2018 Periodic Review Consultations response

Rail Freight Group (RFG) is pleased to respond to the consultations listed below as part of the draft determination for CP6.

Variable Usage Charge Consultation

FNPO and System Operator Draft Settlement Documents

Draft Determination – England and Wales Summary

Draft Determination – Scotland Summary

Enhancements in Control Period 6

Review of Network Rail’s Licence

This response covers all consultations in turn.  We have commented on the key areas for freight in these documents. As open access users of the network, the periodic review is of fundamental importance to the rail freight operators, and their customers. Decisions made will influence the ability of the sector to thrive, to grow new business and improve existing traffic and to encourage investment now and longer term.  Conversely, the wrong settlement could further undermine the position of freight operators, cause modal shift to road and lose private sector investment.

Overall, we consider that this draft determination, and the associated decisions, are broadly reasonable but we have a number of concerns;

  1. The level of increase of variable usage charges for freight in CP6 and CP7 is significant and risks loss of traffic to road. We consider a gentler increase in charges would mitigate this risk.
  2. The ORR’s impact assessment is weak and fails to properly address the impact on the freight market of the proposed increase in charges, including consideration of a wider range of options for mitigating these risks.
  3. Outstanding areas, including around the delivery of specific requirements of the Transport Scotland HLOS must be concluded in a timely manner
  4. The proposed changes to Network Rail’s licence, whilst better than the earlier proposals, remain weak for freight.

Read the full response at the link below.
RFG response to ORR charges consultation for PR18 draft determination Aug 2018