Written Representation:

HeyshamPort

regarding the application for

Development consent to complete

the Heysham to M6 Link Road

IPC Reference: TR010008

On behalf of

Transport Solutions

for Lancaster and Morecambe

(TSLM)

Unique Reference: 10015381

7th May 2012

1Introduction

1.1The port of Heysham is one of several west coast ports traditionally serving the Irish and Northern Ireland sea freight market. One of the arguments put forward for the HM6L is that the port is fast growing and well placed to capitalise on a growing market for sea freighttransport between the west coast, Irish and Northern Ireland ports. Whilst port related activity and employment is to be welcomed it is also clear that Heysham is a relatively small player in a rather volatile market and arguments for a new road costing upwards of £120 million should not be based on the extremeuncertainty and unpredictability of Heysham’s importance as a west coast port over the next 5-6 decades. It is also clear that the Port of Liverpool which like Heysham is part of the Peel Ports group has the potential to increase its throughput by approximately 70% by 2030 (Mersey Ports Masterplan 2011) and that Liverpool’s geographical location near to very large centres of economic concentration and associated origins and destinations for freight traffic will give Liverpool a significant competitive advantage over Heysham during the period covered by its Masterplan.

2Heysham and Irish Sea traffic

2.1The Port of Heysham exists in a highly competitive market occupied by at least 6 ports. Table 1 lists these ports which we will designate as the “Irish Sea Group” or ISG and lists the annual tonnage at 3 time points

Port Traffic of the Irish Sea Group, 200-2010, in thousands of tonnes

2000 / 2005 / 2010
Heysham / 3723 / 3676 / 3461
Fleetwood / 1530 / 1635 / 1137
Liverpool / 30421 / 33775 / 30020
Stranraer / 1506 / 1155 / 1017
Cairnryan / 2283 / 3274 / 2634
Holyhead / 3444 / 4147 / 2658
TOTALS / 42907 / 47662 / 40927

Source: Port Freight Statistics: 2010 Final Figures, Department for Transport, September 2011

2.2Table 1 reveals some basic characteristics of Irish Sea freight traffic:

  • Heysham was responsible in 2010 for 8.4% of the total freight throughput in this port group
  • Irish Sea freight traffic declined by 5.3% in the period 2000-2010 and declined by 15% in the period 2005-2010
  • Heysham’s’ figures show a small decline of 1.3% in the period 2000-2005 and a decline of 7.1% in the period 2000-2010

2.3These data are also discussed in a Lancashire County Council report revealing the problem of decline at the Port of Heysham and the relatively small scale of port activity in Lancashire (0.9% of the UK total). The report summarises port traffic in the following table revealing an 8% decline at the port of Heysham in the period 1997-2009:

Table 1A Lancashire and other selected UK ports, foreign and domestic traffic, 1997 to 2009
Traffic (thousands of tonnes) / Percentage change
1999-2009
1997 / 1999 / 2001 / 2003 / 2005 / 2007 / 2009
Grimsby and Immingham / 47,991 / 49,757 / 54,831 / 55,931 / 60,686 / 66,279 / 54,708 / 10.0
London / 55,692 / 52,206 / 50,654 / 51,028 / 53,843 / 52,739 / 45,442 / -13.0
Milford Haven / 34,518 / 32,187 / 33,192 / 32,737 / 37,547 / 35,496 / 39,293 / 22.1
Tees and Hartlepool / 51,249 / 49,316 / 50,842 / 53,842 / 55,790 / 49,779 / 39,183 / -20.5
Fleetwood / 1,362 / 1,368 / 1,608 / 1,624 / 1,635 / 1,772 / 1,327 / -3.0
Heysham / 4,069 / 3,370 / 3,824 / 4,083 / 3,676 / 3,586 / 3,102 / -8.0
Lancaster / 121 / 112 / 117 / 156 / 111 / 123 / 121 / 8.0
Liverpool / 30,841 / 28,913 / 30,288 / 31,684 / 33,775 / 32,258 / 29,936 / 3.5
Manchester / 7,939 / 7,825 / 7,879 / 6,088 / 7,222 / 8,079 / 6,670 / -10.9
All UK ports / 558,530 / 565,614 / 566,366 / 555,662 / 584,919 / 581,504 / 500,863 / -11.4
Source DfT: Maritime Statistics

Source:

Ship arrivals at Heysham have shown a 40% decline in the period 1999-2009:

Table 6 Ship arrivals, 1999 to 2009
Number of vessels / Percentage change
1999-2009
1999 / 2001 / 2003 / 2005 / 2007 / 2008 / 2009
Fleetwood / 787 / 965 / 909 / 888 / 931 / 461 / 752 / -4.4
Lancaster / 225 / 206 / 225 / 145 / 151 / 134 / 163 / -27.6
Heysham / 3,484 / 2,922 / 2,390 / 2,701 / 3,290 / 2,490 / 2,086 / -40.1
United Kingdom / 153,961 / 145,434 / 152,896 / 146,182 / 139,662 / 130,551 / 119,038 / -22.7
The arrivals recorded relate to movements of all sea-going vessels of 100 gt or over.

Source:

2.4A similar story is revealed in Isle of Man port statistics (Isle of Man Government, 2011). The Isle of Man has been linked to the port of Heysham for a very long time but in the period 2000/01 to 2009/10 general freight in tonnes (excludes oil and gas) declined from 95022 to 79472, a reduction of 17%. The decline in the period 2005/6 to 2009/10 was 19%.

2.5A recent Competition Commissionreport (CompetitionCommission, 2011) drew attention to the economic problems associated with Irish Sea traffic:

2.6A recent study of NW ports (NWDA, 2009) identified the unpredictability of market conditions applying to Irish Sea traffic and the uncertaintysurrounding which port would actually benefit from changes in those market conditions:

Source: NWDA (2009), page 34

2.7Irish sea freight traffic and the Port of Heysham do not exhibit long term, sustained, vigorous growth and if a commercial organisation were intent on putting together a business case for new investment these data would not provide a credible evidence base for borrowing money or for asserting a rate of growth into the future that would produce an acceptable rate of return on the investment. It is a telling point that no commercial organisation connected with the Port of Heysham or the nuclear powerstation at Heysham has come forward with any financial support for the HM6L. If the HM6L is seen as an importantcomponent of the economic success or functioning of port or nuclear powerstations it would be reasonable to expect some financial contribution from both. None has been forthcoming.

3Capacity issues on Irish Sea freight routes

3.1Ireland and Northern Ireland have a combined population of 6.4 million which is 1.2% of the European Union total of 501 million. Ireland has a service based economy with 66% of total employment in services. The combination of a relatively small population and a relatively high service-based economy means that trade flows between theUK, Irelandand Northern Irelandare likely to remain relatively small. This relatively small amount of freight movement is served by a high number of ports. These are listed below

Northern Ireland Ports

Irish Ports

Drogheda

Dublin

Dundalk

Dun Laoghaire

Cobh

Waterford

Rosslare

Source:

The Irish Maritime Transport Economist, Volume 8, April 2011

UK Ports: Stranraer, Cairnryan, Heysham, Fleetwood, Liverpool, Holyhead, Fishguard, Pembroke

3.2Referring back to Table 1 we have a situation with approximately 40 milliontonnes of freight handled by 6 UK ports and having the option of utilising10 Irish and Northern IrelandPorts. Whilst there are no specific data on port capacity on Irish Sea freight routes the offer of 6 UK ports and 10 Irish/NI ports to deal with freight from and to a relatively small regional economy (1.2% of the European Union population) can be regarded as generous and subject to volatility as operators switch traffic between ports in response to their own commercial imperatives.

3.3This shifting of traffic between ports is likely to be a continuingfeature of Irish Sea freight traffic and adds to volatility and uncertainty. A recent example of this shift occurredbetweenFleetwood and Heysham:

Source:

The Irish Maritime Transport Economist, Volume 8, April 2011

Page 23

Another example is the possibility that the Isle of Man Steam Packet service will shift to Liverpool:

THE Steam Packet has signalled it is considering pulling out of Heysham harbour and concentrating its services on Liverpool instead.

In a radio interview, chief executive Mark Woodward said Liverpool was a ‘clear favourite’ of the majority of passengers and freight customers.

He said that the creation of a bespoke, in-river berth at Liverpool would be ‘serious option’ for the Steam Packet looking to the long-term, allowing the use of bigger and more capable ships.

Mr Woodward’s comments came as Liverpool city councillors revealed they were in talks with the Steam Packet about sharing the landing stage of a new River Mersey cruise liner terminal at the Pier Head.

In his interview, Mr Woodward said there may well be arguments about whether Heysham was the right harbour for the company in the long term.

He said the Steam Packet had long and historic links with Liverpool which was ‘clearly the destination of choice’ for the majority of passengers and freight customers.

Source:

Isle of Man Today, 7th February 2012

3.4Volatility also occurs from year to year in response to market conditions and changes in the macro-economy.

Irish Sea freight traffic declined by 18% in 2009 when compared with 2008 and this overall aggregate decline included a decline of 9.5% in Ro-Ro traffic

According to the Central Statistics Office (CSO), the amount of goods handled by Irish ports during 2009 fell to 41.9m tonnes of goods, compared with 51.1m tonnes in 2008.

Goods received decreased by 19.5pc in comparison with 2008, while goods forwarded fell by 14.5pc.

Meanwhile break bulk and other goods traffic decreased by 47.5pc in the year, roll-on/roll-off traffic by 9.5pc, lift-on/lift-off traffic by 15.6pc, liquid bulk traffic by 9.1pc, while dry bulk traffic decreased by 29.7pc

Imports accounted for 69.3pc of the total tonnage of goods handled while exports accounted for 30.7pc, the CSO figures showed.

The annual port figures also showed a 10.2pc drop to 13,223 in the number of vessels arriving into Irish ports in 2009, compared with the 14,729 reported in 2008

Source:

3.5A final source of volatility can be found in the very ambitious plans of Peel Ports for port development in Liverpool. The argument normally made in favour of Heysham emphasises that it is well placed to capture road freight for the Irish/NI market because it minimises road freight distance and provides the industry with a much better offer of cheaper sea miles compared to expensive road miles, applies a fortiori to Liverpool. Liverpool is a “much better bet” than Heysham in a world dominated by the desire to minimise road miles and take advantage of cheaper sea miles. This “better bet” also brings Manchester into the market for Irish Sea traffic and a higher level of use for the ManchesterShip Canal adding yet more capacity to Irish/NI freight traffic routes and more competition for Heysham

3.6Peel Ports currently have a Masterplan for its Liverpooloperationthat includes a 70% increase in traffic from 39.64 million tonnes in 2008 to 68.58 million tonnes in 2030. This is a hugely significant addition to Irish Sea freight route capacity and the map produced in the strategic plan shows Liverpool in the pole position for serving the Irish/NI market. Heysham is not included in this map which was prepared by the owners of the Port of Heysham.

3.7The scale of the Liverpool/Manchester ambitions is very large indeed:

3.8The Peel Ports masterplan for Liverpool and Manchester will deliver a very large increase in port capacity for Irish/NI sea freight in an area that is extremely well connected to the national motorway network and to a regional economy embracing the whole city region of Manchester and Liverpool and far more opportunities for reducing road miles of freight than can be offered by Heysham. The harsh reality in a strong competitive commercial world is that Heysham will not beable to compete with Liverpool and the intrinsic volatility of Irish Seafreight traffic will combine with even stronger competitivepressures that will lead to the switching of traffic away from Heysham.

4National Policy on Strategic Routes

4.1The DfT has designated a number of routes and corridors that are of national importance including those that serve Northern Ireland and Ireland. Norman Baker (the relevant minister) was quoted in a DfT press release dated 23rd May 2011:

The A1 north of Newcastle to the Scottish border has been made a route of strategic national importance following a consultation, Regional and Local Transport Minister, Norman Baker, announced today.

The move sees approximately sixty-five miles of the A1 join a key list of nationally important roads.

It is part of the Government’s move to ensure the economic importance of routes from England to the capital cities of Scotland, Northern Ireland and Wales are properly recognised.

A number of roads linking Bootle with Twelve Quays Ferry Terminal in Birkenhead, Merseyside, will also become a route of strategic national importance. This is because it is the main passenger and freight ferry terminal for traffic travelling between Liverpool and Belfast.

Norman Baker said:

"The important changes I am announcing today will ensure the economic importance of routes from England to Edinburgh, Belfast and Cardiff are properly recognised.

  • As a result of the changes two additional routes will be recognised in future as being of national strategic importance
  • The A1 north of Newcastle – between its junction with the A19 at Seaton Burn – to the Scottish border (providing a defined link to Edinburgh)
  • Approximately nine miles of Local Authority controlled roads between Bootle and Twelve Quays Ferry Terminal in Birkenhead, including part of the A565 and the Kingsway Tunnel (providing connectivity with Belfast).
  • The full route is as follows:

A565 from junction with A5036 in Bootle to A5063 "Leeds Street"; then

A5063 "Leeds Street" from junction with A565 to A59 "Scotland Road"; then

A59 "Scotland Road" to "Kingsway Tunnel"; then "Kingsway Tunnel" to grade separated junction with A5027; then

A5027 to junction with A5139; then

A5139 to A554; then

A554 to Twelve Quays Terminal entrance

Source:

4.2The May 2011 ministerial announcement followed a consultation and report on the consultation in September 2010 which considered which ferry port to designate as the national strategic terminal for Belfast traffic. The report not only favoured Birkenhead but did not even include Heysham in the list of candidates.

4.3There is no mention of Heysham and its role in serving Irish Sea traffic in ministerial announcements or documentation from the DfT dealing with routes of “strategic national importance”. It is clear that Heysham and its road links are not regarded as part of

“a route of strategic national importance”

This sits uneasily and illogically with the designation of the HM6L as a nationally significant infrastructure project (NSIP).

5 Is there a problem with HGV ferry traffic on the existing highway network?

5.1 It has been argued that the existence of large numbers of HGVs arriving at and departing from the Port of Heysham produce a strong argument for a bypass that would divert many of these HGV trips from the existing urban highway network onto a new road, potentially benefiting both the HGV trips and congestion on the existing road network especially at peak hours. Under these circumstances HGV journeys would, in theory, save time and fuel, and the road would underpin the operation of the Port, so adding to the economic case for a bypass. We have carried out a statistical exercise to test this position and find that the majority of HGV trips take place outside of peak hours and in relatively non-congested conditions on the urban highway system. The results of this analysis are presented in Appendix 1.

5.2The analysis in Appendix 1 clearly shows that only 4-6 out of 18 sailings are potentially affected by peak traffic conditions on the local roads network and then only to a limited extent; and no less than 10 of the 18 sailings arrive or depart in the evening or night, when journey time savings would be minimal. We conclude that the scale of benefits attached to HGV journeys for example through time savings and reductions in fuel costs are, in fact, very low and are unlikely to provide a compelling case for a bypass.

6Conclusions

6.1This contribution to the evidence base for considering the case for the HM6L concludes that there is no credible argument for investing a very large amount of public money in a road scheme to connect the M6 with the port in such a fragile and volatile market. This would appear to be the view of central government which has opted for 12 Quays at Birkenhead for its favoured strategic option for serving Northern Ireland. Port related arguments for the HM6L do not stand up to analysis and evaluation and it is highly unlikely that the next 2-3 decades will see a steady rise in freight traffic through the Port of Heysham. The whole Irish Sea freight market is highly volatile and unstable and subject to changes in ownership of shipping lines, the switching of ships from one port to another, changes in the scale and sophistication of logistic offers by those ports pursing very ambitious masterplans and changes in the economy itself which have shown the Irish Sea trade to be very vulnerable to economic difficulties.

6.2The commercial reality is that there is no case for investing in the HM6L on logic related to the future economic success of the Port of Heysham or its role in handling future levels of IrishSea freight traffic. If this were the case then there would be an argument for a public private partnership with those profit-taking enterprises that would benefit from Heysham’sfuture growth actually contributing to this small piece of an infrastructure jigsaw. The commercial world that appears to support the HM6L is clearly not willing to back its rhetoric with cash and that is a telling point in the debate about the rationale for the road.

6.3The commercial world does not back the HM6L, central government has excluded it from its designation of routes of strategic national importance and our analysis confirms that Heysham cannot produce a robust business case to support £120 million of public investment in road infrastructure.

References

Competition Commission (2011), StenaAB and DFDS A/S Merger Inquiry. A report on the completed acquisition by StenaAB from DFDS A/S of certain vessels and assets operated on the Irish Sea

Isle of Man Government (2011) Digest of Economic and Social Statistics, Table 13.3, page 82

Mersey Ports Master Plan. A 20 year strategy for growth. Consultation Draft. June 2011

NWDA (2009) NW Ports economic trends and land use study. Final report

Appendix 1

DEPARTURE / ARRIVAL
0000-0059
0100-0159 / 1
0200-0259 / 1
0300-0359
0400-0459
0500-0559 / 2
0600-0659 / 1*
0700-0759
0800-0859 / 1**
0900-0959 / 2**
1000-1059 / 1
1100-1159
1200-1259
1300-1359 / 1
1400-1459
1500-1559
1600-1659
1700-1759 / 2***
1800-1859 / 1
1900-1959
2000-2059
2100-2159 / 3
2200-2259 / 1
2300-2359 / 1

HEYSHAMPORT FERRY TIMETABLES AND PEAK TRAFFIC CONDITIONS

  • Figures are numbers of sailings arriving or departing each hour of the day (source: web sites of respective ferry operators); some variation in days of service operation, omitted for simplicity
  • Figures in red are sailings most likely to be affected by peak hour traffic conditions on roads accessing the port (but see notes below).
  • Isle of Man ferries are included, but have times varying by up to one hour either side of the time allocated in the Table: in no cases are Isle of Man ferry arrivals and departures anywhere near peak traffic times.
  • Shaded times are peak traffic hours.

Notes: