EU - Transport Policy

Written evidence from Road Haulage Association (RHA) (EU 09)

The Road Haulage Association (RHA) is the trade and employers organisation for the hire-or-reward sector of the road haulage industry. The RHA represents some 8,000 companies throughout the UK, with around 100,000 HGVs and with fleet size and driver numbers varying from one through to thousands. The activities of RHA members are central to the effective functioning of the UK economy with more than 60% of goods moved by road.

Key issues

Vertical Integration of the rail freight s ector :The rail and road freight operations of Société Nationale des Chemins de Fer Français (SNCF) and Deutsche Bahn AG (DB)

We are concerned at the prospect of the creation of two vertically integrated tax-payer backed, land freight transport entities across Europe. Both SNCF and DB claim to be run as private companies, even though their loans are state backed and their operating budgets benefit from taxpayer cross subsidy. We understand that over 60% SNCF's 2009 (€600m+) losses occurred in its freight sector. 

Both entities are securing an increasing presence in the UK road freight market through recently acquired subsidiaries.

The considerable re-structuring of rail freight companies across Europe has not, in our view, been scrutinised properly by the authorities to ensure a level playing field with rival modes such as road. 

We are particularly concerned when state backed rail entities buy road haulage companies, and can then introduce predatory pricing in local road haulage markets.

Regulation 561/2006/EC-Driving and Rest Rules-Mutual Recognition of Enforcement Relaxation : The introduction of formal mutual recognition across Europe of local relaxations of drivers’ hours restrictions

Recent adverse weather related drivers’ hours enforcement relaxations in the UK, were not replicated across the EU. UK drivers have been told to make a note of the reason for their non-compliance with the rules on the back of their tachographs. There is no guarantee that European enforcement officials will accept this system and agree not to fine the UK driver.

Although drivers’ hours relaxations are allowed on a one off basis (Article 12-Regulation 561/2006/EC), they do not envisage relaxations lasting days if not weeks. We believe this issue should be addressed by the EC and Member States to ensure that drivers are not unfairly penalised abroad.

We believe that relaxations are likely to reoccur if severe winter weather becomes more common.

Supply Chain Security

Regulations appear to be made on the assumption that drivers can inspect goods carried prior to sealing and loading. In many cases commercial practice no longer permits driver inspection. However regulations make the driver liable if, for example, illegal immigrants are found inside a container.

We would ask the Committee to raise the disparity between the reality of modern practice and the position assumed by many regulations.

January 2011