Response to the Scottish Executive's Consultation Paper on the Review of Scottish Ports by the Scottish Policy Group of The Scottish Region of the Chartered Institute of Logistics and Transport (UK).
The Chartered Institute of Logistics and Transport(UK) at both UK and Scotland levels has an interest in matters relating to ports and maritime areas, since we have members working there and the industry is also an important sector relating to the broader professional activities of the Institute. In responding to this consultation, we have sought to deal with the Scotland perspective and to constructively highlight issues of relevance and some urgency, which we regard as professionally significant for the industry in Scotland. Recognising the UK wide implications of many of these issues, we have taken account of the broader context of the UK consultation and the paper - Modern Ports: A UK Policy.
2. General Comments.
Below, we comment more specifically on issues raised by the questions set down in the consultation but an overarching issue for the maritime sector is what is regarded as a lack of a particular and defined maritime policy (including ports issues) for Scotland. The contribution of the sector to the Scottish economy is vast and the demand for consumer goods handled in/out of our ports present ever greater challenges. Passenger traffic moving both within Scotland and via the Superfast international link, present considerable opportunities, emphasizing the need for Scottish Executive support for facilitating greater development.
A maritime policy for Scotland would therefore enable development, make clearer the pathways for development support eg the roles of The Executive v Transport Scotland, simplify legislative processes, assist in achieving a sensible environmental perspective, underpin personnel training, support tourism, accommodate infrastructure developments, help with EU State Aid and generally level the playing field with our EU competitors.
We are well aware of the capacity problems our colleagues in English ports are experiencing but also the similar issues for western seaboard ports of continental Europe. Such issues present challenges but also opportunities for Scotland, which we believe the Executive should be facing with the industry. Our responses to the questions raised are given below:
Q1 Current policy framework as set out in "Modern Ports: a UK Policy".
It is our view that a Scottish ports and indeed maritime policy has not yet been developed (2.2.6) and while there is much talk of an integrated policy that is still to be achieved. The principal constituents of such a policy are listed above under "General Comments". Mention is made in the paper of "lifeline services" and support given but we would liken support for piers etc (2.2.12) where "lifeline services" do not figure, to the requirement for railheads under FFGs for facilitating freight movement. Some circumstances will attract FFG support, while others fall to the operator to provide the finance. Much of the infrastructure for shipping is old and in need of replacement but companies do not generally qualify for financial support. We believe that the example of Ireland where infrastructure is driving economic development, should be examined and that the massive diversification across the industry within Scotland needs a special approach. The importance of infrastructure to the industry needs recognition and is rather similar to the importance of the permanent way to the rail industry. Scotland's large numbers of small islands, is peculiar to this country with their own landside problems for access.
We therefore believe that such specific issues make Scotland different to England/Wales which does mean that in certain areas, a "Scottish approach" is appropriate. However, the roles of The Executive and Transport Scotland are unclear and it is an issue for the industry to know who is taking responsibility for what. In addition, views on meanings within legislation eg the ISPS for passenger services are varied with differing opinions from different sources.
Compared with eg the road passenger transport sector, the maritime industry appears to be considered as a lesser priority, given its much smaller employee base but we would argue that its importance should rather be assessed on tonnages and passengers through ports and thus the significant support this gives to the Scottish economy. Indeed we see Scotland as being well placed to develop its potential capacity for serving UK and continental markets. To achieve this, Executive support in many ways will be essential.
The disparate responsibilities of the Executive and Transport Scotland need clarifying, so that there is a single voice articulating maritime and in particular ports priorities, towards smoothing the way for port and related development. In this way, ports would figure in the overall transport scheme of things and thus facilitate an integrated strategy. It is our opinion that currently, there is a measure of' silo thinking'. We appreciate the opportunities for consultation but question how this can be satisfactorily actioned, as things now stand. We recognize that the industry itself also requires to collaborate more and the Institute plans, in the near future, to put a paper to the Scottish Executive to propose a way forward.
Q2 Legislative Framework.
While we would not want to comment on specific legislation, there is a view that legislation too often overlaps and in some cases is perceived to conflict. For example, quayside and wet side laws can overlap and there are too many legislative sources which makes this area to an extent bureaucratic. Hazardous goods is a somewhat fraught and bitty area. Scotland differs from the rest of the UK, in that we have a broadly based industry by no means solely concerned with container traffic. Our differences partly drive the view that legislation as it now stands needs both review and simplification.
Q3 Environmental Issues.
The industry recognises the importance of the natural environment but also takes the view that commercial reality and reasonable protection of the environment must go hand in hand. In our response to the Transport & Works Act consultation we commented on the process of objection and recommend that our comments are reviewed within this context. We would emphasise the need for swift decision making and a strategy of recognizing that there are no absolutes in this area - mitigation is the keyword for mutual achievement of a satisfactory outcome. With the planning process often being long and expensive, the question has to be asked - to what extent does it stifle investment in Scotland ? How many businesses just go elsewhere?
Ports may be sometimes seen as potential polluters and on occasions are quite wrongly blamed for water pollution appearing water side. In fact, often such pollution emanates from land sources but ports are required to take responsibility. Clearly this has commercial costs and implications for businesses so involved. The Environmental Audit Committee (EAC) published a recent report on the poor success of the Department for Transport's progress in reducing carbon emissions. The Committee said "the DfT needs urgently to accelerate its efforts: transport is the only sector of the UK economy in which carbon emissions were higher in 2004 than the baseline year of 1990, and the only sector in which emissions are projected to be higher in 2020 than in 1990."
The Committee made several recommendations, many of which seek to encourage modal shift, in particular from road to rail. However, we believe that opportunities may also exist for short sea shipping which could contribute to a reduction in carbon emissions and which could provide potential for economic benefit.
Q4 Economic Impact.
We believe that in a modern economy, transport is the 'glue' holding it together ! Its economic benefit to the community at large needs to be recognized and ports play a significant part. Freight transport's contribution alone to GDP is circa 6%. Movement costs can be decisive to the overall competitiveness of a project, therefore efficiencies at ports and in transport play a big part in commerce's market success. The Institute is conscious of the lack of public awareness of the role of transport and indeed ports and airports, in the provision of everyday needs and desires. In support of the industry, the Institute is working with schools, universities and colleges to raise awareness of what Logistics and Transport is about but also to publicise the vast array of attractive careers which are available. Some companies via their social policies also provide support to communities, which assists in their being more alert to business functions in relation to goods and services supplied.
Q5 Training and Skills.
The maritime industry has massive training issues at every level. At ports level, there is a wide range of skills required but often there is no specialist training provider to meet the need. An example of this is straddle carrier training. We are aware of the Scotsim simulator for truck drivers and believe that this could possibly be modified to provide other specialized training, using software believed to be available in mainland Europe. The Institute is capable of providing management and broader professional training and is currently in conversation with the industry. In addition, such training can provide a professional mark of credibility and competence, however this does not eliminate the need for core skills training at many levels and for many types of operative.
Funding for the sector is also an issue, since this sector does not have its own Sector Skills Council. Funding issues are not however peculiar to ports, since other transport areas also find that financial support for taking eg Institute qualifications in Scotland is looked on quite/differently to taking them over the border. Occasionally, larger companies in the UK have set up there own range of skills' programmes, having the critical mass to justify this. Typically, these are modular and flexible. This is not viable in Scotland and government needs to consider how financial support can be given to facilitate the skills base needed to retain people in the industry and indeed in Scotland.
There is a need to draw together and co-ordinate incentives for ports and organizations outside ports, to gain benefit from working together. The Department for Transport is active in obtaining TENS funding where there is a UK department concerned with the interests of the sector. Similarly, within Scotland the same should be possible.
Planning issues for port development are well known and have been referred to above. The ongoing review and restructuring of the planning system are welcomed and the Institute has already commented previously on these. Our response to the TWA is also again relevant here and we cannot stress overly much the need for a slick process for applications, followed by a swift decision. Business development cannot wait for long periods for decisions and poorly handled applications can result in development elsewhere.
Q8 Links - Transport Scotland - RTPs.
It is rather early to comment on Transport Scotland and we would ask the question on what links there are at present to RTPs. Certainly, there appears to be something of a need for strengthening the freight priorities within Transport Scotland. The Freight Inquiry, may lead to some positive developments in this area and we trust that ports will also figure in this. The paper coming to the Executive from the Institute and referred to above, will also be relevant. We believe that RTPs could be valuable in facilitating developments in their areas but for this to be successful they will need to be 'hard wired' to Transport Scotland which in turn will have to be clear on its relationship to Executive departments having a finger in strategic developments.
Q9 Freight Links.
While many smaller ports major on passenger traffic with freight being secondary, we have in Scotland a considerable number of ports where this is not so. Freight is the core business and the surrounding transport infrastructure is key to moving freight in and out of these ports. When port developments are proposed, there seems to be some expectation that the port will fund the necessary transport infrastructure. This raises an issue of project viability and especially since it is known that ports in competition with UK ports situated in mainland Europe, benefit from state help. This is the 'un-level playing field'. If development is expected in Scotland and we believe that the Executive is serious about this, we would expect no less than competitors receive, who are also members of the EU. State aid which eg the Germans can source for capital and revenue funding support must be actively sought by the Executive and UK government.
We are not aware of any specific policy on passengers covering the range of sectors using ports and other facilities ie leisure, business, cruise liner, ferry and charters. We would ask how eg fishing fits in, have RNLI and RYA been consulted, how is all of this co-ordinated ? There are of course rules which apply to such activities but we do not see evidence for an overall policy. There are of course ways in which such a policy could be of benefit eg in attracting tourism and by integrating ports structure into transport developments overall. No 'one size fits all' policy would be appropriate a good example being that of security. With the appropriate infrastructure, flexibility and improved co-ordination, we think that passenger traffic could be enhanced. We are pleased to see that the Northern Link issue is now settled. Foul weather back-up can be an issue and for the Northern Isles, a port such as Invergordon could provide the ideal haven. Matters of this nature do illustrate the need for a comprehensive ports/maritime strategy.
Q11 - Funding.
Much has been said already in this paper on funding and in conclusion, the matter of equity across the EU in funding allocation is perhaps the principal message coming across. A clear Maritime Policy for Scotland would enable organizations to know where to go to make their case for funding and where this is from the EU, Scottish Executive support could make the difference adding weight to the Brussels process. There are many organisations to consider for funding - Scottish Executive - FFGs may apply for road/rail links, roads ? Scottish Enterprise etc. DDA announced funding for disability access for rail terminals but it doesn't apply to ferry terminals - a case for joined up thinking!
The closing date for submission of applications for the current round of Marco Polo funding is 11 October 2006. The follow up programme for 2007-2013 will include new measures such as motorways of the sea. It has a budget of £400m and the Commission boasts that every £1 spent on Marco Polo will generate an impressive £6 of environmental and social benefits. We believe that a Scottish Maritime Policy could facilitate shifting some freight from road transport to short sea transport by way of a pro-active Executive approach.
The timing of this consultation in relation to the UK Ports Consultation, seems to have led to a very short period for responding. We would have welcomed more time but trust that the Executive will carefully consider our efforts to try to provide a comprehensive response, within the time allowed.
The CILT Logo is a registered trademark of the Chartered Institute of Logistics and Transport
Unless otherwise stated, site and contents © John G. Fender 1997 - 2017
Site designed & maintained by John G. Fender