Deliver UK - The RHA s Campaign Priorities These are the key issues for RHA: these are the areas where we are campaigning to persuade the Government to take action that will address our concerns and reflect the major contribution that the UK s road haulage industry makes to economic success. In addition to these industry wide subjects, there are many sector specific problems that are being addressed by the RHA s Functional Groups with the Association s full support. Contents Page No: 1) The Haulage Industry s image 2) Fuel Prices, Fuel Duty and Fuel Consumption 3) Standards and Enforcement 4) Roads and Congestion 5) Parking and Security 6) Vehicle Utilisation/Efficiency 7) Modal Choice 8) Carbon measurement and reporting 9) Regulatory Burden The Haulage Industry s image The road haulage industry provides a service that is part of the essential fabric of the UK. Every supply chain relies on trucks, linking companies with their customers and creating employment. We rely upon the people who drive and manage trucks for the food we eat, the clothes we wear, and the houses we live in. The costs incurred are met by us all, in the end. When haulage costs rise, it is felt in higher prices which hit those on lower incomes hardest. And yet, the industry often feels that it needs more recognition of, and support from policy makers for, the essential role that it plays. The industry in Britain is remarkable for its efficiency, its responsiveness to customer needs and its strong and improving record of road safety. Over some 30 years, innovation by the industry and its suppliers, and changes in legislation have reduced the number of trucks on the road to below 400,000 yet, at the same time, the car population has soared to more than 30 million. Modern trucks are 25 times quieter than 30 years ago and emissions levels from new trucks have reduced by at least 18 times since 1993. Publicly recognise the essential and high quality contribution that the road freight transport industry makes to the UK economy. 1
Fuel Prices, Fuel Duty and Fuel Consumption With fuel cost representing as much as 40% of the cost of running a truck, operators go to great pains to minimise the amount of fuel used, so putting up fuel duty will not give hauliers any greater incentive to save fuel. The competitive nature of the UK haulage industry is such that profit margins are wafer thin and this is made much worse by the fact that the UK has the highest level of fuel duty in Europe. UK trucks pay about 30 pence per mile in tax, whereas foreign vehicles pay nothing for the use of roads in the UK and this must be addressed urgently. Refresher training for drivers is now compulsory resulting in LGV drivers receiving on-going training in both safe and fuel efficient driving. Aerodynamics and vehicle specification also have parts to play in minimising fuel use, but investing in modern, more fuel efficient vehicles is difficult. Furthermore, the next step in clean engine technology could well mean a reduction in fuel efficiency. Tackle the unfair duty burden faced by the UK haulage industry in comparison with its EU competitors by charging a lower rate of duty on the fuel used by commercial vehicles and by ensuring that foreign vehicles pay for their use of roads in the UK. Recognise the high burden of taxation on the haulage industry from fuel duty, which amounts to a 25% tax on the operation of articulated lorries and to a carbon tax of more than 220 a tonne; work to close the fuel duty gap between the UK and other EU countries; and take measures to reduce the cash flow impact of fuel duty on professional transport companies. 2
Standards and Enforcement There are those in the industry that seek to compete unfairly by abusing the legislation that is there to protect fair competition, the environment and road safety. There is no place in this essential industry for those who put lives at risk by cutting corners and we look to the Traffic Commissioners and the Vehicle and Operator Services Agency (VOSA) to find the cowboys who deliberately and consistently cheat the system, put them out of business and keep them out of the industry. Around 100,000 trucks and many trailers in the UK are used by businesses with Restricted Operators Licences: they are limited to carrying only their own goods but the operator is under no obligation to employ the services of anyone who knows anything about the laws governing road haulage. Specifically, they do not have to hold or employ the holder of a Certificate of Professional Competence in Road Transport Operations. VOSA has identified a lack of appreciation of the laws governing vehicle operation in many of these businesses. Maintain the government s financial contribution to enforcement and increase the efforts to remove from the industry those who flout the rules and undermine safety and the reputation of the industry as a result. Establish a compliance forum, chaired by the DfT and involving enforcement bodies, the RHA and other trade associations to review compliance policy and how value for money can be optimised in future. Establish a programme to identify the main causes of crashes involving trucks and work with the Highways Agency and others to address the issues revealed. Consider whether it is sufficient to allow a firm to operate a fleet of heavy vehicles on own account without being required to demonstrate that it has appropriate knowledge of the rules of truck operation. 3
Roads and Congestion Everyone knows that manufacturers need to keep the production lines moving. The UK s roads are our production lines and we do not want to see vehicles delayed in congestion, whatever the cause. We need a road network that is developed, maintained and operated to a decent standard, and the Government must provide the funds required to do that. Trucks that are stuck in queues of commuter traffic are not efficient, so there are sound reasons for more no-car lanes that allow delivery and collection vehicles in and out of town and city centres. Maintain planned spending levels on roads, urgently improve road maintenance quality and work to ensure that high standards are set and achieved for local authority roads. Encourage local authorities to increase trucks access to priority lanes, such as Bus and HOV lanes. Develop a national debate on how to reduce congestion caused by cars through greater use of car share schemes, staggering of work start times and development of bus systems. Work with the police to reduce delays caused by accidents and the need for police to carry out investigations. Review speed limits for HGVs with a view to increasing the limit on some single carriageway roads from 40 MPH to 50 MPH. 4
Parking and Security The high value of loads carried on the UK s roads, together with the isolated nature of the truck and its drivers can make them a target for organised crime. The work of our drivers is regulated in such a way that there is a genuine need for facilities to have short breaks and longer periods of rest in locations that are inevitably some distance from their home base. Not only is there a shortage of facilities, many are inadequate in terms of both the services that people require such as food, accommodation and showers, and there is a real problem caused by the lack of even basic security measures at many of the sites. Recognise that there is a severe shortage of secure and driver-friendly truckstops and ensure that suitable and sufficient facilities are made available for drivers who are required to take breaks and rest periods away from their normal place of work. Provide adequate resources for Police activities in relation to truck crime and encourage the highest possible level of cooperation across Police Forces. 5
Vehicle Utilisation/Efficiency Once the decision has been made to use trucks, we must maximise their efficiency. A truck that is full most of the time is a both profitable and efficient and customers need to adapt their operations to allow maximum filling of vehicles. This can be achieved by loading and unloading from the side of vehicles, allowing double stacked/decked loads and ordering full loads. We also need planners to understand that many time restrictions were introduced when vehicles were much noisier than today. Large companies are able to fully utilise their own fleets, then sub-contract what s left over to others. Own account operators - that is those who carry their own goods - are unable to carry for hire thereby limiting their options. Many vehicles are unable to carry other products - for example many fuel tankers have no option but to go out full and return empty. On the other hand, refuse vehicles must go out empty and return full. Encourage users of haulage services to be more flexible in their required delivery times and particularly to accept more out-of-hours deliveries. Require planning authorities to review all access restrictions on the movement of goods vehicles by size, weight or time, reflecting changes in vehicle standards since restrictions were imposed. Implement a new process of active engagement with the RHA and others in identifying how public money can best be spent cost-effectively to improve further the effectiveness of the industry in serving the UK economy. 6
Modal Choice Consignors use six criteria in selecting the best mode of transport - availability, reliability, flexibility, security, speed and cost - cost being the total cost, not just one leg of a complex supply chain. There are also product marketing considerations, such as the growing need to be seen to be green. Fully understanding the carbon implications of the whole supply chain is vital as is the need to recognise that every mode has a role to play. A substantial element of rail freight is currently despatched by road hauliers, who are in business to serve customers. There must be a more sensible balance between the interests of road and rail that reflects the dominant role of road in goods movements. Trucks in the UK cover their track costs, and there is absolutely no point in increasing the tax burden on all trucks in the vain hope that the loads from some trucks might transfer to rail. Rail might play a part, but the initial collection and/or final delivery for the vast majority of products will be by road. One issue is the use of foreign vehicles carrying loads from Scotland onto mainland Europe, travelling by road down to the short sea crossings in SE England. These operators are replacing Scottish hauliers who used North Sea ferry routes from Scottish ports and produced far less CO 2. Stimulate a meaningful and balanced debate about the contributions road, rail, air and water can make to economic prosperity whilst minimising the impact of freight movements on the environment 7
Carbon measurement and reporting Manufacturers and distributors make decisions that include tradeoffs between transport costs and production costs. In some cases, such as aggregates, transport is so expensive that goods do not move far. In others, the cost of transport is a small part of production costs, so longer movements can produce substantial savings that are passed on to the consumer in lower prices. The cash cost is clear, but the carbon cost is not. For example, vegetables grown in Africa may well have a lower carbon cost by the time that they reach shelves in the UK because there is no need to use artificial heat in the growing process, despite the long distance freight movement. Fuel duty amounts to a carbon price of almost 230 a tonne and professional hauliers are well aware of the impact of the cost of diesel on their businesses. The RHA supports measures to build on the core culture of good driving, and effective scheduling of trucks and urges the use of available technology. We should recognise the complexity of carbon allocation in the transport industry and avoid developing a bureaucratic and unproductive burden of carbon reporting. The Government should Consider carefully the complexity of supply chains and the road freight sector in terms of carbon reporting, the key behaviours it is seeking to change and how such outcomes can best be achieved when considering imposing costly and intrusive regulatory burdens on road transport companies. 8
Regulatory Burden Road haulage is the essential link in the supply chain, but it does not receive the recognition that it deserves. Hauliers large and small are struggling to deliver the goods, whilst complying with the complex web of legislation that surrounds them. During the recession, customers have unilaterally reduced haulage rates and extended payment terms whilst at the same time suppliers to the industry such as fuel companies are demanding faster payments. During the last two years, fuel duty has increased by some 18%, and this has increased the working capital requirement for every vehicle by some 2000. The current financial climate means that this imposes a major additional burden on all hauliers large and small. Reverse the decision greatly to reduce the allowances available to road haulage firms from April 2012, which will have a profoundly damaging impact on the willingness of small and mediumsized transport companies to invest. Work to reduce the regulatory burden caused by two sets of overlapping but separate sets of EU rules on working time the Drivers Hours Regulation the Road Transport Directive on Working Time which add cost and confusion to both the industry and enforcers. Amend regulation 33 of the National Minimum Wage Regulations 1998 so that training agreements used to encourage small employers to invest in expensive training for their employees will not fall foul of NMW provisions if a deduction from salary is made upon the employment relationship ending within the validity of the agreement. Amend Health and Safety rules so that employers do not have same health and safety liabilities for remote and lone workers as they do for office based staff. Relieve employers of responsibilities for checking the right to work of their prospective employees. Amend Employment Legislation in order to increase the qualifying service from one year to two and make dismissal for gross misconduct simpler; Simplify disciplinary procedures for smaller businesses Require claimants in employment tribunals to pay the same level of fee as they would in any other civil court, perhaps with exception for those in receipt of Job Seekers Allowance; Simplify redundancy consultation by ensuring that the ACAS guide makes it clear that after the initial announcement that jobs are at risk, only one consultation meeting is necessary. Promote use of and simplify compromise agreements Reach agreement with HMRC in respect of a simple subsistence payment system. Allow public funding for statutory training that has to be provided by small and medium sized enterprises. 9