RFG has no comment on the majority of the topics in the consultation. However there are some areas where there are potential impacts on the freight sector, which are covered in this response.
Overall, we recognise that the final determination must be fair, proportionate and give sufficient flexibility to enable Network Rail (NR) to undertake its business effectively. In achieving this, we also note that ORR must also take a proportionate approach to the impact on operators, and ensure that they also have a fair and proportionate outcome. This must include stability of charges, and appropriate risk transfer recognising the ability of different sectors to bear such risk.
The framework should also recognise the private sector nature of freight customers and operators and the cross modal nature of their businesses and choices.
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