Memorandum from the British Ports Association
(BPA) (FT 43)
1. The BPA represents a broad cross section
of ports in England and Wales operating in diverse markets. In
particular, it represents the overwhelming majority of ro-ro traffic
which, together with container traffic, is an area of significant
growth. All ports are dependent on their links to the national
transport network and it is the efficiency of this network that
underpins the success or otherwise of the freight industry.
We very much welcome the Committee's inquiry.
Although we are not sure what "an integrated freight plan"
might look like, we believe that it is right to consider the freight
industry as a sector in itself rather than as the sum of the various
modes on which it depends.
A successful freight industry is absolutely
fundamental to any successful economy. It underpins manufacturing,
distribution and retailing, improves business productivity, the
efficiency of the labour market and reduces cost to the final
consumer. We believe that a successful freight sector has implications
significantly beyond its own internal efficiencies.
2. Nevertheless, the main conclusion of
our response is that although efficiency of the freight industry
can be delivered through a range of improvements which we identify
below, a full blown integrated freight plan, given the complexity
of the freight market, is, in our view, not necessarily achievable
or desirable. This is not to endorse entirely current arrangements.
Much of the UK has a mature transport system and is reasonably
well connected. What is now needed is targeted investment with
careful thought given to transport projects which can have the
maximum effect on freight efficiency. We therefore believe that
there are a number of pragmatic changes that can be made which
could improve the efficiency of freight movements. Our aim would
be for a freight policy rather than a freight plan.
The UK ports industry is the largest in the
EU. The UK has an increasing dependence on imports, especially
high value manufactured goods; port growth has been almost entirely
the result of import growth, particularly in containers and ro-ro.
Ports overwhelmingly rely on their road links. 66% of all goods
by volume are transported to and from ports by road in England
and Wales. Ports are therefore vital components of, and influences
on, the pattern of freight movements. Compared with other EU member
states where provision of transport infrastructure is substantially
a public sector activity, the UK transport sector is characterized
by a mix of private and public sector finance and ownership. This
creates particular challenges in achieving an integrated approach.
Changes that the rail industry has undergone since the early 1990s
are a case in point. The winding up of the Strategic Rail Authority
and the consequent return to public control of a large part of
the rail industry is an example of the state of flux within which
this major sector has had to operate.
3. Added to this is our experience that
generally, passenger traffic has policy priority, certainly where
road and rail are concerned, and especially rail which has had
to cope with unforeseen and dramatic rises in passenger numbers.
We are not convinced therefore that an integrated freight plan
would sit easily within this complex mix. Nevertheless, there
are a number of changes, some already underway, which could be
beneficial to freight efficiency and which could build on existing
arrangements. These are:
(i) Transport link priorities : Despite the
importance of international trade to the UK economy, current policy
is not to treat ports any differently from other industrial developments.
Not only is this an underestimation of the value of port links,
it has also led to the situation whereby the government is increasingly
looking to ports to fund connecting infrastructure. This has been
confined so far to container developments but we are alarmed at
the potential for the policy to be applied to other developments
across a wide range of ports some of which are better placed to
fund connecting infrastructure than others.
The Eddington Report published in December last
year made a particular point of underlining the value of links
to ports, described as "the key gateways for UK trade".
The report saw strong cost benefit ratios for investment in surface
access to ports ranging between 3 and 15 and estimates the cost
of investment to be between £10 million and £170 million.
We strongly support the approach of targeted investment in high
return schemes such as links to ports.
(ii) Changes to the planning system: It has
long been our contention that the planning system across a range
of transport projects, including ports has failed to deliver.
We have supported, with various caveats, the government's intentions
as outlined in recent consultation on a Planning Bill. We agree
that the setting up of an Infrastructure Planning Committee for
large projects and the creation of a new Marine Management Organisation
for port and other marine developments below a high threshold
does, in principle, hold out the prospect of improvement. Responsibility
for the licensing of developments is currently scattered thinly
across various government departments and agencies resulting in
inefficiencies and the need for a number of licences for a single
project. We look to impending legislation therefore as a very
significant and much needed change to the current planning regime.
(iii) Transport charging: We believe that
there is a place for local road charging schemes as a means of
raising revenue and introducing the possibility of better traffic
management. We very much support targeted schemes addressing current
bottlenecks and which clearly demonstrate to road users the costs
they generate. Much congestion is created by the private motorist
and schemes could be developed which prioritized freight traffic
at certain times and in certain locations. The revenue raised
could also be used to make local access improvements.
(iv) Border Controls: A factor affecting
port efficiency, particularly for ro-ro traffic, is the burden
of border controls, particularly those exercised by Customs, Immigration
and Special Branch. The government has just initiated a border
review aimed at unifying some of the functions of Customs and
Immigration and we believe that a radical re-thinking of the way
in which the Agencies work and cooperate is required.
(v) Role of RDAs: With the abandonment of
Regional Assemblies, RDAs have been given more responsibility
to devise transport plans which underpin regional economic growth;
the port industry is cooperating much more extensively with RDAs
about regional infrastructure needs and we see this as a vital
part of supporting the freight industry in the future. We are
looking at the potential for port master planning whereby each
port identifies the pressures it will place on the transport system
so that the RDAs can factor these into their spending plans.
(vi) Sustainable Distribution Fund: The take
up from the UK ports industry of grants under the SDF has been
low, partly because of the complexities of applying but also because
anticipating the number of lorry journeys saved is difficult.
We are currently in discussion with the DfT on the future construction
of the SDF and whether potentially sound schemes are being unnecessarily
eliminated under current rules. Although we do not believe that
there is huge potential for modal switch from road to water, we
do believe that the SDF could be more finely tuned to identify
niche markets susceptible to change.
4. In summary our main conclusions are:
(i) Although we do not necessarily see the
need for an integrated freight plan, we do see the need for integrated
transport policies.
(ii) Ports as key influences on freight patterns
should receive priority for investment in their infrastructure
links; such investment would bring GDP benefits.
(iii) Proposed changes to the planning system
create the possibility for speedier planning decisions.
(iv) Road charging and RDAs should be significant
factors in the future.
October 2007
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