Effective road and traffic management
Written evidence from t
he National Joint Utilities Group
Ltd
(NJUG)
(ETM 29)
1.0
NJUG – Introduction
1.1
The National Joint Utilities Group Ltd (NJUG) is the only UK trade association
solely
representing utilities and their contractors on street works issues. NJUG is a constructive organisation with a focus on promoting best practice, self-regulation and a two-way working relationship with Government and other relevant stakeholders. NJUG is also the utility arm of the Highway Authorities and Utilities Committee (HAUC(UK)) working collaboratively with local authorities, the UK Government and the devolved administrations to improve standards of road and street works in England, Northern Ireland, Scotland and Wales.
1.2
NJUG's members include the major gas, water, electricity and communications companies operating in the UK, as well as their contractors
. Including members through trade associations, NJUG represents thirty-seven utility companies and thirteen utility contractors.
1.3
Th
is submission
is focused
on the three points in the call for evidence where we have particular expertise – the prevalence and impact of traffic congestion and likely future trends
;
the extent to which the Government and local authorities should intervene to alleviate congestion and the best means to do so
;
and the effectiveness of legislative provisions for road management under the New Roads and Street Works Act 1991 and the Traffic Management Act 2004.
2.0
Executive Summary
2.1
Utility services are the essential fabric of the UK economy and
street works are
undertaken for four main reasons - safety, security of supply, to connect new customer or upgrade existing customers’ supplies, or to divert utility apparatus to facilitate major transport or urban regeneration projects such as Crossrail, the 2012 Olympics and Paralympics, tram projects, or new housing developments.
2.2
Utilities are investing billions to improve the quality and reliability of these essential networks. The Health and Safety Executive has placed a requirement on gas network owners to replace all cast iron gas mains within 30 metres of buildings; the water industry continues to replace its network of water mains, which often dates back to the Victorian era, to
reduce
leakage, and the communications industry is investing in the next generation of broadband networks.
2.3
This investment in the essential infrastructure on which we all depend
,
means that the volume of utility works will not decrease for the foreseeable future.
Therefore it is vital that
utilities and
lo
cal authorities, who have a statutory duty to co-ordinate all works
in the highway
, work together better to plan works and develop further innovative ways to reduce the disruption caused by
both utility
and highway authorities’ own works.
2.4
Utilities are sub
ject to a myriad of legislation/
regulation governing their street works
. Additionally, local authorities have a statutory Network Management Duty requiring them to ensure the expeditious movement of traffic and a specific duty to co-ordinate their own and utilities’ works. The primary legislation regulating utility street works
and t
he implementation of the associated Regulations and Codes of Practice has done much to reduce the unfortunate disruption that sometime arises from essential utility works. However, in order for the regulations to fulfil their full potential they need to be applied more consistently and effectively (as recognised in
a
previous Transport Committee Report
).
Equally, if Government is to implement further measures to regulate works in the street, it must be noted that utilities undertake only 50% of the works in the street, and similar incentives that already
exist for utilities
, and any new regulations,
should be applied to highway authority works which account for the other 50%.
2.
5
NJUG and the Local Authorities
, through the auspices of the national Highways and Utilities Committee (HAUC(UK)),
assist DfT
and
the Devolved Administrations in achieving their priorities. NJUG is
also driving forward numerous self-regulatory initiatives to reduce disruption and improve the quality of works, including implementing the National Code of Conduct (Section 4.0).
2.
6
DfT recently revised its Business Plan to reflect Government’s
overarching
priorities of deficit reduction, deregulation and localism
.
Measures
include
-
a substantial increase in S74 overstay charges; introduction of a daily charge for every day utilities occupy the highway (lane rental); and devolvement of approval of permit schemes to local authorities. The DfT has also decided not
to
honour the previous Government’s commitment to a one-year
independent
review of
permit
s
chemes
.
2.
7
However, Government has committed to reducing regulation and costs on business
. T
herefore
,
NJUG believes that
Government support for the range of self-regulatory measures
,
combined with effective and consistent implementation by all local authorities of the myriad of existing regulations/legislation will deliver a further improvement in street works and reduced disruption, without the need for
extra
measures.
Therefore, serious consideration of any additional regulations
/ increases
should
includ
e
a
rigorous assessment of costs and benefits
.
2.8
NJUG
therefore
wishes to continue to work constructively with
Central and Local G
overnment to ensure any proposals are robust and workable and do not place any unnecess
ary
additional costs on
utilities and
their customers
.
3.0
The prevalence and impact of traffic congestion and likely future trends
3.1
NJUG and utilities recognise that essential street works can sometimes cause unfortunate disruption
and are working hard to reduce it
.
3.2
According to an independent study
by Professor Goodwin (Professor of Transport Policy, University of the West of England) utility and authority works together account for only 10% of all congestion, on an approximately 50 / 50 basis, meaning that just 5% of congestion is caused by utility works.
T
he scale of disruption
for which
utilities are often blamed is striking in its contrast to figures provided by Professor Goodwin’s report, which shows that the "great majority of works cause delays of less than 20 seconds per vehicle".
3.3
Whilst utilities continue, through a range of self-regulatory measures (see section 4.0), to reduce the unfortunate disruption essential street works sometimes cause, given that just 5% of congestion is attributable to utility works,
it is clear that action by utility companies can only have a limited impact on overall levels of congestion – for example
a 20% improvement
by utility companies
w
ould
result in only a 1% reduction in congestion.
3.4
Whereas DfT forecast in their latest report (Road Transport Forecasts 2009 – Results from the Department for Transport’s National Transport Model
) that the volume of traffic will continue to increase at a rate of 0.5% per annum between 2008 to 2015. However,
"the return to economic growth, predicted to begin in early 2010 and to gain strength in 2011 is likely to lead to traffic growing more strongly than the average annual rate forecast for the 2008-2015 period."
3.
5
This means that all the work utilities are undertaking to reduce disruption can only be part of the solution, and there is a risk that any improvements will be dwarfed by the sheer volume in traffic as it steadily grows. Therefore it
is
important to recognise this when considering further legislative / regulatory measures, with a focus on address
ing
traffic volumes likely to deliver greater results.
3.
6
U
tility works are
highly regulated and are
controlled through a myriad of legislation / regulations. In addition to the wide-ranging provisions of the New Roads and Street Works Act 1991 already available to local authorities to manage street works, the Government has implemented a range of new provisions under the Traffic Management Act 2004 (TMA) – see section 5.0.
Additionally, economic regulators for energy and water further incentivise utilities to operate efficiently through five-yearly
regulatory settlements. Whilst
regulators’ statutory duties vary, their central objectives are to protect the consumer, by balancing investment for the future with price levels to customers and ensuring all works are undertaken as efficiently as possible.
3.
7
However, currently there are no financial incentives
for local authorities to carry out their work in a similarly efficient and timely manner even though they account for around half of all works.
3.
8
Scotland has an independent road works commissioner who is able to penalise both utilities and local authorities for failures to coordinate and cooperate
, which has proved to be effective at encouraging a more collaborative approach to reducing disruption
.
C
onsideration
should be
given to
how the benefits of this approach could be realised
in the rest of the UK
,
given
how effective it has
been in Scotland.
4.0
The extent to which the Government and local authorities should intervene to alleviate congestion and the best means of doing so
4.1
U
tilit
ies are
continually under pressure from economic regulators, road users, Government, local authorities, and the public to reduce the time works take, and so works are planned on the basis of ensuring the safety of the public and operatives and securing / enhancing their networks whilst taking as little time as possible. Yet street works
account for a small proportion of overall congestion, with
mostly arises
from
volume of traffic and road accidents
, and so
congestion alleviation policies need to
focus heavily
on these areas to be truly effective.
4.2
However,
we believe that
s
ome Government and local authority intervention is necessary to tackle the unfortunate disruption that utility
and highway
works can sometimes cause. The Traffic Management Act 2004 imposed a statutory duty on local authorities to manage their networks (The Network Management Duty), however currently there is inconsistent application by local authorities of the powers they have to help them fulfil this duty. More effective application would negate the need for further intervention by the Government.
4.3
I
n
the
light of cuts
in
local authority budgets
,
coupled with
devolvement of additional
responsibilities and powers
as a result of
localism, there is
a
danger
of
greater inconsistencies
in
interpreting and applying regulation
. This would place considerable burdens on utility companies, many of whom
have a
national
footprint
or work across many local authorities, and
who
would therefore be faced with a range of approaches a
cross their operating area,
increasing costs and creating a potential
for
inadvert
e
nt
non-compliance
.
Equally, i
t is important that the emphasis remains on
improving the quality and management of works rather than on revenue-generation.
It should not be forgotten that utilities already make a very significant contribution - in excess of £1.3 billion per year - to local authorities through "business (cumulo) rates" charged on their network assets, which are the assets that utilities carry out roadworks to maintain. At present, we understand that this contribution is not specifically allocated for highway maintenance
.
4.4
T
he
refore,
the most effective way of reducing disruption from works in the street is through Government and local authorities working in
partnership with utilit
ies
to better coordinate and manage works
to consistent standards
. NJUG has been working constructively with local authority and DfT colleagues through HAUC(UK) and with individual authorities across the UK.
4.5
Government
/
local authorities should also encourage and promote self-regulatory measures instead of further regulation, particularly
given
Government spending cuts
and
the
deregulation
agenda
.
NJUG has driven a number of voluntary initiatives deliver
ing
real benefits through
a step-change in the quality and impact of street works,
including
improved safety, quality, sustainability
, communication
and reduced disruption, as well as extensive sharing of best practice.
4.6
However, whilst we are seeing many examples of good practice becoming commonplace, we need to continue to
further
improve the safety and quality of works and find new ways
of reducing
disruption.
A summary of these voluntary initiatives is below:
4.
7
NJUG’s Vision for Street Works
[5]
–
Launched in early 2007 it reflects NJUG’s
commitment to supporting the implementation of the Traffic Management Act 2004 as well as existing street works legislation and codes of practice. It has gained high-level commitment from
the vast majority of
utility companies to deliver improvements in safety, sustainability, quality, co-ordination, communication and co-operation whilst reducing disruption and damage to underground assets, and has acted as a real catalyst for change.
4.
8
The Annual NJUG Awards
– Launched in 2008 to recognise the voluntary efforts being made by utilities and contractors to combat disruption and improve efficiency of works. There are six categories, one for each
Vision for Street Works
statement. Most importantly, the Awards provide examples of best practice, which are converted into case studies and shared across industry
.
4.9
Mayor’s London Code of Conduct –
Launched in 2009,
the Code is
a voluntary agreement between the Mayor of London and the capital’s largest utilities in order to reduce the unfortunate disruption sometimes caused by essential utility street works. In its first year it delivered:
·
Significant increases in the use of plating, out of hours working and first-time reinstatements;
·
Better co-ordination and communication including improved signage on sites;
·
Increased joint safety visits of local authorities, utilities, the Health and Safety Executive, and police who audit any works within the highway (from skips and scaffolding to highway and utility works), with any serious digressions tackled through a Joint Review process;
·
996 days saved occupation of the street.
4.
10
National Code of Conduct
[6]
–
The content of the London Code has been modified by NJUG so that it can be applied to the whole of the UK, and is intended to mirror the success the Mayor and NJUG members have achieved in the capital
.
The Code was jointly launched with the London Mayor in Summer 2010, and is being rolled out across industry. Discussions are
well advance
d
in
develop
ing
a HAUC(UK) Code in conjunction with authority colleagues.
4.1
1
Regional forums / conferences –
NJUG holds seminars to share good practice around the country and attend
s
national/regional conferences to spread good practice.
4.1
2
Improving co-ordination –
NJUG has also initiated many other voluntary initiatives and worked closely with highway colleagues – including:
·
Sharing plans of major works up to 2 years in advance
,
allowing
better
co-ordina
tion
;
·
Giving longer periods of notice than legally required for shorter-duration works;
·
Participating in the successful Workathons introduced by TfL – which take advantage of a road closure to bring in numerous different organisations to do small short-term works.
4.1
3
HAUC(UK) Strategy and Business Plan
-
With local authority colleagues, NJUG has developed
a strategy and business plan to support the delivery of the DfT Business Plan and Devolved Administration priorities
,
as well a
range of voluntary initiatives to improve the quality of road and street works. This is currently being updated to reflect new government priorities.
5.0
The effectiveness of legislative provisions for road management under the New Roads and Street Works Act 1991
(NRSWA 1991)
and the Traffic Management Act
(TMA)
2004
5.1
The TMA built
on
and improved the provisions of NRSWA 1991. Under
the
TMA
there is a wide range of legislation / regulation to enable local authorities to deliver their Network Management Duty. The success of local authorities in carrying out their network management duties and effectively utilising these legislative provisions has been very varied. However NJUG does believe the current legislative provisions
have delivered many improvements in the management of street works, a summary of which is below:
Improved Noticing (introduced April 2008)
5.2
The improved Noticing provisions require greater periods of notice to be given when utilities wish to undertake works. This allows local authorities more time to co-ordinate street works.
5.3
C
orrect and timely Noticing helps local authorities co-ordinate and manage street works.
Utilities have focused heavily on improving the timeliness / quality of Noticing, with numerous authorities reporting significant improvements since the Noticing requirements were enhanced in April 2008. Sustained awareness campaigns / training have emphasised the importance of
correct
Noticing, with many utilities reporting 97+% compliance. Equally, streamlining processes has reduced inadvertent non-compliance. Utilities continue to monitor their compliance levels and introduce proportionate and cost-effective measures to further drive towards 100% compliance.
S74 Overstay Charging (originally introduced in 2002 under NRSWA
1991
and then increased in April 2008 under the provisions of the TMA 2004
– with further increases being considered
)
5.4
Utilities are required to agree with the local authority the number of days that works will take. When introduced in 2002 S74 delivered a step-change in the reduction of duration of works
. Further
increase
s in the charge levels were introduced
in
April 2008
, but with
considerable shortening of durations already achieved
further significant reductions won’t be easily deliverable.
Fixed Penalty Notices
(FPNs)
(introduced May 2009)
5.5 In May 2009, the Government introduced the option for local authorities to serve a FPN including a fine of £120 (or £80 if paid within 29 days) for a range of Noticing infringements, such as late or incorrect Noticing. Local authorities retain the right to take a utility to court for persistent non-compliance, but the FPN provides a quick and cheaper alternative to penalise utilities for not telling authorities about their works in a timely and accurate manner.
Permits (introduced January 2010)
5.
6
Currently local authorities, either singly or together, may apply to the Secretary of State to run a permit scheme, which requires utilities, and local authorities’ own highways teams to apply for permits to undertake works. In granting permits, local authorities can apply conditions, including when works can take place. As with Noticing, permit schemes require greater notice to be given of works, including three months for works of 10 days or more. This allows local authorities to better co-ordinate
both their own and utility
works and thereby reduce disruption.
5.
7
So far, only three schemes have been approved.
The
common permit scheme in London requir
ing
permits for all works in all streets of those authorities who have introduced it
, regardless of whether the street is busy or not
.
In contrast,
Kent’s permit scheme
takes a more proportionate approach, by
focus
ing
on the major works on the busiest streets
to deliver maximum benefit for minimum administrative burden and cost. This is
based on the
general
principle that
about
80% of the disruption is on
approximately
20% of the streets
. The final scheme is in Northamptonshire
, which
has just gone liv
e in January 2011 and like the
Kent
scheme, it
focus
es
on strategic roads only which equates to around 19% of their road network
.
5.
8
NJUG
is also
work
ing
constructively with other local authorities to develop robust workable permit schemes that efficient
ly
tackl
e
congestion without placing unnecessary burdens on utilities
and
their customers, whilst
also
ensuring that essential street works programmes take place.
5.
9
However, NJUG has concerns about some local authorities’ operation of permit schemes.
The London Permit Scheme, introduced in January 2010, is not targeted to prioritise works on the most traffic-sensitive parts of the network
. It
is
therefore
unlikely to reduce congestion as intended, whilst imposing significant additional costs on utilities and their customers, particularly given inconsistent application of the scheme. Interestingly, on the day the scheme came into force London Mayor Boris Johnson commented that permits would
not
be effective in reducing congestion in London (despite having pushed for its early implementation) and that he wanted lane rental. In contrast, because the Kent Permit Scheme focuses on only the most congested roads, it enables utilities to prioritise those works. So far, the County Council has seen a 50% reduction in complaints about street and road works.
5.10
It is also worth noting that differing schemes add unnecessary additional costs to utilities, their customers and indeed local authorities, and increase inadvertent non-compliance because of the
many differences between schemes.
5.1
1
During the passage of
the TMA through Parliament
, the previous Government committed to evaluate the effectiveness of
permit schemes one year after their implementation
.
This was a commitment that we welcomed,
to enable the relative benefits and costs of differing schemes to be assessed
and
lessons
to be
learnt and shared. However, since the election, t
he DfT has stated that
due to funding restrictions th
is
evaluation will not now be carried out
by the Department. I
nstead
local
authorities
will
report on
the effectiv
e
ness of
their own schemes. NJUG believes that an independent assessment of both the London and Kent schemes will not only demonstrate their respective effectiveness and identify th
e full costs incurred, but will
also provide a valuable comparison of the two different schemes, enabling analysis and sharing of the most effective practices, for other authorities to consider when developing their own schemes.
5.1
2
NJUG therefore urges the Transport Select Committee to
emphasise the importance of
the need for
an independent assessment of the initial period of operation of permit schemes, and i
n the absence of
the Department for Transport carry
ing
out such an assessment,
we urge the Committee to
consider launching an inquiry of
its own.
Government’s current policies
5.1
3
The DfT’s recent Business Plan includes proposals to devolve permit approval powers to local authorities (delivery deadline April 2012); increase S74 Overstay Charges (delivery deadline October 2011); and to consult on and deliver lane rental regulations (delivery deadline December 2011).
These measures
will have a significant financial impact on utilities and their customers.
5.1
4
NJUG is concerned that implementation of these policies will require utilities to redirect their efforts to meeting specific regulatory requirements, rather than continuing to deliver further improvements through successful self-regulatory measures.
5.1
5
NJUG contributes to and supports robust workable regulation which does not impose unnecessary additional costs on utilities and their customers. For several years, we have been working closely with DfT and local authority colleagues to develop
e
ssential regulations and codes of practice to improve
the
quality and safety of works. As part of the Government’s desire to not impose further burdens on business, these workstreams have been delayed to allow further consideration of how to reduce their financial impact. However, in contrast,
the
DfT continue to press ahead with lane rental and increases in S74 which will have significant financial implications for utilities and their customers.
5.1
6
The administrative cost of managing and complying with these new regulations has increased substantially for both utilities and local authorities at a time when both are under pressure to make efficiency cuts. Furthermore, NJUG is concerned that
,
in light of how high the potential financial implications of these new regulat
ions are for both parties,
a greater focus will be placed on charging or avoiding charges at the expense of improving the quality of the works or developin
g new innovative ideas to limit the associated unfortunate
disruption
.
5.1
7
Therefore
NJUG believes that the existing regulations, if implemented consistently and effectively by all local authorities, would
further reduce
disruption caused by utility and highway works and therefore negate the need for
more
regulation. However, if the DfT wish to pursue additional regulations then NJUG would welcome an early opportunity to work with them to ensure that they are fair and workable
,
do not place unnecessary burdens on utilities and their customers
and apply to all works equally
.
Lane rental (S74a of the NRSWA 1991)
5.18
Lane rental
would be
an additional charge imposed on utilities
(
ultimately paid for by their customers)
for every day they occupy the highway regardless of how efficiently they undertake works. Given the myriad of regulation already available and the numerous voluntary measures introduced by NJUG, we do not believe that
lane rental will necessarily deliver significant
additional
benefits
over and above
the
existing legislation, whilst increasing utility costs considerably.
5.19
However, i
f lane rental
was
to be implemented
it
could
only be effective if applied to all works
promoters
- highway authorities as well as utilities
.
Additionally,
NJUG believes it should be targeted only at pinch points on strategic roads, where there are very high recorded traffic densities, and only in cities where there are a significant number of pinch points.
Any scheme should also be incentive
-
based, providing an opportunity for works promoters to work safely outside of critical / peak times and use plating during the busiest times to return the road to use, where practical and safe to do so,
or working in collaboration with others,
and in doing so avoid the charge
. This is a view that has been endorsed by DfT.
However,
the additional financial and social cost of
personnel work
ing
out of hours, and
the additional time factor of
putting down and removing plating each day need
s
to be considered when assessing the costs and benefits of lane rental.
5.20
The DfT has come under considerable pressure from key stakeholders
to expedite
lane rental proposals as soon as possible.
However, to have
a
chance of
making a difference
on overall levels of disruption
, any lane rental proposals
must
be equally applied to local authority works, who account for nearly half of all works, but which currently face no financial incentives or penalties to carry out works in an efficient and timely manner. According to TfL’s own figures
[1]
38% of London’s traffic delays are caused by road works, with half from utility works and half from local authority works. Prematurely implementing
the
proposals
target
ing
only utilities
would raise false expectations of having a major
reduction in
congestion, while imposing significant costs to utility customers
. T
herefore robust analysis of costs
/
benefits is vital before any implementation.
5.21
NJUG is also concerned that there may be a perverse incentive for authorities to manage works in such a way that delivers maximum revenue, rather than always reducing disruption
which must be addressed
.
5.22
Given
the
Government
’s interest in
enabling the
implement
ation
of
lane rental
,
NJUG would welcome the opportunity to work with DfT
/
TfL to develop an initial scheme targeted at pinch points on selected strategic routes in London. This should include rigorous assessment of the costs and benefits, with a full review prior to consideration of implementation elsewhere. Such benefits should be over and above those already claimed in the Cost Benefit Analysis for the introduction of changes to the Co-ordination Code of Practice, Improving Noticing regulations, FP
Ns
, Section 74 Overstay Charges and Permit Schemes.
Increased S74 Overstay Charges
5.23
Since its introduction in 2001, Section 74 Overstay Charging has delivered a step-change in reducing durations.
5.24
However
,
Government is now considering a substantial increase in S74 charges
. With considerable shortening of durations already achieved, NJUG has serious doubts whether a similar step-change to achieve even shorter durations is possible, given the need to maintain safety, quality and environmental standards
.
5.25
NJUG is also concerned that any such increase may lead to (i)
increased utility costs disproportionate to any benefit
and ii) encourag
e
some local authorities to
use
S74 as an income stream because of the large numbers of works involved, resulting in an increase in spurious
s74
charges and
FPNs not in the spirit of the HAUC(UK) Advice Note on FPNs
.
5.2
6
Utilities are alive to the cost/reputational damage of overrunning works, and are already incentivised to be efficient and minimise duration
s
of works through their economic regulatory settlements (gas, water and electricity) or commercial pressures (
tele
communications).
5.2
7
Utilities acknowledge the perception that nothing is happening if there is no-one on site, but there are often good reasons for this – such as concrete drying, waiting for a unique part to be manufactured (given that gas and water mains can date back to Victorian times) or workers having been diverted to an emergency. However utilities are taking
positive
steps to
minimise these and also
improve commu
nication with the public. F
or instance a number of companies have introduced new street signage explaining why there appears to be no activity on site
and the expected date works will be completed
.
5.2
8
However, as part of the NJUG National Code of Conduct (Section 4.0) we continue to encourage utilities to minimise durations of works at all times.
5.29
NJUG does not therefore believe there should be any further increase in S74 charges, as in the current economic climate S74 at its existing level remains a potent
drive
for utilities to minimise the duration of their works
.
Permits
5.30
NJUG is concerned that
the
Government’s drive for localism and
consequent
decision to devolve the approval of permit schemes by the Secretary of State to local authorities may lead to schemes being less focused on major disruption and more towards generating fees, all of which increases the administrative and financial burden on utilit
ies
and their customers. Additionally, with local authorities approving their own schemes, there is a risk that a) without a sense check by the Secretary of State, local authorities will unwittingly misinterpret the regulations and introduce overly burdensome requirements and b) numerous different schemes will lead
to inadvertent non-compliance
, and increased costs / administrative burden for utilities.
6.0
Recommendations
In summary, we would like to make the following recommendations for the Committee’s consideration:
6.1
Following the decision of the DfT not to
undertake the one-year
review
of
the effectiveness of permit schemes,
NJUG urges the Committee
to
emphasise the importance of there being an independent assessment of the initial period of operation of permit schemes, and
in the absence of a
D
fT
assessment, consider launching an inquiry of its own
.
6.2
We urge the Committee to call on Government to ensure that, in devolving the approval of permit schemes to local authorities, there are suitable safeguards in place
to
ensure that
:
·
A
uthorities are appropriately incentivised to deliver a balance between reducing disruption and ensuring the efficient and cost-effective supply of essential utility services;
·
A
uthorities don’t use existing/new regulation as a way of increasing income;
·
It is recognised that inco
nsistency of approach will add costs and bureaucracy, and also potential non-compliance by utilities and highway authorities;
·
M
echanisms
are
in place to share best practice so that individual local authorities do not all ‘re-invent the wheel’
.
6.3
NJUG also asks the Committee to consider
the proposed increases in S74 overstay charges and implementation of lane rental
, in light of the Government’s commitment to
not impos
e
further additional burdens on business
, and
given
the myriad of legislation already in place
to regulate
utility
street
works
. The
combination of significant self-regulatory measures initiated by NJUG
along with the TMA provisions
has
already
resulted in considerable improvements in the quality of works and reduced disruption
.
However, further improvements and consistency in implementing the TMA
could
negate the
need for
more
regulations.
6.4
We therefore ask the Committee to
urge
Government to demonstrate that any new regulations deliver additional benefits over and above existing regulation; that costs to utilities
/
their
customers are minimised; and that benefits considerably outweigh the costs.
6.5
Finally, we urge the Committee to acknowledge that utility works only contribute to a small percentage of overall congestion and that without applying equal incentives to local authority works, any new regulations will have little impact on reducing congestion.
February 2011
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