Memorandum from the Institution of Highways
& Transportation (IHT) (FT 14)
1. The IHT, founded in 1930, has over 11,000
members concerned with the design, construction, maintenance and
operation of transport systems and infrastructure across all transport
modes in both the public and private.
2. The IHT welcomes the opportunity to give
its views on the need for an overall integrated freight plan for
the UK to guide and underpin investment by both the public and
private sectors.
3 Passenger transport movement is largely
determined by land use patterns and where people live, work and
engage in activities such as shopping, recreation, education and
so on. Similarly, freight transport movement is largely the result
of the import or export of products, the locations of manufacturing
activities, the places where products are sold or used, and the
distribution system to move goods from ports or factories to the
points of use or sale. This is referred to as the supply or logistics
chain, and needs to be understood before an integrated freight
plan could be developed.
4. Passenger transport in Britain depends
mainly on privately owned cars operating on publicly provided
roads, paying more than the cost of road construction and maintenance
through various taxes. Collective passenger transport is a mixture
of commercial and public provision, with a considerable element
of subsidy. Freight transport also uses privately owned vehicles
(trucks, ships, aircraft) using generally publicly provided infrastructure
(roads, ports, airports), though most of the ports and airports
are now at least operated commercially. However, the freight industry
also has a massive private infrastructure of distribution centres
and warehouses, that cost more than the vehicle element of the
system to operate, and whose locations largely determine the pattern
of road and rail freight movement. In addition, for freight there
is no publicly subsidised collective movement system; the rail,
sea and air freight operators are wholly commercial.
5. Of all the money spent on transport in
the United Kingdom, 45% is spent on moving things (freight) rather
than moving people. In 2005, road freight transport used 38% of
the petroleum used by all road transport. In 2004 freight plus
public transport ("light and heavy duty road transport vehicles")
emitted 39.5% of all the CO2 from road transport, 58.6% of the
oxides of nitrogen and 52% of the particulate matter PM10 (mainly
from vans rather than heavy goods vehicles or buses).
6. Freight is a significant tax payer in
the form of fuel duties, vehicle excise duties and profits taxation.
More importantly, it is crucial to the functioning of the economy.
Without freight transport, and particularly road freight transport,
goods cannot reach shops, industry cannot function, fuel cannot
get to garages, offices cannot receive supplies, mail cannot be
delivered, and normal life cannot be maintained. This reinforces
the significance of freight as an economic facilitator as well
as an economic entity in its own right.
7. It is for these reasons that freight
must be seen as part of a supply chain activity and not in isolation.
It is an intimate and vital part of our core social activity and
must be treated as such. The IHT believes that freight and supply
chain issues have been badly understood and in many ways ignored
by the professionsparticularly transport planning and including
IHTdominated by passenger and car issues. Many freight
operations ride "on the back of" car and passenger facilities
and often struggle to perform at their best because of it.
8. The IHT considers that the best way forward
is to encourage a better understanding of the issues of industry's
supply chains and to educate transport and land use planners,
local authorities and developers to enable them to plan for freight
and provide the infrastructure, facilities and regulatory environment
that enables freight to operate efficiently and with minimum impact
on the environment. To assist this, in 2005 IHT, with the support
of the Freight Transport Association, published guidelines "Moving
freighthow to balance economy and the environment".
These guidelines were supported by a number of regional workshops
bringing together the professionals from industry and the planning
sector. IHT intends freight to be a constant feature of its professional
and educational focus.
9. Freight supply chains are multi-modal
and concern road, rail, sea and air. The IHT's expertise is mainly
concerned with road issues and therefore we will restrict our
further comments to the road mode. The large majority of freight
generators and attractors are served only, or most efficiently,
by road, so almost all freight journeys include at least one stage
by road.
10. About 84% of inland freight moves by
road. Of road freight, the vast majority is moved in heavy goods
vehicles, although light vans contribute about 68% of the vehicle
km by goods vehicles. But the size of lorries (heavy goods vehicles)
makes them very visible on the road. Naturally, therefore, people
tend to see freight as just lorries and lorries as something to
be controlled and regulated rather than helped and facilitated.
Sadly this has too often been the position that the Department
for Transport and its predecessors have taken. But we are pleased
that following the Eddington Report, the Department has been reorganised
with supply chain and logistics as a Board level responsibility
for the first time. The title of the Directorate suggests that
it is not just about the management and control of the safety
of lorries. As professional planners, transport engineers and
operators, we welcome this new approach, which we hope is a sign
that the government is constructively planning for freight, the
supply chain and lorries as part of an efficient, effective and
competitive economy.
11. The following paragraphs address some
of the specific questions asked by the Committee.
12. Should the Department have more
responsibility for planning and delivering integrated infrastructure
which might promote `free movement of goods'? How is this to be
balanced with the Department's other commitments?
The first priority for the Department should
be raising the awareness of transport planners and local authority
staff to the requirements of the freight transport industry. It
should disseminate guidance on planning for freight such as the
IHT Guidelines "Moving freight" and the Freight
Transport Association "Designing for Deliveries".
An issue on priorities is how to maintain goods vehicle journey
times as motorways and major cross-country roads become more congested.
Work has already been done on possible truck and bus priority
lanes, but no satisfactory solution has yet been found, and more
work is needed.
The importance of maintaining average journey
speeds for goods vehicles is that the network of distribution
centres has been located on the basis of current journey times.
Goods vehicle drivers' working hours are strictly limited, and
even small increases in journey times could disrupt the functioning
of the distribution network and impose disproportionate extra
costs on industry.
13. How could the Government help to
ensure a level playing field between UK and overseas freight companies?
Overseas freight transport operators benefit
by fuelling at lower prices overseas before entering the UK, and
for some countries, by operating vehicles on which lower annual
vehicle taxes are paid than would be the case in Britain. There
are other issues such as wage levels, but those are matters for
the market.
The issue of fuel costs and vehicle taxes can
be tackled, as it has been tackled in Germany, by the introduction
of a lorry road charging system. This takes the place of fuel
taxes, and charges heavy goods vehicles for use of roads (in Germany,
motorways only). Operators can reclaim part of the tax on fuel
purchased within the country against road charges that they have
paid. This appears to be working well in Germany, and could prove
to be the basis of a more general road use charging system, when
there is political will to introduce such a system.
Issues over the qualification of foreign drivers
and compliance with driving hours legislation needs to be approached
through enforcement activities.
14. How can the road safety record of
haulage vehicles be improved?
Because lorries are large in comparison with
most other traffic they are perceived to be unsafe. In reality,
heavy goods vehicles have the lowest rate of accident involvement
of any class of vehicles on the road and their safety record is
one of continuous improvement due to the unique combination of
vehicle and driver licensing in GB. However, lorries are large,
heavy and hard, and when hit by other vehicles, cause serious
damage to the other vehicles and their occupants. Because of this,
lorries are over-represented in fatal accidents, though often
their responsibility is no greater than that of a tree hit by
a motorist.
Much has already been done with rear and side
under-run guards to protect motorists and cyclists from HGVs.
Front under-run guards offer some protection in frontal collisions,
and both front and rear under-run guards need to be energy-absorbing.
More use could be made of retroflective paint to make vehicles
more visible at night. Intelligent transport systems are being
introduced to warn drivers of vehicles, cyclists or pedestrians
in blind spots. All these steps need to be encouraged.
There is a concern over the increasing numbers
of foreign registered lorries operating in the UK. Unfortunately,
some do not conform to our high domestic safety standards. Roadside
checks by VOSA and the Highways Agency confirm the increasingly
poor safety record of these vehicles. Estimates of the amount
of goods vehicle traffic that is foreign vehicles are approximate,
but it is likely that foreign registered vehicles contribute at
least 10% of vehicle kilometres by the heaviest vehicles on our
roads (five and six-axle articulated HGVs), and this proportion
is increasing. We believe that more and more pervasive roadside
checks is the single most effective action by which the already
good safety record of lorries could be improved.
15. How effective are the Freight Quality
Partnerships in improving the local experience of freight and
deliveries?
Understanding freight and lorries not just in
themselves but how they play their part in the supply chain is
important for success in managing these issues effectively. This
was the whole basis of the Freight Quality Partnerships initiative.
Started originally by the FTA working with the Civic Trust, it
put freight people, local planners and amenity groups in one room
together. Their objective was to define ways of improving the
environment that was within their powers, and not to prescribe
things others should do. The FQP follow on has been really impressive
by linking groups of well meaning people to work together for
a common objective. Much been learnt and achieved, but their brief
has been narrow and now it should be widened and supported more
by central government. One of the key impediments to supply chain
efficiency is the dominance of local curfews limiting both hours
of operation of warehouses and delivery points. The Cabinet Office
put a lot of work into this in 2006 but it needs both local and
national vigour to achieve the result.
The root of this is good planning and good review
of planning when conditions change. An example is the design of
premises to receive lorries and allow deliveries to be made without
blocking the road or other facilities. Understanding how lorries
manoeuvre and the space they require to do it safely is another
"black art" that is poorly understood. The FTA for many
years has made available design guidance for this purpose but
although the DfT and the IHT commend it, its application is not
universal and we still risk building new problems into our communities.
Here too more confidence, understanding and rigour is called for.
16. Are the restrictions on night-time
deliveries still appropriate? What impact would weakening the
restrictions have on quality of life and other factors?
Lorries are much quieter than they used to be,
and it would be sensible to review restrictions on night-time
deliveries to determine whether they are still required. With
increasing road congestion, road freight operators are increasingly
using night-time for trunk movements, and for deliveries where
this is possible. Reducing restrictions on night-time deliveries
would reduce the number of lorries on roads and in towns at times
when other road users are about, and should provide benefits for
other road users as well as improved economic efficiency. Driver
training and management are required to minimise nuisance from
banging doors, radios, and so on.
17. Lorries are often perceived to form
the majority of the traffic flow on motorways and trunk roads.
This is not correct. Lorries rarely exceed 40% of the traffic
stream and only then on our busiest motorways. Most of the time,
lorries are less than 10% of traffic and in urban areas frequently
much less. Lorry traffic on urban roads and minor rural roads
has been falling since the 1980s.
18. We cannot refer to freight without mentioning
vans. This is a rapidly growing sector of the market attracted
by its relative lack of regulation and easy access. We know too
little about this sector and how the use of vans is split between
light goods movement and the provision of service van operation.
This has been recognised by the CfIT and a special study is underway.
Vans are important to our economy but we need to understand whether
they need more regulation to maintain safety and if so what?
19. In summary, transport and land use planners,
local authorities and property developers do not pay enough attention
to freight transport, and do not provide the infrastructure, facilities
and regulatory environment to enable freight to be moved efficiently
and with minimum damage to the environment. We would like the
Department for Transport to take the lead in increasing the awareness
of these professionals to freight transport, and both IHT and
FTA would be pleased to work with DfT to encourage this awareness.
20. The IHT would be happy to elaborate
on any of the above if required.
October 2007
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