Road Haulage Association's Observations on the "Report"
Page 43
Page 44
Page 45
If you've noticed an error in this article please click here to report it so we can fix it.
A Precis of the First Fully Considered Association Criticism of the Recommendations of the Rail and Road Transport Conference
THE Association calls attention to the comprehensive suggestions it placed before the Conference on July 7. The Association had not the advantage of the same facilities as the Conference, but it is forced to the conclusion that, whilst the Association's suggestions if given effect would be a genuine contribution towards the solution of the difficulties which exist to-day with regard to the goods transport of the country, the effect generally of the recommendations of the Conference would be to the ultimate disadvantage of the nation industrially, and would involve notable injustice towards motor users generally and commercial-motor users in particular, with no other justification than to afford unfair preference to railway interests.
The Rif.A. was one of the three bodies invited by the Minister of Transport to attend the meeting on March 21. when the Conference was appointed. At that meeting strong objection was made by the R.H.A. with respect to those members appointed to represent road interests. The Association also caused questions to be asked in the House of Commons regarding the constitution of the Conference.
Grave Injustice to Hauliers.
It is maintained by the R.H.A. that the representatives of road transport possessed but slender claims to speak on behalf of hauliers. The IL.H.A. believes that it represented at that time more hauliers than any other body, and it unquestionably does so now. It therefore considers grave injustice was done to hauliers by excluding their representatives from taking part in the work of the Conference and thus impairing its representative nature.
The R.H.A. submits that the Conference had not the interests of road-transport contractors before it during its deliberation, and views the situation and the report with grave mistrust.
The terms of reference to the Conference were proposed by various individuals present at the original meeting, and those terms in general, after being summarized by Sir Cyril Hurcornb, were agreed at that meeting. Subsequently, the terms of reference were altered in a material way, and it is submitted that such alteration should not have been made without reference to all the representatives who attended the first meeting. As it appears to the Association that the Conference has reported on matters outside its terms of reference, the Association attaches considerable importance to this point. If it had been intended that the Conference was to recommend taxation to be imposed upon public-service vehicles, private cars, etc., then clearly, bodies representing those interests should have been present at the meeting on March 21 and represented on the Conference. Only goods representatives were present at the meeting and the Minister of Transport clearly stated that passenger transport was adequately provided for under existing regulations.
No Railway Improvements Recommended.
The R.H.A. particularly notes that the Conference has failed to make any recommendation with respect to the improvement of railways, but confines itself, with the exception of two minor points contained in paragraph 90(i), to proposals to restrict and .penalize road transport with the obvious intention of assisting the railways. Discussion appears to have been confined to road questions exclusively, and in such circumstances the presence of railway representatives appears unwarranted.
The Ministry of Transport, in the year 1931, provided ample evidence that the ancillary businesses owned by the railways, such as docks, hotels and canals, the collection and delivery of parcels, etc., arc, to a large extent, accentuating the position in which the railways are finding themselves. They do not compare favourably with the results of similar undertakings not railway-owned or controlled.
The R.H.A. comments on the incompleteness of paragraphs 11 and 12 in the report, which lead up to the use of the words " unfair competition" contained in paragraph 13, and to which it takes the strongest objection. Had paragraphs 11 and 12 explained that the railways have always enjoyed the free use of the roads and that, with the exception of " private-siding " traffic, they have carried all traffic over the roads to and from their system, the paragraph would have presented a truer picture and would have indicated the substantial subsidy which the railways have enjoyed and still enjoy with respect to their horse-drawn vehicles, which use the roads equally as much as mechanically propelled vehicles on similar work.
Incidence of Highway Costs.
The Association submits that as the Conference did not call any expert evidence, it was not competent to reach conclusions with respect to the wear and tear of the roads caused by different classes of vehicle. Although evidence in such matters is admittedly so vague and speculative, the Conference has not hesitated to translate mere supposition into definite proposals for taxation on each class of vehicle, by the exercise of mathematical ingenuity to prove what it wishes to prove. It is therefore submitted that those parts of the report which make recommendations • on matters requiring expert evidence should be treated with the utmost reserve, as the Conference was not properly constituted or competent to make decisions in such matters.
The R.H.A. is greatly concerned with the proposal to saddle motor users with the sum of £60,000,000, as representing the total costs of the roads. It does not consider that the roads should and will cost this sum annually for the next five years, neither does it agree that motor users should pay the whole costs when the roads are used by everybody.
The report gives the annual cost of the roads before the motor era at £12,000,000, but the Association suggests that thefigure is between £14,000,000 and £15,000,000, and converted to present-day costs of labour and material, cannot fall short of £28,000,000 as the amount which would fall on the public revenues even in the absence of motor traffic. This figure ignores all question of increased mileage, social improvements, many residential districts and housing estates created by new roads and the whole development of the road system since the war, all of which have increased the amenities enjoyed by the public.
Discrepancies in Statistics.
The Association questions the correctness of the figures furnished by the railway representatives and referred to as "railway track costs corresponding to those provided by public authorities for road users for 1930." The sum of £36,000,000 is given, representing 4 per cent. on £800,000,000, the money presumably spent on permanent way and corresponding to the roads used by road users.
From the returns issued by the Ministry of Transport, it would appear that the railways have included in this total figure many items quite apart from the actual cost of track, and there is no proof that the total given is not a seriously inflated one, viewed under the conditions of to-day.
In the same table the railways include the cost of signalmen at £6,500,000. According to the Ministry of Transport, the total for the year 1930 was £5,432,000, and for 1931. was £3,000,000, and it should be noted that maintenance of signalling is provided for in the sum of g18,060,000 stated to cover maintenance and renewal of tracks. The figure of 03,500,000 would therefore appear a gross mis
statement. The railways claim to pay £3,500,000 per annum in rates. The actual amount for the year 1930, according to the Ministry of Transport, was £1,650,000. In the year 1931, the sum is stated to have totalled £1,550,000.
The Association considers that these misstatements are serious in themselves, and it does not appreciate how they come to be issued by the railways, when the actual figures are so clearly set out in returns from the Ministry of Transport from figures provided by the railways. It is typical of the manner in which the whole report is prepared for presentation to the public.
Motor Users' Contribution to the Rates.
In paragraph 24, the report refers to road users as both taxpayers and, to some extent (although small in comparison with the railways), ratepayers. This statement is misleading and -incorrect. The paragraph clearly states road users, and therefore every class of motor vehicle is included in this statement, and the Association makes the following estimate:— If an average rate of 10s. in the be taken, the total
contribution to the rates by motor users is no less than 19,103,125, or six times more in rates than is paid by all the railways put together.
In paragraph 35 cif the report, it is stated that the railway representativer asked no more than that road transport should pay its fair share of the cost of the roads used as its permanent way, but in a memorandum addressed by the railways to the Minister of Transport on January 26, it was stated that it would ultimately be necessary to impose further burdens on the road industry which will have the effect of definitely adjusting the balance in favour of railway transport. The Association is forced to the conclusion that the railways are still advocating the policy contained in that memorandum.
In its statement that the community use cannot be calculated, it would appear that the Conference clearly recognizes that motorists should not be called upon to pay the total cost of the highway, and the R.H.A. is entirely in accord with that view, and if this basis were accepted it would naturally follow that the motorist would be called upon to pay less in taxation than that in eilstence to-day, as the report admits that the present taxation of motor vehicles equals the total cost of the roads. It would appear, however, that this did not snit the railways, and the R.H.A. submits that this is the sole reason for introducing the theory which immediately follows in the report and which is referred to as a "legacy from the past."
The Association consider that this "legacy from the past" theory is a dangerous and revolutionary one. It is equivalent to saying that the British Colonies should not. only be called upon to contribute to the upkeep of the British Navy, but to pay a calculated sum for the money and labour involved over centuries in building up the Navy to its present position.
If the theory be persisted in, surely the railways are enjoying a greater "legacy from the past" than motor users, because they have been entirely dependent upon the roads for serving their system with passengers and traffic. At December 31, the railways owned no fewer than 31,188 horsed vehicles, and the railways have enjoyed for many years the free use of the roads tor the employment of this large number of tax-free vehicles.
The banking of roads to carry them over railways, causing unnecessary gradients, the large number of weak bridges and level crossings are all " legacies from the past" which have been freely enjoyed for some considerable time by the railways.
B26
"Heavies" Use Only 24.3 Per Cent. of the Roads.
Class 1 and 2 roads are those mainly used by the heavier types of vehicle which are called upon to pay increased taxation. These roads represent only 24.3 per cent, of the total in the country, and it naturally follows that heavy commercial vehicles should be judged for taxation only in respect of that proportion of the total cost of the roads, and should not be called upon to pay full taxation in respect of classes of road they seldom use or are ever likely to use. It is true there might be some difficulty in so taxing commercial vehicles, but the fact of limited use should be met by a general reduction in taxation in respect of commercial vehicles.
The R.H.A. submits that the Conference ignored this limited use of the roads and was influenced by the fact that the heavier classes of vehicle are the types competitive with the railways. This influence is reflected in the recommendations.
The Conference has not made any allowance for the number of wheels employed by the heavier vehicles or the greater area of tyre in contact with the road. It is submitted that there is a definite relation between the wear of the roads and the wear of tyres. One must be dependent entirely upon the other. It does not follow that a vehicle of 12 tons must set up 12 times the wear of a vehicle of 1 ton. In this connection the following table of tyre costs is interesting. It is taken from well-known fleets of commercial vehicles :—
The R.H.A. considers that a table of taxation based on tyre wear must be a better indication of road wear than the method adopted by the Conference.
The conclusions of the Conference are based on rough and ready estimates and are not reliable.
The Association fails to understand why the compression-ignition-engined vehicle should pay substautially more
than a similar vehicle driven by steam. The fact that the former is more competitive with the railways on longdistance work than is a coal-burning vehicle, appears also to have influenced the Conference.
The Rebate to Vehicles In and Around Ports.
The Association sees no logical reason why vehicles engaged in and around ports should receive a 25 per cent. rebate as suggested, and subibits that this relief -is because the work is not competitive with the railways, and, furthermore, the railways themselves do a considerable amount of it. The road expenditure in providing by-pass roads to relieve congestion and the great cost of roads in towns over and above that in country districts, does not warrant the relief proposed.
If the recommendations in respect of taxation be carried into effect, there must follow greater use of the smaller classes of vehicle, resulting in increasing congestion. The Association submits that the employment of the larger classes of vehicle, usually in charge of experienced men and moving more slowly, is preferable from the point of view of safety, to a number of smaller types generally driven by younger and, perhaps less experienced men. Road transport should not be restricted in .respect of the classes of vehicle employed. The industry should he left free to conduct its business by vehicles most suitable to its requirements and thus provide scope for the greatest progress in vehicular design.
The report must also have the effect of encouraging a greater use of trailers, which, the Association submits, is not in the interests of public safety.
The Association is definitely of the opinion that the time has come when the taxation of all commercial vehicles, whether mechanically propelled or horse-drawn, should be equalized. The horsed vehicle carrying four tons from docks to station pays nothing. The commercial vehicle carrying an equal weight and on a similar journey is subject to penal taxation, although the latter is on rubber tyres and the former is steel-shod.
In the opinion of the Associatioe an impartial Assessment Committee, able to call expert evidence, would he the appropriate body to determine the cost of the high ways and the incidence of taxation, and it urges that a body composed on the lines of the Salter Conference is entirely unsuitable for such purpose. The Association also entirely disagrees that there is any ease for stabilizing the petrol tax at the present exhorbitant figure of 8d. per gallon.
Proposals for Regulating Hauliers.
The R.H.A. has, from time to time, made proposals with a view to regulating hauliers, and submits that the proposals put forward in its memorandum to the Conference under the heading of " Licensing for Hauliers " are the only requirements necessary in the interests of road transport nationally and road transport in particular. Whilst there may be grounds for a rigid system of regulation in iespect of public-service vehicles, and termed "Licensing," there can be no grounds for a parallel system in connection with goods transport by road.
The expression of opinion of the Royal Commission on Transport was that applicants for hauliers' licences need be considered from two aspects only : (a) fitness of vehicle ; (h) wages and conditions of service of persons employed in connection therewith. The R.H.A. claims that no other form of regulation is necessary to achieve these ends. It submits that the system of licensing proposed by the Conference must have the effect of restricting road transport, particularly for the benefit of railways,' that it can have no other effect and can fulfil no public need.
It is felt that the Views of the Conference expressed in paragraph 107 are dangerous, and it is unsound for road transport or any other form of transport to be subjected to the test of "existing transport facilities." The Association considers that by attaching the condition of fitness of vehicle to the licence, operators might be in danger of having their licences suspended if even one of their \ chicle ehonld be unfit at any time. Furthertnore, in the ease of nu owner-driver this condition would take away the livelihood of such an individual. In the recommendation of the Association, such danger is avoided because it would he quite possible for an operator to hire other vehicles during any period of maintenance or repair, and so retain his business connections, whereas under the proposals of the Conference he could not operate at all because his licence would be suspended.
With reference to paragraph 111 (sub-paragraph C.) the Association considers that the whole proposal is unnecessary and unworkable and is forced. to the conclusion that the dangerous and restrictive proposals contained in subparagraph D are included solely for the purpose of restricting road transport for the benefit of the railways.
It is obvious that the congested industrial centres developed in the past were due to the limitations of route which railways could provide. It is apparent that during the past few years there has been a tendency for factories to be placed in areas not served by the railways, thus ameliorating that over-population of restricted areas which has produced so many serious social problems since the inauguration of railways.
Agriculture has become to a large extent dependent upon road transport for distribution, and the proposals of the Conference, if put into practice, would have the effect of putting back rural districts into the isolation which, in the past, did so much to reduce the agricultural community of Great Britain.
The Association finds difficulty in discovering any logical reason why the ancillary user should be allowed to become professional haulier within a 10-mile radius, and recommends that this proposal should be ignored. If there is to be any system of registration or even licensing, then it should be compulsory for the railways to obtain licences in respect of any road haulage they may do, and the Association considers that it is time the railways were controlled in this respect, because they lost more than 11,000,000 during 11131 in respect of the collection and delivery by road of parcels and goods.
The R.H.A. again submits that hauliers should be registered under the conditions of (a) wages and conditions of service; (b) general suitability of applicant in the matter of knowledge of the business and resources to conduct it. In this connection the Commissioners should pay due regard to the smaller operator who, whilst possessing only limited resources, may be quite capable of conducting one or two vehicles in a perfectly satisfactory manner.
The ancillary user who carries his own goods exclusively would not require a licence, but should he desire to carry other people's goods for reward, then he should make application to the Area Commissioner for registration as provided.
The Association submits that it is practically impossible for journey records to be kept in respect of weights of commodities loaded, working time and rest periods of drivers, in the many classes of work conducted -by road transport in general. The records resulting could lead to no useful purpose either nationally or otherwise, and there is no more reason why such records should be kept for commercial goods vehicles than there is for them to be kept by the driver of every private motorcar.
The Association is opposed to any obligation as to the publication of rates being imposed upon the haulier. The principle is unsound from a common business point of view. The only basis of rate publication which would be workable is a general regulation of rates with respect to road and rail as recommended by the Association.
The Association's Conclusions.
It submits that the -report of the Conference is of no value and not a sincere contribution to the problem, but is almost wholly directed in favour of restriction of road transport for the benefit of the railways, and it would appear to the Association that the Conference has laboured with the pre-conceived idea that at all costs the railway system must occupy a paramount position.
The Association makes the suggestion that an impartial committee should he set up to inquire into and report to the Minister of Transport on the working of the railways fu Great Britain, and to make recommendations quite apart from other forms of transport, for railway improvement.
The observations conclude with copies of correspondence between the chairman of the R.H.A., the Minister of Transport, and the Road and Rail Conference.