Memorandum from GPS Marine Contractors
Ltd (FT 24)
1. This submission is made from the perspective
of an inland waterways (Rivers Thames and Medway) operator with
term contracts for 760,000 tons per annum and that has historically
additionally won short term contracts for the transport of between
180 and 220,000 tons per year. We operate 5 tugs in the Thames
and Medway and 30+ barges between 150 and 1500 tons cargo capacity.
The principal cargoes carried are concrete aggregates and spoil.
2. The sustainable distribution fund is
something from which a company such as ours should benefit, yet
it is something of a mystery to us and, indeed, it is something
of which we have been unable to learn anything despite numerous
attempts to do so. We have in excess of 5 million tons of aggregate
in the ground that is suitable for recycling and that has to be
removed from site by barge, yet the intransigence of the Environment
Agency and the inaccessibility of the sustainable distribution
fund have combined to ensure that this valuable resource remains
untapped.
3. The major disincentive relative to modal
shift towards inland waterways transport in the Thames and Medway
is lack of suitable cost effective land. Suitable land, in this
respect, means land where port operations can physically be carried
out, ie where there is good water access and where the land is
suitable for the associated shore processes. Such processes may
be pure storage for onward distribution, but more frequently,
in our experience, inland waterways transport works best when
feeding riverside manufacturers or producers. Such sites are often
blighted by the proximity of residential developments whereby
the industrial or commercial process that the inland waterways
transport supplies often offends the sensibilities of residents.
These problems cause the shore based processes to incur additional
cost and expensive restrictions that would not be experienced
in other areas. Often in these situations out of hours tidal barge
change overs also cause problems with residents. In the UK today
one of the biggest disincentives to industrial and commercial
use of riverside land is cost. All riverside land is seen as prime
residential land and even protected status of some wharves has
not precluded their residential development. For this reason,
if for no other, riverside land has become prohibitively expensive
for industrial, and commercial operators compared to comparable
sites elsewhere. Modal shift towards inland waterways transport
of freight can be encouraged and incentivised by protecting potentially
useful riverside sites and making it absolutely certain that the
protected status cannot be overturned. Such a move would automatically
reduce the market value of such sites to levels at which commercial
activity becomes viable. A further incentive would be for government
to make it more difficult for normal commercial and industrial
activity to be deemed a statutory nuisance. In particular it should
not be possible for residents in new developments to object to
activities and uses of land proximate to such new developments
that existed prior to the new development being built. It is precisely
this type of objection that has caused numerous Thames wharves
to close and become lost to commerce over the past 20 years.
4. The Department must have more influence
and responsibility for planning and delivering integrated low
carbon footprint infrastructure. At the moment we have experience
and knowledge of terminal operators who discriminate against inland
waterways container movements in favour of road to achieve either
opportunity profit (ie increased profit unrelated to increased
cost, risk or operational complexity) or to support existing owned
lorry fleets. There is also a conflict between the aims of ODPM
and the Department, in that ODPM wants to exploit all brown field
sites on the banks of the Thames and Medway (Thames Gateway) for
residential development and this is at variance with the aim of
maximizing the potential for use of low carbon emission inland
waterways transport. It was precisely the inability of the Department
to influence the ODPM that caused the rail connected port of Rochester
(6 berths, 4 of which were non tidally constrained) to be lost
to trade in favour of residential development. It is undoubtedly
also the case that where UK port authorities have become independent
of central government control, or have to manage on relatively
small budgets with no significant potential to create wealth (eg
PLA), in consequence their imperatives are driven either by shareholder
concerns or by short term budgetary concerns rather than matters
of strategic national importance. For this reason dredging of
channels and maintenance of strategic port infrastructure is frequently
neglected and as a result facilities have become unusable. This
is vastly different from the situation in ports such as Rotterdam
where national government in the form of Port of Rotterdam Authority
deal with issues of strategic national importance as part of its
day to day activities without reference to shareholders who, of
necessity can not take into account the bigger picture. Within
any initiative that the Department might take to develop an integrated
freight infrastructure that takes advantage of inland waterways
transport, it must be appreciated that at the present time the
industry is suffering from an acute shortage of skilled labour
both operationally and in support sectors. Indeed, the shortage
of repair facilities and skilled ship repair operatives is a major
obstacle to the efficient operation of inland waterways vessels
and to the development of the sector. To eradicate these problems
consideration again has to be given to the price of land adjacent
to waterways, to the funding of repair facilities aimed at commercial
vessels as well as to the education and training of potential
employees (both operational and in support services). In attempting
to promote modal shift towards movement of freight by inland waterways
the Department must work more closely with MCA and, even more
importantly, MCA must consult properly with the industry it is
supposed to serve. Recent history is littered with inappropriate
consultations between MCA and the relevant sectors of the maritime
industries. The problems in MCA are endemic and are principally
a result of MCA staff being drawn from a very narrow sector of
the industry. It is a commonly held belief that MCA is not possessed
of a single person with specific detailed knowledge of inland
shipping, yet the Agency considers itself to be in a position
to "rubbish" the established principles by which the
inland waterways industries of mainland Europe are operated. Hence
the systematic disadvantaging of UK operators compared with their
European competitors.
5. Successive governments have been singularly
inept at ensuring a level playing field between UK and other European
inland waterways freight operators. UK businesses are unable to
compete in the inland waterways of other European states for 3
principal reasons. The first is that the UK opted out of EU directive
540 of 1987. In consequence of this UK operators at 01.07.90 have
been prevented from obtaining "grandfathered" licences
as inland waterways operators in mainland Europe. UK operators
are prevented from obtaining these licences through study because
the syllabus and examination is not available in English. Without
such a licence UK operators can not operate elsewhere in Europe,
but the UK will, and does, allow operators from elsewhere in Europe
to operate in the UK with impunity. The second reason is because
the recently adopted MCA National Fitness for Purpose Scheme is
in many ways more onerous to UK operators than the European standard
Rhine rules but the UK fitness for purpose scheme certification
is not recognised in Europe, whereas a vessel that is compliant
with the Rhine rules is automatically accepted in the UK. The
sensible approach to a national fitness for purpose scheme, one
that we advocated from the outset, would have been to adopt the
Rhine Rules "as is" and then to issue exemptions as
deemed appropriate to cater for specific national conditions.
In this way existing situations could have been accommodated,
a level playing field could have been created and the seemingly
deliberate disadvantaging of operators such as ourselves, compared
with operators in other EU countries could have been avoided completely.
This dreadful situation, one that could so easily have been avoided,
must be dealt with urgently by means of dialogue between industry,
the Department and MCA. The third cause of the UK inland waterways
industry being disadvantaged in terms of European competition
is as a result of education. Dutch, and to some extent Belgian
and German operators, can operate internationally more effectively
than their UK competitors because their employees enjoy a higher
level of education and this enables them to perform to higher
standards and to communicate more effectively in their own language
as well as in others. A massive problem for UK operators that
only government can address is the inability of our employees
to communicate adequately even in English with other native English
speakers. The possibility of their employees communicating adequately
in a foreign language is, unfortunately, only a distant dream
for the vast and overwhelming majority of UK inland waterways
employers. An example of this type of communication problem is
that of one of our masters, a 21 year old native Englishman, who
on 4 October 2007 was given instructions by another native Englishman
to load a barge with 20mm gravel at 08:10 and proceeded to load
it with sand at 08:15! Unfortunately this is anything but an isolated
occurrence; regrettably, it is instead indicative of a lack of
educational and temperamental ability that gives a lie to the
stated emphasis of government on education, education, education!
October 2007
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