Rail Freight Group (RFG) is pleased to respond to the consultation on changes to charges and contractual incentives.
We recognise the desire of Network Rail and ORR to increase transparency of charges, and to levy additional charges where this can be done legally and without adverse impact on the rail freight market. However, in low margin businesses even modest increases in charges can impact on the viability of operating, so ORR must set a high bar for assessing increases, and take into account the overall envelope of charges that an operator or customer is exposed too.
Given this, we are pleased that the ORR has concluded that for significant parts of the rail freight industry including intermodal and construction, a mark-up cannot be charged. This is particularly welcome. We also note that ORR proposes no change to the principle that a mark-up should be charged for coal, iron ore and spent nuclear fuel. In principle, we have no objection to this continuation, but this is subject to the level of the mark-up, and the overall charge, remaining affordable.
Click below to download the response in full.
ORR Biomass 2017 (1)