Respondents felt that the prevalence of empty running was overstated, and as discussed, the costs associated with moving vehicles meant road freight operators plan to reduce low utilisation. Amazon stated that their main limitation was not the capacity of vehicles but time and the need to limit the number of packages per vehicle to ensure all deliveries can be made on time.

For the grocery sector it was felt that a CUCC would be of limited value, with supermarkets generally served by full articulated HGVs, which have been loaded at Regional or National Distribution Centres (RDC/NDC).

Those representing parcel carriers were keen to stress that they provide a premium service, often at a relatively high price. They need to be able to deliver parcels between continents within 24 hours (or less) and any delay could result in lost business or fines associated with not satisfying Service Level Agreements. They also offer hourly delivery windows so any wait time at a CUCC would impact that area of their business. Collections are also important, with parcels picked up from customers as well as deliveries on the same round. A CUCC would need to reflect the need for a two- way supply chain.

Parcels are generally collected as close as possible to the next working day and as such late pick- up of parcels is required. Parcel operators offer specific time slots (e.g., pre 9am, 10am, midday).

Customers now demand the ability to track goods in real- time and many freight operators offer this service. It was felt that a CUCC, potentially operated by a third party (and possibly a competitor) would affect the ability of freight operators to accurately inform their customers of where their goods were in transit.

There is also an issue around the requirement for many businesses to estimate carbon emissions from packaging (Scope 2 and 3 emissions) and it was felt it would be challenging to determine which business is responsible for associated emissions if consignments were consolidated.

There was also strong reluctance to entrust the final delivery (or pick up) of a package to a third party, as any issues or delays would impact on the operator, with the level of service on the 'first or last mile' being to some extent out of their control. This is not a risk they would be willing to take, and this loss of control was cited as a major issue.

As discussed, AICES stated that express/parcel operators offer a premium service which allows customers to ensure time- definite recorded deliveries, having an area- mandated consolidation centre would mean express operators would have to relinquish control of a key part of their service, the final mile delivery. Without any control, or KPIs established this would severely undermine the service express operators provide and produce liability concerns if packages were lost or not delivered in time.

The Royal Mail has a legal obligation to deliver letters and parcels 6 days a week (known as the Universal Service obligation) and is currently the only provider who delivers letters (it not being a commercially viable operation). They are working with aspiring 'net- zero' cities to explore how they can be more sustainable and are establishing the basis for a virtual trial with third parties. However, one of the key barriers at Royal Mail to working with competitors is gaining support from the Communication Workers Union (CWU) that is resistant to Royal Mail parcels being given to a third party.

It was felt that customers would not want their goods carried by an operator that they had not commissioned and that there was often loyalty to a particular provider, with customers unhappy that a rival (in this instance) parcel operator undertakes the delivery (although this does happen to some extent in certain locations (e.g., Gnewt Cargo). The large parcel carriers are protective of their brand, which is often a major selling point.

In addition, freight operators generally have their own software for managing their supply chain and these are not compatible with other operators. For commercial reasons there is an unwillingness to share platforms and as such this is a barrier to the introduction of a CUCC.