APPENDIX 19
Memorandum submitted by the Road Haulage
Association Ltd
INTRODUCTION
The Road Haulage Association (RHA) was formed
in 1945 to look after the interests of haulage contractors in
various areas of the country, in effect, amalgamating local organisations
that had already been established. The Association has subsequently
developed into becoming the primary trade association representing
the hire-or-reward sector of the road transport industry. There
are presently some 10,000 companies in RHA membership, varying
from major operators operating hundreds of vehicles through to
single vehicle owner-drivers. As such the evidence below focuses
on the interests of the professional road haulier.
BACKGROUND TO
THE INDUSTRY
The road haulage industry has an essential role
in the UK economy, accounting for 6% of Gross Domestic Product
and employing some 1 million people. Government figures show that
103,000 registered goods vehicle operators carry out over 80%
of all the domestic freight movements within the UK, utilising
394,600 licensed heavy goods vehicles and 265,000 semi-trailers.
In 2004 the amount of freight carried by the
UK road fleet amounted to a total weight of 1,643 million tonnes:
— 1,053 million tonnes carried on 53,500
hire-or-reward operators' vehicles; and
— 590 million tonnes carried on 49,500
own-account operators' vehicles.
As well as the domestic fleet there are also
many thousands of Continental registered goods vehicles regularly
running on UK roads, and it is important that they should also
be taken into account when the work of the DVO Group and the Highways
Agency is considered.
GENERAL COMMENTS
As the representative body for the domestic
road haulage and distribution sector, the Road Haulage Association
enjoys a close working relationship with the DVO Group and the
Highways Agency (HA). Both staff and members of the RHA sit on
numerous agency led committees and working groups to ensure that
the safety and interests of commercial enterprise are recognised
and considered whenever issues pertaining to levels of service,
compliance and value for money are being examined. However, there
have been numerous changes in the recognised practices and procedures
of the DVO Group during the last few years, which have resulted
in a substantial increase to the fees charged. HA has also been
radically restructured during this same period and its responsibilities
have been dramatically extended.
REMIT/ROLE
OF AGENCIES
Due to the nature of their businesses, virtually
every RHA member company will have direct dealings with the Driving
Standards Agency (DSA); the Driver and Vehicle Licensing Agency
(DVLA); the Vehicle and Operator Services Agency (VOSA) and the
Highways Agency (HA). Contact with the Vehicle Certification Agency
(VCA) is less regular. Broadly speaking the agencies' interests
in the road haulage sector are as follows:
VOSA—is responsible for licensing
haulage operators and for enforcing all the regulations that govern
the industry from the roadworthiness of vehicles to drivers' hours
and the Road Transport (Working Time) regulations. In addition,
they are the responsible for ensuring that foreign lorry operators/drivers
are compliant with the law. In addition, VOSA has recently acquired
several additional areas of responsibility including the power
to stop lorries to conduct checks; checking at the roadside that
carriers of dangerous goods have evidence of receiving security
awareness training; checks of premises where dangerous goods are
stored; the enforcement of the Road Transport (WTD) Regulations
and the implementation of digital tachographs across both the
commercial goods and bus/coach sector. In July 2006 they will
also have the responsibility for ensuring that all in-scope drivers
carrying hazardous goods (including vehicles under 3.5 tonnes
gvw) are accredited by examination and approved to transport this
type of consignment. This is all over and above the already onerous
amount of safety and enforcement work agency staff must undertake.
DSA—is responsible for the testing
of drivers. Recent changes to driver testing have resulted in
an increased workload—the introduction of a separate theory
test for prospective vocational commercial drivers, plus the need
to successfully complete a category C practical examination before
being able to apply for and sit a category C+E practical test.
In addition, they will be responsible for overseeing the implementation
of the new Vocational Training Directive in the UK. The RHA believes
this new directive will bring some important changes to the way
in the industry operates in the UK. Our members will be relying
on the DSA to implement the requirements in a sensible, efficient
and operator-friendly manner. If this is not achieved, considerable
extra costs will be imposed on the sector.
DVLA—in addition to their normal
licensing activities, DVLA will have an important role in the
introduction of the digital tachograph. This new system of recording
drivers' hours requires DVLA to provide four different types of
electronic smart cards to all vocational drivers; goods vehicle
operators; accredited technicians and enforcement personnel.
Highways Agency—Like all other road
users, the RHA's dealings with the Highways Agency primarily are
as users of the road network—albeit as commercial/business
users. However, members are also reliant on the Agency to provide
suitable facilities that allow them to comply with the legal requirements
for breaks and rests.
PERFORMANCE
As mentioned previously, both the DVO Group
and the Highways Agency have been involved in a period of extensive
change over the last few years, which we believe has had a detrimental
affect on the effectiveness and commercial profitability of many
operators, whilst at the same time compromising the ability of
the agencies to carry out an effective level of enforcement and
service.
For example, during 2005 the core services of
VOSA were severely disrupted and they were unable to offer a satisfactory
level of service to a large percentage of their customer base
(goods vehicle and bus and coach operators), due to an inability
to offer test appointment times for Heavy Goods Vehicles and buses/coaches.
The reasons given for this failure were unforeseen
problems, by the IT provider, regarding the introduction of an
extensive programme of e-capability to the system. However, the
loser was not the agency, it was the customer. And although the
agency was alerted to the problems likely to be faced when the
new system was introduced, it failed to act accordingly and the
system crashed, without any alternative plan being put in place.
Despite this, VOSA's fees for the period actually increased.
Whilst this was just one (albeit fairly fundamental)
problem, it demonstrates the "un-commercial" way in
which these agencies tend to operate. Few organisations can guarantee
that they will never face such problems. But none would be able
to provide such a poor service and yet still increase the fees
charged to their customers!
To its credit VOSA is working with the RHA and
others in the sector to develop a Service Level Agreement aimed
at alleviating some of these problems. However, the RHA believes
that additional changes may also be necessary (see below).
AGENCY FUNDING
ARRANGEMENTS
Executive agencies are now operated as Trading
Funds, and their stated objective is to at least break-even year-on-year.
Specifically, the costs incurred in undertaking all aspects of
work involved with a particular scheme have to be covered by the
scheme's fee or payment. This need to cover costs regardless of
the levels of service offered to customers is our major cause
for concern. Although Service Level Agreements are being entered
into, these are just treated as advisory and as yet there are
no procedures in place whereby unsatisfactory levels of service
lead to the executive agencies being penalised.
Furthermore, although regular consultations
take place before fee structures are revised and the trade representatives
annually spend time and resource responding, the truth is that
this is merely seen as a paper exercise by the agencies and increases
take place irrespective of the level of discontent voiced.
CO -ORDINATION
AND INFORMATION
SHARING
This is an area of executive agency operation
that the RHA is keen to see addressed. It is essential that co-ordination
and sharing of information is given a higher level of priority
as this has potential to improve core activities for customers
and make best use of scarce resources whilst continuing to deliver
the safest road transport network in Europe. The DVO Managers
within DfT must have a role in overseeing progress in this area.
CONCLUSION
DVO Group—the Road Haulage Association
supports the statements made by the DVO Group members in their
various business and corporate plan publications that they aim
to improve their service to customers and carry out more effective
enforcement.
However, although the importance of a customer-focused
service is stated within the Business Plans, as well as being
an integral part of the Secretary of State for Transport's key
targets, it is not yet evident in the attitude or service offered
at ground level (ie Vehicle Testing Stations and general DVO Group
agency response to operator enquiries).
We are also conscious that the delivery of these
pledges is to be accompanied by "improved efficiency through
transforming processes and centralising internal services".
This invariably leads to a reduction in manpower and an increase
in fees. RHA members, who are often overlooked as the customer,
have already provided a massive injection of additional funding
to the DVO Group by a 13% increase in test fees within a single
calendar year. It would be totally unreasonable to expect the
private sector to subsidise the public sector still further by
additional inflation busting price rises, just so that efficiencies
can be shown to be achieved in DVO Group's "bottom line".
Highways Agency—in the same period
as DVO Group has been transforming its services to customers the
Highways Agency has been undergoing a massive transformation of
its own. The road network is increasingly being managed and physically
patrolled by Highways Agency traffic officers.
Although still in its infancy, the RHA believes
that this more active approach to road management is a positive
step, although we are conscious that the level of resource that
is being committed will undoubtedly lead to government requiring
a further influx of revenue from the private sector to cover this.
Whilst, as noted, the RHA has a good working
relationship with the agencies concerned, this extends only to
departmental levels. We note the Government's desire to encourage
stakeholder involvement and believe that this could be extended
to participation by stakeholders in the strategic issues covering
these agencies. The scope for creating a new board to assist in
this exercise would offer the opportunity to reduce controversial
policy decisions before a full discussion of the implications
had taken place. Consultation papers are currently seen as too
much of a fait accompli—the new arrangements could help
to address this.
10 January 2006
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