Written evidence submitted by Road Haulage Association (RHA) (SRI0043)

 

Summary of the Call for Evidence

 

The strategic road network in England comprises more than 4,300 miles of motorways and major A-roads. The Department for Transport plans improvements to these roads through five-year road investment strategies and sets priorities for the strategic road network. The Transport Select Committee inquiry will look into how well the current Road Investment Strategy (RIS2) is being managed, and what the Government’s priorities should be for future investment.

 

Responses to questions
 

How effectively the RIS2 enhancements portfolio has been managed to date

 

Some areas of the RIS2 enhancements portfolio have been managed well to date, however there are significant improvements and lessons to learn as we plan for RIS3. We welcome the noted enhancements in response to the Government’s Smart Motorways Stocktake.  We believe that safety and road user confidence whilst using Smart Motorways is paramount and these enhancements will help with these objectives.  However, we seek clarity on whether the funds to complete these enhancements are to be diverted from other projects.

 

We also note that many of the major enhancements that are delayed are due to the Government’s Smart Motorways Stocktake and relate directly to the roll out of Smart Motorways.  For example, the numerous upgrades of dynamic hard shoulder running to all lane running contained in the National Highways Delivery Plan.

 

We are concerned by delays to two major projects in particular – the Lower Thames Crossing and the A27 Arundel bypass.

 

With reference to the Lower Thames Crossing, although we are aware of the planning constraints impacting the project and opposition from some stakeholders, we are concerned that the planned start of works being quarter four of 2024-25 will have an ongoing impact on our hauliers and other commercial vehicle operators that transit the current Dartford Crossing.  The Lower Thames Crossing is a project that we believe will offer vital roads resilience when the Dartford Crossing is either closed or congested.  Although we have caveated our full support with the need to introduce commercial driver facilities into the project, we do believe that the estimated date for the commencement of works needs to be revised to the original date.

 

Regarding the A27 Arundel bypass, the delay to the start of works is disappointing.  As the main road serving the south coast, the A27 is a crucial route through the southeast.  However, as it passes through Arundel it operates well over capacity and causes disruption and severe congestion.  Given the significance of the location to the industry we would like to see the planned start of works of 2024-25 bought forward and therefore the planned completion date of 2030 bought forward.

 

Finally, we seek further clarification on the performance metrics outlined in the latest National Highways Delivery Plan particularly concerning delays.  The current KPI is for performance to not be worse at the end of the second road period than it was at the end of the first road period.  We believe that an improvement should be factored into performance metrics.

 

Overall, we believe National Highways have made significant positive developments during this Road Investment Strategy period.  For example, we welcome National Highways Smart Motorways stance, and we commend them for their engagement on projects such as the A47 works, A27 Arundel bypass, Lower Thames Crossing and A14 improvements. 

 

Whether risks to the enhancements portfolio for the remainder of the RIS2 period are being well managed

We agree with the National Audit Office report dated 25 November 2022 said that the Department for Transport and National Highways could have done more to manage potential risks to the portfolio of works in RIS2. In particular, we note the following concerns:

 

 

What the impacts of delays and cost overruns are on the overall programme, and whether the revised programme can be delivered to schedule and on budget

 

We note that the National Audit Office report dated 25 November 2022 stated that the Road Investment Strategy 2020-25 will have completed less work on road enhancements and at a higher cost than originally planned.  The added costs are due to delays in carrying out work on various projects combined with inflationary pressures in the economy.

 

We also note that the cost saving from removing the 11 smart motorways schemes from the programme has already been overtaken by cost increases in the remaining projects.

Given increasing inflationary pressures and ongoing delays, we have concerns whether the remaining programme will be delivered in its entirety and on budget.
 

What progress is being made on planning for the next Road Investment Strategy

 

We note from the National Highways Delivery Plan that there is currently a RIS3 pipeline of schemes that are to be included.  We seek clarification on which of these schemes are residual schemes of RIS2 and which of these schemes are new projects specifically for RIS3.
 

We also note that engagement is taking place with the Sub-National Transport Bodies.  Although this a positive step, we believe this engagement should include industry trade associations.

 

Looking ahead to RIS3 planning, engagement so far between the Department for Transport and RHA has been limited and we would like to see engagement including stakeholder events staged on a more regular basis to allow for input to be given.

 

What lessons from RIS2 need to be incorporated into RIS3 to ensure it is achievable and delivers on policy objectives

 

There are a number of lessons to be incorporated into RIS3. The RIS2 plan was a challenging and complex portfolio which has faced obstacles from legal challenges, planning consents and the impact of inflation. In many cases, these obstacles could have been foreseen and the governance management and deliverability of the RIS2 portfolio must be evaluated to ensure the RIS3 plan accounts for these lessons.

 

The 33 projects in RIS2 requiring Development Consent Orders presented a significant risk to the deliverability of the overall portfolio. Although 14 consents have been gained through the DCO process, this is less than half of those required.

 

Improvements to cost control are also vital. Costs must be better planned and controlled before the contingency budget is used with a realistic assessment of the risks to the portfolio and individual projects. The contingency fund for RIS2 may have been underestimated given the risks to the portfolio. For RIS3, the scale of the contingency fund should be better assessed and the pressure of the carryover of projects from RIS1 and RIS2 should be managed. Due to delays from RIS2, there will be very limited headroom for new projects in RIS3. The strengthening of DfT’s senior capability in managing Tier 1 projects is welcome and should be maintained.

 

The geographical spread of RIS3 projects must also better account for the Government’s levelling up policy ambitions.

 

Adequate roadside facilities should also be planned for RIS3 major road schemes and enhancements. Driver facilities with sufficient lorry parking should be recognised as part of our national infrastructure but too often are met with local resistance. The Department for Transport’s recent lorry parking survey showed there was a critical level of usage of overnight parking spaces. Private investment is available to enable this but the barriers of obtaining planning consent are significant.

 

The renewal capital spend and maintenance must also take account of the backlog of bridges and structures which require upgrades.

 

Whether the Government’s current and forthcoming roads investment programme is meeting the current and future needs of consumers and business
 

The UK road network, in particular the Strategic Road Network (SRN), is our members’ workplace.  Commercial vehicle operators need roads that are fit for purpose and allow for consistent, reliable and predictable journey times.  Any cutting of budgeted projects risks under developing the infrastructure that our industry needs, which is vital to future economic growth.

 

We agree with the concern from the National Audit Office report that the majority of the £11.5bn committed for RIS3 is focused in the south-west, south-east and east of England. We call on the government to confirm the full 31 projects outlined for RIS3, and to consider other projects in areas in need of additional government investment.

 

Given delays and shifting economic and political priorities, we would welcome additional consultation with key stakeholders in order to ensure RIS3 brings about investment across the country and is targeted most effectively.

 

Whether the Government’s roads investment programme aligns with other policy priorities, such as decarbonisation, levelling up, productivity and growth
 

We ask that future iterations of the Government’s road investment programme are clearly embedded within its decarbonisation and levelling up initiatives, and is part of a coherent roadmap. This will ensure that it is adequately aligned.


Our starting point is that we are clear that, to meet the needs of people and businesses, goods and passengers must be moved via the road network in an efficient and predictable way. Congestion creates unpredictable and longer journey times. This leads to waste, creates unnecessary emissions, undermines productivity and the competitivity of the UK economy. As the Government’s Net Zero Agenda additionally gains momentum, we look for coherent policies that minimises congestion and creates the conditions that allows investment in the infrastructure necessary to power low and zero emission commercial vehicles. Against this backdrop, we make the following points.

 

Firstly, since RIS2 was formulated, the Government has published a raft of strategies to address decarbonisation and, via its levelling up agenda, productivity and growth. It is essential that subsequent iterations of the Government’s road investment programme clearly aligns with these strategies.

 

Secondly, we observe that, whilst the aims contained with the decarbonisation and levelling up strategies are laudable, there is little underlying detail to coordinate the necessary activity. For example, whilst the dates for stopping the sale of ICE vehicles are clear as part of the Government’s Transport Decarbonisation Plan, the underlying regulatory detail that is essential to support the investment decisions of businesses is either unclear or piece-meal. This was flagged in the National Audit Office’s report Achieving Net Zero in December 2020, and the absence of a timely and supportive regulatory framework persists.

 

A case in point is the promised review of the National Networks National Policy Statement (NN NPS) - last written in 2014 and which sets the framework the Government uses to inform its investment in roads – but has not been completed. Alongside a refreshed National Policy Planning Framework, an updated NN NPS is one of the components necessary to ensure there is a clear and co-ordinate roadmap to allow businesses and public authorities to invest in decarbonisation initiatives. We also await the long-overdue Low Carbon Fuels Strategy where we anticipate the Government signalling which low carbon fuels it is prepared to back.

 

Finally, whilst we welcome the commitments set out in National Highways’ Net Zero Highways plan to support planned initiatives to decarbonise HGVs (such as the investment needed in infrastructure to power electric HGVs), it is not clear why National Highways has chosen the year 2020 on which to set its baseline for measuring subsequent reductions in carbon emissions from users of its network. We consider that 2020 is not a representative year of traffic volumes, given the Covid-19 lockdown restrictions imposed which severely curtailed traffic use on the network.

 

How RIS3 should take account of technological developments, and evidence on ways of increasing capacity on the Strategic Road Network (such as smart motorways and potential alternatives to them)
 

National Highways is developing the third road strategy against a backdrop of uncertainty in road usage and changing technology. The road haulage industry requires regulatory certainty to allow them to make the investments in new technology that the industry and the economy needs.


We believe that RIS3 and any future roads investment strategy should take into account the latest technological developments and evidence on ways of increasing capacity on the Strategic Road Network (SRN).  For example, RHA welcomed the announcement that the roll out of Smart Motorways would be paused until five years’ of safety data had been gathered.
 

On RIS3 specifically, National Highways will need to consider the planning of roadside facilities and what infrastructure those facilities will need e.g. electric vehicle charging, hydrogen refuelling etc.


In our view, Smart Motorways have a potential part to play in the future of increasing capacity on the SRN.  However, in order for this increase in capacity to be effective, it must be done in a way in which is safe and commands public confidence.  Taking this safety-lead and evidence-based approach is the correct way forward.

 

Background about the RHA

 

The RHA is the leading trade association representing road haulage, coach and distribution companies who operate HGVs, coaches and vans commercially. Our 8,500 members operate near to 150,000 commercial vehicles.  Members range in size from single-vehicle businesses to those with thousands of vehicles.

 

These road logistics companies provide the people and businesses of the UK with the goods and services upon which we all depend. From food and clothing through to medicines, car parts, construction material and passenger transport.

 

 

February 2023