A response to our letter of the 22 September was received on the 21 December 2018. As cautioned by the HTA, the DfT recognised that the appointing of a Transport Specialist to assess ad hoc and unpredictable moves was not required. However, the letter then went on to say that the current practice of applying the Reasonableness Test to both inland waterways and coastal shipping would continue.
In response the HTA sent a further letter to the DfT on the 25 February 2019. We pointed out that it is not current practice to apply the ‘Reasonableness Test’ to both inland waterways and coastal shipping and this application is in fact a change of policy to include coastal shipping.
The HTA explained that there is a long standing policy for ad hoc and unpredictable AIL moves using costal shipping to use the nearest convenient established port. Cases can and are made as to the nearest convenient port which take many factors into account. To name but a few; it could be that, a particular port offers a scheduled deep sea service or, there may be existing heavy lift crane or, mileage to the destination could be greater yet the route provides less impact on the SRN. The HTA cautioned against such a change in policy as significant disruption to the industry is a likely result.
We await a response from the DfT.