Memorandum from the Road Haulage Association
(RHA) (FT 15)
UK FREIGHT INQUIRY
1. The Road Haulage Association is the main
representative body for companies whose main business is providing
haulage and related services. Our 9,500 members run 100,000 lorries
and include owner-drivers, small and medium-sized fleets and large
multi-depot operators. It is worth mentioning that our members
pride themselves on providing an essential service in a manner
that is efficient, flexible, responsive and recognised as probably
the safest in Europe.
2. Thank you for your invitation to contribute
to your inquiry into UK freight transport policy. This inquiry
is most welcome. It comes at a time when there is a strong feeling
within the road haulage and logistics sector that we need greater
recognition at national and local level of the contribution the
sector makes to the economy and that this should be recognised
in areas such as planning and taxation.
EXECUTIVE SUMMARY
3. The Sustainable Distribution Fund is
welcome but can be improved and developed. The inclusion of road
haulage is a welcome recognition of the importance of the sector.
4. More work can and should be done to develop
an integrated transport infrastructure, with each mode encouraged
to be as efficient as possible.
5. The government engages well with Europe
but has failed utterly to level the duty playing field, either
by reducing UK duty levels or by persuading our EU partners to
raise theirs. This remains a serious failure and handicap to the
UK haulage sector, which is now being made worse by fuel duty
increases.
6. Freight quality partnerships are a welcome
innovation which has led to practical improvements and improved
understanding, although stronger political will is needed to apply
necessary but potentially unpopular measures. FQPs should be held
when there are issues to discuss, rather for their own sake.
7. The UK haulage sector is not complacent
but has perhaps the best record in Europe and is trending in the
right direction, unlike overall UK accident statistics. Efforts
to educate and to enforce the law in respect of foreign drivers
must be maintained.
THE SUSTAINABLE
DISTRIBUTION FUND
8. We welcome the Department for Transport's
statement that its promotion of sustainable distribution of goods
should move towards support according to outcomes achieved. The
aim is to buy the benefits of reduced pollution and congestion
and better safety rather than to promote certain modes of transport.
9. We welcome, too, the inclusion in recent
years of programmes to promote efficient road haulage, both for
the contribution made and for the recognition that road haulage
is and most probably will remain the dominant mode of transport
for the foreseeable future. At the RHA we have a saying: "Without
trucks, you get nothing." This is true even where the road
movement is linked to those of rail, air and water.
10. We are aware of some controversy surrounding
the calculation of Sensitive Lorry Miles, which are often replaced
by rail or waterborne transport, with some favouring a tonne/km
calculation and others vehicle movements. In addition, we have
concern over certain measures used by the Department, for example
that of the increase in CO2 generated by trucks over the past
decade in the GB Freight Model. We believe it to be substantially
inaccurate and are seeking clarification.
11. The RHA recognises the effective efforts
made in the industry to ensure that an outstanding service is
delivered efficiently and safely. The association supports measures
to improve the professionalism, efficiency and safety of the road
haulage sector—and has a number of services and training
programmes that promote these skills and attitudes. The Freight
Best Practice programme is a welcome initiative that makes available
useful references for improving efficiency and fuel economy, although
the navigation of the programme could be easier for operators.
The RHA is pleased to be able to recommend it to members. We believe
that there is much that could be done to develop the programme
and we are seeking more dialogue with the Department on that.
12. The SAFED programme has been readily
adopted and has re-enforced an existing culture of safety and
fuel efficiency. For example, that the UK led Europe in the adoption
of cab-roof and other aerodynamic aids, which have been adopted
on continental Europe only relatively recently.
13. In terms of mcdal shift grants, especially
to rail, we would like to see more effort towards making capacity
available in practical terms to a wider section of the road haulage
and distribution sector. We appreciate that this can be a difficult
area, due to commercial sensitivities; however, it would be desirable
for companies to see a mechanism whereby grants can be made available
in smaller packets to those hauliers keen to consider rail as
an option.
14. We see a paradox in the modal shift
programme. The more lorry taxation is aligned to total cost of
impacts on the road, congestion and the environment, the more
expensive/marginal become the benefits of grant-assisted modal
shift. We expect, nonetheless, to see continuing growth in rail
freight.
INTEGRATED INFRASTRUCTURE
15. The development of an integrated transport
infrastructure is to be welcomed and should be assisted by the
Independent Planning Commission envisaged in the Planning White
Paper published earlier this year. Thus, it is important to have
not only ports with sufficient capacity to handle demand but appropriate
road and rail infrastructure to take freight to and from those
ports.
16. Transport infrastructure—be it
road, rail or water-borne—suffers from opposition based
from both local residents and, often more effectively, the perception
of higher value for other industrial or housing development. It
is important that a long-term, strategic view be adopted. There
is scope for both rail and water-borne to increase their contribution.
FREIGHT QUALITY
PARTNERSHIPS
17. RHA staff from our four regional offices
are engaged directly in many of the country's freight quality
partnerships and it is clear that some work well for the benefit
of local authorities and the industry.
18. FQPs are a relatively new phenomenon.
In many cases, they provide a valuable forum for an honest, informed
and focussed discussion, for thrashing out local issues and keeping
freight moving. They highlight at an early stage initiatives from
local authorities that might have adverse affects that had not
been realised. In this way, damaging decisions have been avoided.
At the same time "quick wins" resolving practical issues
can be identified and implemented.
19. Truck parking can be and is addressed
at FQPs. This is an important issue, both locally and in a strategically
and one of growing importance.
20. The FQPs would benefit from stronger
political will and appreciation of the role of road haulage. For
example, a study in Aberdeen demonstrated that allowing trucks
into bus lanes would have no little or adverse affect on buses,
would improve haulage efficiency and would reduce car congestion;
and yet the proposal was rejected by the council because it was
perceived as potentially unpopular.
21. We believe that FQPs should meet by
exception rather than on a regular basis, regardless of the extent
or urgency of issues to be discussed. We have experience of some
FQPs "agenda hunting"; that is meeting without clear
need. In such cases the impact has been for attendance to suffer
and, on occasions, for the FQP to be wound up altogether. FQPs
should tailor their activities according to need, adopting a "horses
for courses" approach.
INFLUENCING EUROPE
22. We welcome the government's close involvement
in European freight negotiations; however has failed completely
to ensure that the playing field between UK and foreign companies
is level.
23. The significance of the fuel duty difference
was recognised by Gordon Brown when Chancellor in 2001. He said
he would correct this unfair tax disadvantage (and modernise road
haulage taxation) with the lorry road user charge. Almost four
years later, and after £40 million had been spent on consultancy
fees, the project was abandoned as too expensive and too difficult.
We are still waiting for a solution. Fuel duty was held until
last November, but we are effectively back on the escalator, with
above-inflation increases in fuel duty. The gap between the UK
and the rest is widening. The association calculates that it now
stands at somewhere between £13,700 and £15,600 for
a typical articulated lorry on hire or reward haulage work. This
difference is unsustainable by UK road hauliers and will continue
to lead to a loss of jobs and work to foreign firms.
24. Solutions are available. One reason
for the failure of the LRUC may be that it expanded in scope towards
a demand management and enforcement project which went far beyond
the aim of levelling the duty playing field. We have also proposed
alternatives, including an increase in VAT and an essential user
rebate.
25. The Department has an important role,
we believe, in resisting European Commission proposals to liberalise
the EU's rules on cabotage. The RHA is in favour of a free market,
all things being equal; but they are far from that, in terms of
fuel duty, regulation and enforcement, all key areas in the commercial
haulage sector.
26. The road haulage sector in the UK is,
we believe, the best and most coherently regulated in the EU.
For example, ours is the only industry that suspends, curtails
and revokes licences of non-compliant operators. We therefore
welcome the specific inclusion of these three terms in Article
21 or EU Regulation 561/2006 on drivers' hours. The European Commission
is to promote this culture in Europe and we would support the
UK government's contribution to that process.
27. We regret that the Department has been
unable to stop the duplication of regulations inherent in the
drivers' hours and working time directives but welcome its input
towards a common understanding and harmonised enforcement of the
former, and UK guidance notes on the latter.
28. There is much talk, in the UK and elsewhere
in the EU, about longer heavier vehicles, especially the 25.25m,
60 tonne European modular concept. The RHA's view is that we need
on-the-road tests of longer heavier vehicles to test their suitability
for the UK roads and UK economy. We have members who can see economic
benefits to their companies and to the UK as a whole, as well
as gains in terms of the environment, congestion and road safety;
and these benefits would accrue not only in terms of long distance
but also relatively short hauls. We have other members who are
more sceptical on some or all of these points. Nonetheless, we
should not be left behind in the European debate and we need more
information as to UK suitability. There is a negative view of
what is perceived to be a knee-jerk reaction from rail freight
interests keen to deny possible efficiency gains to what is the
UK's main freight transport mode, especially when there is strong
focus on each mode paying its full costs. The two modes should
seek optimum efficiency and safety—and seek to work together
where possible.
IMPROVED ROAD
SAFETY ROAD
HAULAGE
29. The RHA targets many of its activities
towards legal compliance, in which practical issues of safety
are a key element, and driver assessment and development. These
qualities are promoted through a variety of methods, including
our national training service.
30. The road safety record of the UK fleet
is outstanding in terms of European comparisons. In contrast to
overall UK road injury statistics, those accidents involving lorries
are trending in the right direction, according to the latest Department
statistics. These are indicators of which the industry is rightly
proud—and determined to improve further.
31. We feel that the contribution to road
safety of the driver CPC requirements, which come into force in
September 2009, will be significantly less in the UK than in many
other EU countries, where the need for improvement is greater.
There will, however, be a gain; perhaps this will be most marked
in terms of safe loading, an issue which RHA's training team stresses
and which may cause accidents such as rollovers at roundabouts.
32. We welcome the increased education of
foreign lorry drivers and the issuing of Fresnel mirrors, which
we are told have dramatically reduced the number of side-swiping
incidents; and the increased enforcement of haulage laws, especially
those in respect of drivers' hours.
33. There has been much concern expressed
over the safety of cyclists in regard to lorries. We believe that
driver education is important but that there is much greater gain
to be had from educating cyclists in regard to turning circles.
34. There would be gains from educating
the general motoring public about lorries and their characteristics.
We would go further. We believe that the haulage industry has
a core culture of safe and fuel-efficient driving that can translate
to car drivers. Indeed, lorry drivers could be role models for
motorists, due to their knowledge of their vehicles, road awareness
and anticipation.
35. An increase in the 40 mph speed limit
on some two-lane roads would improve road safety, by reducing
the frustration on motorists and their temptation to overtake
where it is dangerous to do so. This is a controversial proposal
to some. However, we note that when the issue was debated at the
Scottish parliament last year, there was almost unanimous support
for a test, for example on the A9, and there were no dissenters
from the idea.
36. Modern technology has the ability to
monitor driver behaviour more closely than ever before, for example
with respect to hard braking, acceleration and cornering. This
technology should be more readily accessible. Also, new electronic
stability control devices, most obviously for high trailer and
tankers. These are relatively inexpensive to fit to modern trailers.
37. There is a need for more research into
the causes of accidents, the better to inform management, training
and enforcement efforts.
38. Road hauliers' customers have a role
to play in road safety. The RHA is championing health and safety
not only on the road but at customers' premises, where loading
practices can on occasion mitigate against safe and legal loading.
Also, the application of just-in-time principles by some major
buyers of transport, who impose unnecessarily narrow delivery
windows and heavy fines for not meeting these targets, puts unreasonable
and "ungreen" pressure on drivers.
October 2007
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