Transport Technical Paper [EXAM 114]

Summary of the Consultation
1. Central Bedfordshire Council are in the process of consulting on the Central Bedfordshire Local Plan examination, seeking new evidence.

Background about the RHA
1. The RHA is the leading trade association representing road haulage and distribution companies, which operate HGVs as profit centres. Our 7,200 members, operating near to 250,000 HGVs out of 10,000 Operating Centres, these range from single-truck firms to those with thousands of vehicles. These companies provide essential services on which the people and businesses of the UK depend.
2. We proactively encourage a spirit of entrepreneurism, compliance, profitability, safety and social responsibility. We do so through a range of advice, representation and services, including training.
3. We would like to thank Central Bedfordshire Council for the consultation and the opportunity to comment on the issues raised.
General Comments
4. We have not previously responded to the Central Bedfordshire Local Plan and wish to make the following points.
5. Road Freight is vital for the economy. Before and during the recent pandemic 98% of all food, medicine and other essential goods were delivered by Road Freight. This sector continued operating seamlessly throughout the crisis keeping Central Bedfordshire operating. At the same time many other businesses were forced to use alternative methods.
6. We support the improvements made to the M1 in Bedfordshire and welcome the partnership working with Highways England to improve traffic flows, journey time and reducing congestion from the Strategic Road Network onto Local Authority roads and visa versa.
7. The Technical Transport Paper – Exam 114 – includes the need to examine existing transport networks. There is one reference to freight, no mention of HGV, yet these are the vehicles that supply and deliver goods to all businesses and dwellings throughout Central Bedfordshire, enabling Central Bedfordshire business.
8. Rail freight is mentioned and the modal shift from road to rail, we fully support multi modal transport. The reality is that roads can be constructed faster than rail infrastructure and roads are required for final mile delivery.
9. We know that 5% of Central Bedfordshire businesses are Road Freight orientated and employ a high proportion of the Central Bedfordshire population.
10. We can find no reference to the provision of more Lorry Parking, or driver facilities for rest and welfare. This issue causes significant problems in areas of high HGV usage, we estimate there is a nightly shortage of more than 11,000 spaces a night. A high proportion of those are in the South East and Midlands.
11. The Department for Transport, National Survey on Lorry Parking in 2017 identified the East Midlands Lorry Parking utilisation as Serious.
12. The 2019 Highways England, Lorry Parking Demand Assessment rated the three Central Bedfordshire lorry parks at Critical. There is a clear need in Central Bedfordshire for additional Lorry Parking.
13. HGV drivers must take statutory breaks and rest. Lay-by’s and HGV parking facilities are needed for HGV’s prior and post delivery in towns. If these facilities are not provided it is likely that drivers will be forced to drive until they can find a suitable place to stop. This causes unnecessary congestion and other environmental issues.
14. We would highlight the beneficial environmental aspects of Euro VI Heavy Goods Vehicles which by 2021 will account for more than 72% of the UK HGV fleet. There are no viable alternatively fuelled 44 tonne HGV available in the UK at present. These vehicles have a lifespan of 12 years and carry the same load as 21 Transit vans.
15. It is essential that these vehicles are considered in all planning requirements.
16. During the pandemic Central Government has encouraged Local Authorities to introduce measures which have resulted in loading and unloading bays being removed. These and other restrictions have prevented trucks from being able to deliver and collect goods from business and other premises.
17. Careful consideration must be given to the unintended consequences of implementing any restriction which force HGV to travel on extended routes, resulting in more congestion and air quality deterioration.

Final Comments
18. The RHA welcomes the opportunity to work more closely with Central Bedfordshire Council for the benefit of all Central Bedfordshire businesses and residents.