current Lorry Ban (specifically that
deliveries from the west of London would face lengthy detours
to access sites in the Lower Lee Valley).
More specifically, there needs to be a fundamental
review of the London Lorry Control System that does not limit
itself to tinkering with the existing routes but instead examines
the very rationale for the scheme and how the scheme's objectives
are otherwise being achieved. Indeed, given that the objective
of the Congestion Charging scheme is to reduce congestion in the
central zone, a lifting of unnecessary restrictions on freight
access would support Mayoral objectives at no cost to freight
operators.
Better use should be made too of the limited
road space around the Olympic venue and the capital as a whole,
by facilitating the shared use of existing bus lanes by HGV vehicles
as well as creating dedicated freight routes.
The implementation of effective freight operations
could be further supported by the reduction of the current, onerous
regulatory burden, by the use of a London Delivery Disk scheme
proposed by the FTA is developing in consultation with the ALG.
SUMMARY
Whilst it is recognised that the effective delivery
of the Games is dependent upon cost-effective and environmentally-friendly
freight transport solutions there is still a gap between the rhetoric
of the Olympic promoters and the evidence of supporting actions
to actively promote freight and improve the difficult environment
under which freight operators are conducted in London. The FTA
is confident that the Olympics' objectives could be achieved but
is not at all certain that the political will and that of stakeholders
is yet firmly enough established to make success a certainty.
| 
