APPENDIX 6
Memorandum submitted by Wynns Group. Incorporating
Wynns Ltd & Robert Wynn & Sons Ltd
INTRODUCTION AND
BACKGROUND
1. Wynns Ltd are the UKs only independent
transport consultancy specialising in the movement of abnormal
indivisible loads. In 1998 and working on behalf of Powergen,
Wynns engineered the delivery of seven loads in excess of 150
tonnes to Cottam Power Station in Nottinghamshire. The loads were
delivered directly to site via the River Trent.
2. In November 2000 Wynns subsidiary company
Robert Wynn & Sons Ltd was awarded an £8.5 million freight
facilities grant. The grant represented 99% of the total cost
of the design and build of a specialist ro/ro barge and the purchase
and conversion of a former inland tanker barge. The vessels, later
named the Terra Marique and the Inland Navigator, work as a system
to maximise the potential of the inland waterway network for the
carriage of the largest and heaviest abnormal indivisible loads.
Specifically, Special Order and VR1 categories which are granted
for road movement by the Secretary Of State for Transport.
3. The Governments "water preferred
policy" was announced on 11 June 2002 by the then Parliamentary
Under Secretary for Transport David Jamieson MP and clearly states
that:
"the Departments VSE Division will henceforth
adopt a policy whereby water transportation is the preferred mode
for the movement of the largest and heaviest abnormal indivisible
loads. Road movements will only be authorised where the Department
has considered the possibility but believes water transportation
is not feasible"
4. In 2003 the Highways Agency became responsible
for the implementation and management of the Government's policies
concerning the movement of the largest and heaviest abnormal indivisible
loads. Previously this had been the responsibility of the VSE
section of the Department for Transport.
5. On behalf of the Secretary of State for
Transport, Highways Agency officials manage the application process
for Special Order permits (for loads which when transported are
either in excess of 150 tonnes in weight, six metres in width
or 30 metres in length) and VR1 permits which are for loads which
when transported are above five metres in width.
6. The Highways Agency is also responsible
for the implementation of the Governments "water preferred
policy".
The purpose of the agencies and whether the current
allocation of responsibilities is appropriate
7. The Highways Agency website states that:
"The Highways Agency is an Executive Agency
of the Department for Transport (DfT), and is responsible for
operating, maintaining and improving the strategic road network
in England on behalf of the Secretary of State for Transport".
8. The Highways Agency's role in the management
of abnormal loads is involved. Last year alone, as well as co-ordinating
the issuing of Special Order and VR1 permits, Highways Agency
officials co-ordinated the compilation of a code of practice and
best practice guide for the self escorting of abnormal load vehicles,
commissioned and co-ordinated research into the true economic
cost of the movement of abnormal loads and set up a working group
to study the availability of inland waterway infrastructure which
would be appropriate for the transhipment of abnormal loads.
9. As a direct consequence of the government
adopting a water preferred policy for the movement of the largest
and heaviest abnormal loads, the Highways Agency is increasingly
involved with the facilitation of abnormal load movements. Applicants
for Special Order permits are being asked to fill out a "water
proforma" (attached) which request extensive information
regarding the proposed road route as well as waterborne alternatives.
The information contained within this proforma is then used by
the Highways Agency within their decision making process when
deciding if they allow use of the road network either in whole
or in part.
10. There are a number of reasons for this.
Primarily the Highways Agency has no responsibility for the UK
commercial waterway network and they do not have ownership or
responsibility for any waterside sites. Also as their role has
developed from one of administration to one of implementation,
they do not have the knowledge or expertise required with which
to take steps towards the timely implementation or development
of the water preferred policy.
11. The implementation and facilitation
of the water preferred policy has been severely compromised under
the stewardship of the Highways Agency. It is however questionable
if the agency should have been given responsibility for the implementation
and development of the water preferred policy.
12. There is a need for the Department for
Transport to take ownership of it's policy. There are numerous
stakeholders within government who need to work together to facilitate
this policy and it is clear that the Higways Agency as an executive
agency of the Department for Transport tasked with operating,
maintaining and improving the strategic road network in England
is not best placed to do this.
How the agencies contribute to Departmental objectives
and policy?
13. In June 2002 the Minister announced
his water preferred policy. At this time it was made clear that
the Department wished to see the transfer of a significant number
of abnormal loads from road to inland waterway.
14. Since the policy was announced we belive
that there have been less than half a dozen examples of where
Special Order abnormal indivisible loads have been refused road
route permission and have subsequently been carried by inland
waterway. According to the Highways Agency themselves, there are
some 450 Special Order applications per year, 26% of which are
over 150 tonnes in weight, moving on the road network at a maximum
speed of 12 mph and most often blocking two lanes of the carriageway.
15. In fact there are examples of where
the Highways Agency have taken steps to seemingly compromise the
policy. These initatives are actually making it easier to transport
large indivisible loads by road.
Such initiatives include:
Developing the ESDAL system (Electronic Service Delivery
for Abnormal Loads Project)
16. This is a system currently being developed
which when fully online will make the administration of the Special
Order process for road based movements much simpler for both the
Highways Agency and the hauliers. Waterway routes do not feature
in this £8 million Treasury funded initiative. It should
be noted that this initiative was announced after the the
announcement of the water preferred policy.
Allowing night time movements of slow moving abnormal
load vehicles
17. The practice of moving large indivisible
loads in the hours of darkness has until recently been discouraged.
We are now however seeing a greater proportion of loads being
given permission to move at night. This is a policy change since
the water preferred policy was announced. The significance of
this is that congestion on the road network is significantly less
at night. Therefore when the Highways Agency assesses the potential
disruption caused by such a move they are less likely to insist
on the load being transferred to an inland waterway. We are not
aware of any research carried out into health and safety issues
of night time movements.
Commissioning research in to the viability of raising
the speed limit at which abnormal loads can travel
18. Currently the maximum speed limit that
a Special Order category abnormal load is permitted to travel
is 12 mph. The Highways Agency are currently commissioning research
which will investigate the potential for an increase in the maximum
speed that Special Order category loads are allowed to travel.
19. Research has shown that one of the significant
factors when analysing the congestion caused by abnormal load
movements is the speed of the abnormal load carrying vehicle.
Should this research lead to a revision of the current limits
upwards this would most likely lead to more loads being transported
by road as the congestion anticipated by the movements of these
loads would be less than it is now, again serving to undermine
departmental policy and objectives.
20. While we welcome any Highways Agency
initiative to make the movement of abnormal loads easier, we would
have expected that in light of the Departments stated water preferred
policy that their Executive Agency would be putting forward initiatives
and finding funding to promote the waterborne carriage of the
largest and heaviest abnormal indivisible loads. This as yet has
not happened.
Whether the agencies' performances are satisfactory
and whether they are sufficiently accountable
21. It is clear to us that the Highways
Agency have not performed satisfactorily in the area of abnormal
load transportation. The government has a clear policy regarding
the movement of the largest and heaviest abnormal loads and it
is not being implemented satisfactorily by the Highways Agency.
22. The policy has not been promulgated
to any great extent by the Highways Agency. There is widespread
confusion within industry as to how the Highways Agency apply
the policy and local government officials are on the most part
unaware of its existence.
23. While we understand that the Highways
Agency are currently formulating a policy statement with accompanying
guidance notes, for some three years now the only public reference
to the "water preferred policy" is contained in a media
briefing circulated in June 2002. Surely this is unacceptable.
24. The Highways Agency has commissioned
the Transport Research Laboratory to carry out research into the
true economic cost of abnormal indivisible load movements by road.
This research project commenced early in 2003 and is yet to be
concluded. The drafts issued to date have concentrated on the
cost of the congestion generated by the movement and have failed
to fully investigate all impacts generated by abnormal load movement
and the resulting congestion. Despite representations being made
by ourselves and others, the Highways Agency have to date refused
to consider those costs it feels unable to quantify or calculate.
25. It is imperative that the officials
within the Highways Agency abnormal load section are held to account
and that their work in fulfilment of departmental objectives is
assessed. This however is not the case. Abnormal loads seem to
have fallen through the departmental stools. By that statement
we mean that the Department for Transport has a water preferred
policy but no actual responsibility for waterways, and as the
role of the abnormal loads team has traditionally been an administrative
one there is nobody within the Department for Transport who is
responsible for the review of their effectiveness or for the development
of policy in this area.
Whether there is sufficient co-ordination of systems
and sharing of information between agencies and with the Government
26. There is currently no co-ordinated approach
within Government on policies relating to waterborne freight carriage.
The Navigation Authorities who are responsible for the day to
day operation of the inland waterway network report to DEFRA.
Responsibility for freight/logistics policy is that of the Department
for Transport and it is the Highways Agency who are designated
to implement the water preferred policy for abnormal load movement.
27. These are some of the Govenment's stakeholders
responsible for issues associated with waterbourne freight carriage
and specifically abnormal load carriage on the UK commercial waterway
network. There are however many others who need to take a proactive
role if the Departments water preferred policy is to be effectively
implemented, these include: the Environment Agency, Office of
the Deputy Prime Mininster, Regional Development Agencies, Regional
Assemblies and Local Councils.
28. If the current situation continues it
is difficult to see how the Highways Agency can effectively deliver
the Department's water preferred policy. There is a lack of both
impetus and strategic direction with the Highways Agency who would
appear to be working at arm's length with other sections of Government.
The Department for Transport should be acting as a co-ordinator
of stakeholders to ensure the the Highways Agency can deliver
the water preferred policy, this to date is not happening.
29. In summary the water preferred policy
was created by the Department for Transport as a common sense
initiative but with no ownership within the Department. The Highways
Agency have been given it to administer but do not own it and
have no target or responsibility to make it work and indeed, as
we have argued given the current set up, cannot make it work.
9 January 2006
1. INSTRUCTIONS
Please complete all the following tables. Where
information cannot be supplied, please give reasons.
The note boxes are for additional comments,
however, if there is insufficient space (they can be extended)
additional comments can be submitted separately but should refer
to the line number in the table.
An example of how Table 5 should be completed
is demonstrated.
2. SUMMARY TABLE
GENERAL
TABLE
4. WATER OPTION
TABLE
ROAD
OPTION TABLE
(EXAMPLE)
6. WATER OPTION—ROAD
ELEMENT IF
APPLICABLE
7. BREAKDOWN
OF COSTS
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