===== PAGE 1 ===== # Department for Transport # SPaTS - T0195 CUCC Compulsory Use of Consolidation Centres Reference: | 24 August 2022 ===== PAGE 2 ===== # Document Verification Project title Compulsory Urban Consolidation Centre Study Document title Phase 1 Report Job number 287361- 00 Document ref Final Draft for Approval File reference SPaTS - TO195 CUCC
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1.0 24/08/2022 Description Compulsory use of Consolidation Centres
Prepared byChecked byApproved by
NameTom Zunder
Paul Davison
Sara Gilmore		Martin SchulzMarco Boettcher
Signature
Filename Description
Prepared byChecked byApproved by
Name Signature Filename ===== PAGE 3 ===== # Description Prepared by Checked by Approved by Name Signature Issue Document Verification with Document ===== PAGE 4 ===== # Contents 1. Executive Summary 1 1.1 Introduction 1 1.2 What is the problem? 1 1.3 Key findings 2 2. Semi-systematic literature review 3 2.1 Objective 3 2.2 Context 3 2.3 Gear Change 5 2.4 Definition of (Compulsory) Urban Consolidation Centre 5 2.5 Categorisation 6 2.6 Key findings 6 2.7 Direct legal regulation 8 2.8 Controlled territory 8 2.9 Receiver procurement led to consolidation 9 2.10 Construction consolidation centres 11 2.11 Enablers, opportunities, barriers, and risk 13 3. Legislative Review 15 3.1 Objective 15 3.2 Restricting the entry of delivery vehicles to a particular area 15 3.3 Charging delivery vehicles to enter a particular area 16 3.4 Building a CUCC 16 3.5 Compelling a delivery to a CUCC 17 3.6 Delivery from a CUCC 17 3.7 Delivery models identified in the Literature Review 17 3.8 How could the implementation of these delivery models be challenged? 18 3.9 Summary 20 4. Stakeholder Consultations 20 4.1 Introduction 20 4.2 Approach 20 4.3 Awareness and rationale of CUCCs 21 4.4 Barriers to CUCCs 21 4.5 What models of operation would be most effective? 23 4.6 Summary 24 ## Tables Table 1: Proportion of road air quality pollutants attributable to freight, 2019, NAEI 4 Table 2: Topic search terms [\* excluded] 29 Table 3: Key Bibliographic Projects on Grey Literature 30 Table 4: CASP list for inclusion/exclusion adapted from [27] 30 ===== PAGE 5 ===== ## Figures FiguresFigure 1: Greenhouse gas emissions by sector, 2019, BEIS [89] 4Figure 2: Conceptualisation of a UCC, Verlinde et al., [50] 5Figure 3: Gothenburg retail freight 'train', [64] 9Figure 4: Disconnect between end receiver and carrier, Verlinde et al., [50] 10Figure 5: The Good City, Trafikverket, [72] 11Figure 6: Typical CCC configuration, TfL, [81] 12Figure 7: Different stakeholder experiences of CCC, Janné, [85] 13Figure 8: Semi- systematic literature review, [34] 26Figure 9: Domains associated with Urban Consolidation Centres (UCCs), Wed of Science 27Figure 10: Recent publications regarding UCCs, Web of Science 28 ## Appendices A.1 Literature Review Methodologies 25A.2 References 31A.3 Final Sources 36 ===== PAGE 6 ===== ## 1. Executive Summary ### 1.1 Introduction On 27 July 2020 the Government published "Gear Change - a bold vision for cycling and walking!" setting out the Government's plans to promote cycling and walking in England. Key aims for this strategy include improvements in reducing congestion in town centres, increasing local business, reducing transport's environmental impact, improving air quality, and reducing noise. One of the commitments made in Gear Change is to pilot the use of compulsory urban consolidation centres (CUCCs) in historic city centres, specifically, it said: "In one or two small historic city centres with narrow and crowded streets, we will pilot compulsory freight consolidation schemes, based on experience from the Continent, which seek to ensure that all deliveries (except perishables and items which require specialist carriers) are made to consolidation centres on the edge of the city centre, or the edge of the city, then taken to their final destinations in a far smaller number of vehicles, including cargo bikes and electric vans wherever possible. These pilots could complement work already underway by cities and towns to develop Clean Air Zones to improve air quality." The Department for Transport commissioned a study to review previous research and trials to improve understanding of the elements that make for a successful and viable Compulsory Urban Consolidation Centre (CUCC) and also identify barriers and risks. This report, representing the output of the study, encompasses the results of: a) A semi-systematic literature review; and b) A legislative review; and c) Stakeholder consultations ### 1.2 What is the problem? The increased demand for the distribution of goods and services in cities are forecast to continue to grow through the 21st century, due to increasing urbanisation, income growth, and fragmentation of supply chains. The fragmentation of logistics at the last mile delivery stage is evident, both globally and locally, as smaller vehicles are delivering smaller consignments of lower value but higher density goods. The causes of this fragmentation are yet to be fully understood but are known to include rising home deliveries; online shopping; regulations on time; vehicle size or type; reduction of storage; just- in- time principles; and replacement of stocks with last minute deliveries. This inefficient use of resources has impacted the economic viability of delivery services, since the cost of last- mile deliveries could contribute anywhere between \(13\%\) and \(75\%\) of the total logistics costs, with research suggesting a norm of 40- 50% for parcel deliveries. Freight traffic has been highly unpopular with the public in the UK, who consider it the lowest priority in terms of road use and see a growing issue of congestion and safety conflicts between cyclists and commercial vehicles. Some recent research into US metropolitan areas also suggests traffic congestion growth negatively affects growth in income and employment. Furthermore, in 2018, \(34\%\) of Nitrogen Oxides (NOX) emissions and \(13\%\) of Particulate Matter (PM2.5) emissions came from transport, and Transport produced \(27\%\) of the UK's total emissions in 2019. Of this, the majority \((91\%)\) came from road transport vehicles (111 MtCO2e). Diesel is the predominant freight fuel and therefore the major contributor to nitrogen oxide pollutants (NOx) and particulate matter (PM) - the main causes of poor air quality. Freight consolidation centres can, in many of their various forms, help to reduce the number of delivery vehicles in the areas they serve (in some specific circumstances, by up to \(80\%\) ). However in the past, many ===== PAGE 7 ===== Urban Consolidation Centres were granted only a short life because they failed to attract a sufficient number of customers, making them economically unviable. ### 1.3 Key findings #### 1.3.1 Literature review The literature review identified examples of compulsory (to use) consolidation centres in the United Kingdom and Europe and identified four primary drivers responsible for the effectiveness of CUCCs. These drivers are: a) Direct legal regulation b) Controlled territory c) Receiver procurement led consolidation d) Construction consolidation centres Examples are given for each primary driver and the literature review covering academic, expert, project, governmental and 'grey' literature suggests that the top- down compulsory imposition of an Urban Consolidation Centre (UCC) seems to work best in clearly controlled domains. #### 1.3.2 Legislative review The legislative review considered whether under existing legal powers, a scheme could be introduced to ban delivery vehicles from collecting from and delivering to a city centre and compel them to deliver instead to a compulsory urban consolidation centre. The review provides an analysis of the implementation of such a scheme in a hypothetical location within England but outside London and considered the following scenarios: a) Restricting the entry of delivery vehicles to a particular area b) Charging delivery vehicles to enter a particular area c) Building a CUCC d) Compelling delivery to a CUCC e) Delivery from a CUCC f) Delivery models g) How implementation could be challenged The review has shown that there are potentially existing powers that could provide for the restriction of delivery vehicles entering a city centre and the construction of a CUCC. However, to use such powers in this way would be novel, unusual, and not clear cut. #### 1.3.3 Stakeholder consultations Between June and July 2022, engagements with stakeholders were undertaken. These represented face- to- face appointments as well as an opportunity to complete and return a survey. Consultees included trade associations, global and local parcel delivery service providers, local authorities, and a global online retailer. Whilst responses to the concept of consolidation centres were generally neutral or favourable, there was strong resistance to CUCCs from freight operators. Local authorities on the other hand were broadly in favour. The consultations also identified that there are specific sectors and areas where CUCCs could be applied relatively easily. ===== PAGE 8 ===== ## 2. Semi-systematic literature review ### 2.1 Objective This is a literature review of previous research and trials to improve understanding of the elements that make for a successful and viable Compulsory Urban Consolidation Centre (CUCC) and identify barriers and risks. It directly feeds into subsequent objectives/tasks, which are: A review of the legislative landscape and recommendations for the legislative changes needed to enable the establishment and enforcement of a real- world trial, Case studies for the establishment of real- world trials to include recommendations on costs/benefits, goods included/excluded, cost of establishment and running the facility and Local Authority enforcement, and A framework for site selection for a real- world trial. These tasks are part of a project that is solely to research and identify the necessary criteria for establishing a viable compulsory consolidation centre. As the future trial itself will evidence the impacts, risks, and benefits of a CUCC, this project must establish the requirements for conducting a successful trial, such as the legislative changes needed to allow it to operate successfully, the resources required to set up and run the operation and how site selection for a future trial should be conducted. Note that some evaluation has been made as to the varying levels of compulsion and the potential strengths, weaknesses, barriers, and risks of these different types of mandatory intervention. This is to be able to explore the elements of previous trials that were most successful, produced the greatest impact or were essential to the functioning of consolidation centres/schemes. ### 2.2 Context The increased demand for the distribution of goods and services in cities ('urban freight logistics') and solutions to the dis- benefits generated ('city logistics') are forecast to continue to grow through the 21st century, due to increasing urbanisation, income growth, and fragmentation of supply chains. Urbanisation has risen globally, with Europe the most urbanised continent, and the greatest rates of growth predicted for 2050 in Asia and Africa [1]. A fragmentation of logistics at the last mile delivery has been evident, both globally and locally, as smaller vehicles delivered smaller consignments of lower value, higher density goods [2]. The causes of this fragmentation are yet to be fully understood but are known to include rising home deliveries; online shopping; regulations on time; vehicle size or type; reduction of storage; just- in- time principles; and replacement of stocks with last minute deliveries [3]. The inefficient use of resources has impacted economic viability, since the cost of last- mile deliveries could contribute anywhere between \(13\%\) and \(75\%\) of the total logistics costs, with research suggesting a norm of \(40 - 50\%\) for parcel deliveries [4,5]. Costs may be generated by the low load utilisation of urban freight vehicles, partially due to market demand, restrictive regulation, and lack of cooperation in a free market [6,7], making higher vehicle utilisation a key economic goal. The social effects of urban distribution have been potentially lower than expected: delivery vehicles made up between \(10\%\) and \(18\%\) [8,9] of urban road traffic and in general tended to avoid peak times. There are few noticeable social equity issues, although some recent research into US metropolitan areas had suggested traffic congestion growth negatively affected growth in income and employment [10]. Freight traffic has been highly unpopular with the public in the UK, who considered it the lowest priority in terms of road use [11] and saw a growing issue of safety conflict between cyclists and trucks [12]. In 2018, \(34\%\) of Nitrogen Oxides (NOX) emissions and \(13\%\) of Particulate Matter (PM2.5) emissions came from transport, and Transport produced \(27\%\) of the UK's total emissions in 2019. Of this, the majority \((91\%)\) came from road transport vehicles (111 MtCO2e). The biggest contributors to this were cars and taxis, which ===== PAGE 9 ===== made up \(61\%\) of the emissions from road transport (68 MtCO2e), followed by Heavy Goods Vehicles (HGVs) \((18\%)\) of road transport emissions, 19.5 MtCO2e) and vans \((17\%)\) of emissions, 19 MtCO2e) [13]. Transport contributed a substantial portion of these air pollutants to the UK's domestic total: \(34\%\) of NOX emissions, \(13\%\) of PM2.5 emissions, and \(11\%\) of PM10 emissions came from transport in 2019 as shown in Figure 1 [13].
Figure 1: Greenhouse gas emissions by sector, 2019, BEIS [89]
The environmental impact of freight distribution in cities has been observed as disproportionate to the number of vehicles: Whilst about \(20\%\) of road vehicles are light vans or heavy good vehicles (HGVs), they generate a disproportionate volume of key pollutants, as show in Table 1. Table 1: Proportion of road air quality pollutants attributable to freight, 2019, NAEI
Pollutant% Attributable to light vans and HGVs
(b) Nitrogen oxides (NOx)28.95%
(c) Particulates (PM10)32.91%
(h) Sulphur dioxide (SO2)37.32%
Diesel is the predominant freight fuel and therefore the major contributor to nitrogen oxide pollutants (NOx) and particulate matter (PM) - the main causes of poor air quality. The health impact of freight on citizens due to poor air quality in the UK has been known and has become increasingly controversial and driven both national and local governments to consider interventions to limit commercial vehicles, especially those using diesel [14- 17]. The Urban Freight Research Roadmap 2014, developed by two European Technology Platforms (ETP)2, noted: "Therefore, a holistic approach should be followed to understand what can be done upstream the supply chain to optimise urban logistics. But the peculiarities of cities and the differences [...] also call for a focus on the urban logistics itself. Different business models, new processes and technologies should be researched and implemented." [18]. Work has tended to focus on the transport chain, regulation, and the technology of operations. Urban freight transport has been seen as notoriously 'difficult to organize, difficult to modernize' [19], and can be described as a classic 'mess' in systems approaches terminology [20]. ===== PAGE 10 ===== ### 2.3 Gear Change On 27 July 2020, the Government published "Gear Change - a bold vision for cycling and walking" [21] setting out the Government's plans to promote cycling and walking in England. Key aims for this strategy include improvements in reducing congestion in town centres, increasing local business, reducing transport's environmental impact, improving air quality, and reducing noise. One of the commitments made in Gear Change is to pilot the use of compulsory urban consolidation centres (CUCCs) in historic city centres, specifically, it said: "In one or two small historic city centres with narrow and crowded streets, we will pilot compulsory freight consolidation schemes, based on experience from the Continent, which seeks to ensure that all deliveries (except perishables and items which require specialist carriers) are made to consolidation centres on the edge of the city centre or the edge of the city, then taken to their final destinations in a far smaller number of vehicles, including cargo bikes and electric vans wherever possible. These pilots could complement work already underway by cities and towns to develop Clean Air Zones to improve air quality." ### 2.4 Definition of (Compulsory) Urban Consolidation Centre The definition of an Urban Consolidation Centre (UCC) has varied and developed over time with multiple confusions between 'urban distribution centres' and 'urban freight transhipment platforms' and so on [47,48]. Since many such definitions are for centres that are not explicitly for the consolidation of goods, they need excluding and as such the following definition meets our needs most appropriately: "A centre for transhipment of goods with a destination in the city, located at the edge of the city with good infrastructural accessibility. Its main purpose is to achieve a high degree of collection in the goods flows (thick) to supply efficient transport from the distribution centre to the city centre and vice versa" [49] This addresses the core definition of a UCC. Another definition often used in the literature is that of Browne, et al [48] which adds multiple additional features and can be adopted. "[A] UCC is best described as a logistics facility that is situated in relatively proximity to the geographic area that it serves be that a city centre, an entire town, or a specific site (e.g., shopping centre), from which consolidated deliveries are carried out within that area. A range of other value- added logistics and retail services can also be provided at the UCC. Logistics companies with deliveries scheduled for the urban area or site can transfer their loads at the UCC and thereby avoid entering the congested area. The UCC operator sorts and consolidates the loads from several logistics companies and delivers them, often on environmentally friendly vehicles, to an agreed delivery pattern" (Browne et al., 2005).
Figure 2: Conceptualisation of a UCC, Verlinde et al., [50]
===== PAGE 11 ===== This traditional conceptualisation of a UCC is shown above in Figure 2. To better define a UCC for our needs we adopted the following definition of a compulsory centre. "A compulsory urban consolidation centre (CUCC) is a logistics facility that is situated in relative proximity to the geographic area that it serves, be that a city centre, an entire town, or a specific site, from which consolidated deliveries are carried out within that area. All logistics companies or a subset defined by types of vehicle, goods or timing, with deliveries scheduled for the urban area or site are required to deliver their loads to the CUCC and thereby avoid entering the congested area. The CUCC operator sorts and consolidates the loads from some logistics companies and delivers them to an agreed delivery pattern." This fits well with the definition in the Gear Change document: "small historic city centres with narrow and crowded streets [...] compulsory freight consolidation schemes, which seek to ensure that all deliveries (except perishables and items which require specialist carriers) are made to consolidation centres on the edge of the city centre, or the edge of the city, then taken to their final destinations in a far smaller number of vehicles, including cargo bikes and electric vans wherever possible." UCCs cannot be viewed and studied in isolation, but rather in the context of the entirety of supply chains that typically cross the geographical boundaries of urban areas. This review shows that there has been almost no account taken of the wider pre- existing supply chain networks, both between cities and over the last mile. ### 2.5 Categorisation There are few examples of compulsory consolidation centres reported in any of the literature. The primary examples of a compulsory consolidation centre are: ## Direct legal regulation: Monaco Vicenza ## Controlled Territory: Monaco CC Heathrow CC The Houses of Parliament MOD Inbound Logistic Centres Receiver procurement led consolidation: London Borough CC Newcastle University CC Swedish Municipal co- distribution ## Construction consolidation centres: Potsdamer Platz Hammarsby Sjostad The University of Amsterdam Utrecht guidance London CCCs ### 2.6 Key findings This semi- systematic review covering academic, expert, project, governmental and 'grey' literature strongly suggests that the top- down compulsory imposition of an Urban Consolidation Centre (UCC) works only in clearly controlled domains, and only two cities have made this a direct legal regulation, Vicenza, and Monaco. Vicenza was resisted strongly by local and global carriers acting as one. After two court cases the city's approach was (more or less) upheld by the supreme court in Italy; it was not challenged at the EU level; the global carriers are reported to have stated they will oppose such a scheme again anywhere. Despite the judgement holding precedence for Italy, no other Italian cities have tried such a model. [51- 53] ===== PAGE 12 ===== The literature review found a few papers that look at the econometrics of shipper savings through the use of a UCC, but none that explored the break- even point of a CUCC. The issue of enforcement was not found in the review; however, this may be due to the scope delimiting. Exploring the full range of urban freight concepts and practice from the 1970s through COST321, OECD, and multiple thematic and knowledge networks such as BESTUFS, the Institute of City Logistics, BESTFACT, and CIVITAS, it is clear that most UCC initiatives fail in a liberal economy where free choice and market economics apply without levels of subsidy unacceptable to public and private bodies over time [54,55]. Many of these UCCs have been successful in understanding urban freight logistics, trialling clean urban vehicles, testing the limits of co- operation in a free market, and indeed understanding why they are nonviable. Given that COST321 [56] (and then subsequent networks and projects) identified a wide range of urban freight logistics interventions apart from or in parallel to UCCs, it is noticeable that they have been somewhat neglected in comparison, and that, as COST321 suggested, several other interventions may yield more advantageous results. On the other hand, the theoretical goal of reducing last mile congestion in urban cities through focused scheduling and bundling of flows into sites and locations still holds, and there are 3 types of UCC that could be implemented with the degree of compulsion required to overcome the drivers of free markets. In all cases, the mandate for compulsion lies in the hands of public and private actors. The 3 site types are: - Secure controlled sites: where the controller of that site wishes to reduce traffic flows for reasons of security, safety, reduced intrusion, or corporate social responsibility AND has the budget and mandate to pay for the inevitable on-cost and/or service level reduction. - Examples: Government buildings, transport hubs, military bases, and small polities outside of free market principles. - In most cases, the mandate and power already exist, are unlikely to be affected by budgetary concerns, and can be enacted with no challenge. - In effect, the 'front door' is moved to the CC. - Construction sites are under the control of a developer who has been required to mitigate traffic impacts through better vehicle utilisation by a planning body that has made it a condition of the development being approved. - Examples that are known are Hammarsby Sjostad and Potsdamer Platz, and it is known that TfL requires developers to demonstrate where consolidation can take place on a construction site within Construction Logistics Plans. - In the UK, it is likely that planning authorities already hold this power either in fact or through negotiation. - Purchasing departments require improved utilisation of vehicles to reduce the impacts of inbound logistics on organisations, either through the operation of a UCC or through a requirement on suppliers to prove optimised utilisation on inbound logistics flows. - This is potentially powerful and could be achieved through the controls in place for any procurement that involves substantial amounts of public funds, either to or through public and some private bodies (e.g., Universities). - However, this would require to be placed high enough in the wide range of requirements made on purchasing professionals from national and local governments, and the primary issue is that cost reduction usually trumps all other concerns. The review has shown that there are very few successful compulsory consolidation centres in the world. These can be divided into those that have an entirely controlled territory, those that use procurement- based control of inbound logistics, or direct legal regulation [53,57- 59]. ===== PAGE 13 ===== ### 2.7 Direct legal regulation The only uncomplicated and explicit compulsory UCC is that of Monaco, where all non- perishable and non- postal deliveries3 have to be delivered to the UCC for onward distribution, at the expense of the principality. The principality is a sovereign micro polity outside the EU and laws on free trade, and as such makes for a poor use case [53]. Vicenza has implemented a top- down prohibition on vehicles entering the historic city centre and required the use of a CUCC for most goods; it faced multiple legal challenges from logistics operators with global reach. The case was found in the city's favour by the highest court in Italy because legal environmental obligations can override free trade in very localised areas; it was not tested at the EU level, and the carriers stated clearly that they will challenge any further such imposition in any city globally [60]. This precedent for clear legal compulsion has not been repeated, other cities usually offer 'carrot and stick' inducements, such as Utrecht, where operators can avoid time window delivery restrictions in exchange for audited levels of operational efficiency and higher load factors [59]. Such restrictive access to urban cities increases both the cost and the volume of last mile deliveries, increasing congestion, carbon footprint, and air pollution and lowering competitiveness. This is usually due to increased trips less well loaded in a limited time period, as opposed to fewer trips better loaded over a full working day. For example, in the case of Parma such restrictions have been modelled as resulting in \(+34\%\) more tours and \(+9\%\) distance travelled [61]. ### 2.8 Controlled territory When an organisation controls a territory wholly it can mandate the use of a UCC. This has been the case with the Heathrow Consolidation Centre [53,57], the Houses of Parliament, most MOD sites, and some other examples (such as large theme parks in the USA) where security and safety concerns are such that unauthorised access is not allowed. These are funded at the cost of the territory owner. They reduce overall vehicle kilometres on site since the effect is to extend the front door of the establishment to a safe perimeter. Since historic city centres are not usually a wholly controlled territory, these are also not use cases. There is another semi- controlled territory, and that is property owned by a landlord and leased to tenants. Such landlords with retail tenants have set up UCCs and encouraged their tenants to use them, usually with low take- up. Examples are the Regent Street CC initiated by Crown Estates [62], the Meadowhall UCC initiated by British Land, the Bristol- Bath UCC, and the Stadsleveransen UCC (and accompanying 'delivery caravan') in Gothenburg, as illustrated in Figure 3 below [63]. ===== PAGE 14 =====
Figure 3: Gothenburg retail freight 'train', [64]
Most of these schemes have had high levels of a start- up public sector subsidy. This was often from an extended sequence of sources. They tended to achieve a low take- up amongst retailers. It is widely stated that retailers have been unwilling to pay extra for the consolidation service. They do, however, seem to have a niche providing close call- off stock for stores that are too small to hold stocks in store, and some small elements of added value services. Even with a strongly persuasive landlord on a busy street such as Regent Street, the operator of the scheme, Clipper Logistics, did not think that their share of all retail deliveries on Regent St was very large, probably less than \(20 - 30\%\) , and lower at Meadowhall [62]. ### 2.9 Receiver procurement led to consolidation Whilst not a legal compulsion, the payer of the final invoice has the contractual right to dictate the inbound logistics terms and conditions of supply, in that a supplier cannot maintain a business without meeting the needs of their customers. This can have greater compulsion than a parking regulation or a delivery access window. This is not, as explained by Verlinde et al [59], likely to happen organically since there is a disconnect between the three main actors in most UK logistics operations: the receiver (retailer/customer), the shipper (supplier) and the carrier (logistics operator) as shown in Figure 4 below. The contracts exist between receiver and shipper, between shipper and carrier, and therefore the parties to the transport operation usually have no contractual relationship in most urban settings. ===== PAGE 15 =====
Figure 4: Disconnect between end receiver and carrier, Verlinde et al., [50]
There have been several examples of interventions to adopt a new approach to the inbound logistics of large and small institutions. Smaller independent retailer schemes have tended to fail due to the lack of core focus from small shopkeepers and the difficulties inherent in coordinating large groups of disparate SMEs. Focus has tended to be on large institutions such as councils, universities, and hospitals. Such examples include the ongoing Southampton NHS and Council consolidation schemes run by Meachers Logistics with subsidy/funding [65], inbound consolidation at Newcastle University 2011- 2016 [66,67], the London Borough Consolidation Centre scheme [68] and the Municipal co- distribution scheme in Sweden [69,70]. In all cases, there have been teething problems with this approach. Early hopes that the suppliers would pass on the last mile savings, which have been estimated as circa €7 per cubic metre [71], did not realise. This may be because most suppliers have no visibility of the cost structure inside their external or internal logistics providers operations. All such schemes have thus been funded primarily by subsidy and then by the receiving organisation. As Verlinde et al. [59] state: "that appears to be a problem as the bare fact that the number of freight vehicles entering the city is reduced does not yield a financial profit. At the most, it leads to a more pleasant [...] climate for [...] customers and fewer interruptions by carriers delivering something. That is why concepts oriented towards the receiver would also have to be advantageous to them in other ways to receive bottom- up support". Whilst potentially some congestion, intrusion, \(\mathrm{CO_2e}\) , and emission reductions can be shown from such UCCs [66], and the mandatory nature of purchasing contracts is very strong, the receiver organisation has to foot the bill for the UCC. For Newcastle University, the projected cost of £100,000 plus per annum, combined with the departure of the Vice- Chancellor that championed this cause, meant the scheme was not considered attractive by the University and it was dropped. It appears the LBCC scheme may have gone the same way, but after the contraction of the TfL freight team, the project has been less well documented. A key success here has been the Swedish Municipal co- distribution model. This has been based on the "The Good City" [72] project developed by Trafikverket and illustrated below in Figure 5. A conceptual framework was developed, to overcome traffic congestion and accessibility problems in the Central Business District (CBD) of the larger cities. This explicitly separates logistics prices from goods tendered to local authorities, essentially 'ex- works' pricing and the logistics operation to collect, consolidate and deliver last mile goods is handled by contracts tendered by municipalities. The business model for co- distribution of goods evolved and in 2011 became conceptually integrated with the official Swedish SFTI (Single Face to Industry) standard for e- commerce, commissioned by government agencies and coordinated by the Swedish Association of Local Authorities and Regions. [58] ===== PAGE 16 =====
Figure 5: The Good City, Trafikverket, [72]
[56,69] The legal basis for the system is a combination of municipal regulations and the Swedish Public Procurement Act, which explicitly allows for tendering processes that favour local businesses, SMEs, and sustainability. The potential conflict lies within the provisions in the Act which include EU principles of equality and non- discrimination. However, the scheme has not been legally challenged in Sweden and it is believed that two rulings by the Court of Justice of the European Union show precedent for recycling, emissions, and noise concerns to influence tendering processes [73,74]. 45 municipalities had adopted co- distribution by 2015, one- seventh of all Swedish municipalities, and interest was extending to Norway. ### 2.10 Construction consolidation centres Construction consolidation centres (CCC) are a success in the domain of UCCs in London, UK, with some early and successful examples in wider Europe, but still a low level of take up. Sharing some of the characteristics of regulatory control, controlled territory and receiver- led procurement approaches, some examples are the rebuilding of the Potsdamer Platz in Berlin [75], Hammarsby Sjöstad in Stockholm [76], the building of new campuses for the University of Amsterdam using the Binnengasthuis service [77,78] planning guidance in Utrecht and the dozen CCCs operating independently and viably in London [79- 81]. The core operational basis of a typical CCC is shown in Figure 6. ===== PAGE 17 =====
Figure 6: Typical CCC configuration, TfL, [81]
CCCs are driven by 3 mutually supportive drivers. First, the ability for planning authorities to use their existing statutory powers to require traffic assessments and mitigation strategies for not just the ongoing operation of development but also the build phase, developed most strongly as planning guidance by Transport for London, [81]. Second, the high level of 'shrinkage' and loss on traditional building sites which has been stated as running at \(10\%\) of all inbound goods, makes a traceable, secure, and controlled logistics operation that consolidates and stores deliveries very attractive to the bottom line [82]. Last, is the ability of a developer, once required by a planning authority to use an efficient and consolidated logistics solution, to use purchasing power to cascade the requirement in contracts down the hierarchy of sub- contracts to all parties. Balm and Van Amstel (2017) explore how tendering for public construction projects can support sustainable urban construction logistics within the context of sustainable construction such as the BREAAM [84] scheme and with the use of 'logistics quality' criteria for tender procedures using EMAT (Economically Most Advantageous Tender) to support tendering construction projects by both public and private clients. ===== PAGE 18 =====
Figure 7: Different stakeholder experiences of CCC, Janné, [85]
### 2.11 Enablers, opportunities, barriers, and risk Top- down implementation by law will be challenged. Whilst the Vicenza case was upheld, this may not the case in the UK courts. Global and local carriers co- operated to oppose the Vicenza case and have stated they will do so again, globally. The Vicenza case, the Swedish scheme, and the development of construction logistics guidance suggest routes to cut the 'Gordian Knot'. To do that the primacy of either the principle of equality and non- discrimination OR environmental and sustainability obligations will need to be defined and decided in the UK. This may already be soluble with existing law and regulation. It may only apply in limited geographical areas, market niches or only certain goods types. It should avoid creating delivery windows which have negative sustainability effects. It may require clarification with secondary or tertiary legislation/regulation. The other question that would be worth exploring is whether this law is observed and enforced, for example the Limited Traffic Zone (LTZ) of Como is only monitored in one- way directions but vehicles flout the regulation by entering through exit lanes (Oesterle et al., 2015). Ten UCCs are reported as current in Italy, the examples of Parma and Genoa, whose regulations initially favoured a UCC, are also interesting. In both cases, a municipal ordinance restricted the access of an LTZ to non- accredited vehicles. Two basic requirements have to be met to obtain accreditation: the use of low emission vehicles and better optimization of vehicle load when entering the zone, albeit no compulsory consolidation centre. [86] However, Southern European cities have a much higher level of own account logistics than Northwest Europe (66% in S versus 33% in the NW), and usually these vehicles are owned by residents who use them for domestic purposes as well as servicing their SME shop, café, or retail business. Such residents are always allowed an exemption [87]. The carriage of some dangerous goods, goods from air carriers and the post were all contentious issues in the Vicenza case and from the author's conversations with postal carriers across Europe, none will accept the carriage of the mail by another carrier, either for legal reasons or human resources reasons. This may need to be addressed if it was a hard requirement. Opening discussions with UPS suggest that they and other ===== PAGE 19 ===== premium couriers would view such an approach as unacceptable, and so a question is whether the issues regarding air freight exist in the UK or were a solely Italian matter. Receivers need a strong reason to fund an incoming logistics UCC. They have the purchasing power to do so, as exhibited in the trials seen, but often have not had the organisational appetite to carry the costs. Negotiated supplier price savings have not materialised (probably due to the lack of transparency in the cost/price relationship between the supplier and the carrier) and the known lack of price signals regarding the last mile. The Swedish model has shown that a solution is for public- funded bodies to completely take over the inbound logistics chain and require 'ex- works' or 'ex- distribution centre' pricing. This forces cost transparency and provides a fund to run tendered logistics operations. There may be potentially a need to resolve any concerns regarding the tendering of the logistics process, but this seems a strategy that could work. Public procurement is wider than the public sector alone, a body with high levels of public funding must comply, and the purchasing profession is chartered and capable of administering contracts. This would need a review and secondary or tertiary legislation/regulation to enforce across all bodies covered by public purchasing rules. A lesser level of compulsion that would use public purchasing power not to take control of logistics but to set standards may have value. This might incorporate a new parameter into the FORS or ECOSTARS standards regarding utilisation. FORS is increasingly common in UK public procurement contracts. Use of such a revised standard could require suppliers to use logistics services with a proven and auditable level of utilisation, load factors or use of low or zero emission vehicles in cities. This would then act as a catalyst for the practice to spread across private businesses. Most city centres are full of organisations covered by public purchasing institutions, councils, schools, universities, hospitals, and so on; and they represent a low- hanging fruit option for the trial; though one should accept that many larger retail organisations run efficient consolidated logistics chains into cities, as stated by Cherret et al. [88] CCCs are potentially the most self- sustaining form of Urban Consolidation Centres and may require little legal regulation since the mandatory powers exist in the planning guidance, and once a clear signal is sent to the developers it can be cascaded through contracts. Currently, the sector still does not stack up against others when it comes to productivity performance. Studies estimate that transport and logistics could cut the total construction budget up to \(20\%\) by implementing a rigorous planning of logistics activities [82]. The lead taken by TfL and the growth of privately run viable CCCs in London suggest that it is strong policy guidance and education of the developer and construction sector that is needed to trigger a virtuous cycle. ===== PAGE 20 ===== ## 3. Legislative Review ### 3.1 Objective The objective of the legislative review is to identify the role of compulsion in the provision and functioning of urban consolidation centres. This section of the report provides an analysis on whether under existing legal powers, a scheme could be introduced to ban delivery vehicles from collecting from and delivering to a city centre and compel them to deliver instead to a compulsory urban consolidation centre (CUCC) in which the relevant delivery company's shipments for delivery into the city centre would be combined with those of other delivery companies and made by a single delivery company to their final destination within the city centre. This section of the report also analyses the implementation of such a scheme in a hypothetical location within England but outside London and further legal analyses would need to be undertaken prior to drawing conclusions as to the ability to implement such a scheme in any particular identified location (including within England but outside London). ### 3.2 Restricting the entry of delivery vehicles to a particular area Under the Road Traffic Regulations 1984 (RTRs), a local authority has the power to implement a Traffic Regulation Order (TRO) if expedient for a range of reasons including: for preventing the use of the road by vehicular traffic of a kind which, or its use by vehicular traffic in a manner which, is unsuitable, having regard to the character of the road or adjoining property; for preventing damage to the road and buildings on or near the road; and for air- quality- related reasons, (although these are not necessarily the only potentially pertinent reasons of application in this case). TROs may prohibit, restrict, or regulate the use of a road by vehicles (or a class of vehicles) in general or subject to exceptions. The power is widely drafted and can apply at such times, on such days and subject to such exceptions as are considered desirable. TROs are subject to certain restrictions under section 3 RTRs (TRO Restrictions), which include, preventing for more than eight hours in any 24- hour period access for vehicles of any class to any premises situated on or adjacent to the road. The TRO Restrictions will apply unless the authority gains consent from the Secretary of State pursuant to paragraph 1 of part 2 of schedule 9 of the RTRs, or the authority making the order is satisfied that it is requisite that such restriction should not apply for one of several reasons including for preventing damage to the road or buildings on or near it (section 3 RTRs). Such a TRO could be used to prohibit entry of all light or heavy commercial vehicles. This could then be subject to an exemption for vehicles being used in the area other than for provision of services for the transport of goods. However, this approach is likely to be difficult and costly to enforce, as it would be a subjective exception compared to a blanket ban on certain types of vehicles, which could be enforced through cameras and number- plate recognition technology. The legislation enabling TROs is drafted for TROs to apply to all vehicles or to a class of vehicles only. It does not provide for a TRO that discriminates in terms of whether or not the vehicle is being used by a delivery company or the type of goods being carried. Any such effect would need to be introduced via an exception such as 'all heavy and light commercial vehicles other than those being used for the provision of a service for the transport of goods'. While such a broad exclusion would be necessary to ensure that other users of delivery type vehicles, such as tradespersons, were not subject to the restrictions, its broad nature leaves it somewhat exposed to challenge. Authorities may expect challenges at two levels: 1) road users arguing they are not providing services for the transport of goods (for instance, a tradesperson conveying parts sold to a client within the area covered by the TRO in order that he/she can install them as part of a wider service); and 2) as discussed below in more detail, arguments that certain items should be excluded from any restrictions, for example certain medicines. Such an exemption could be introduced by reference to harmonised tariff codes, although this would not eliminate the opportunity for road users to select how they classify their goods in order to take advantage of exclusions. Furthermore, in practice, unless the Secretary of State's consent were obtained, or it could be argued that the TRO Restrictions should not apply, which given the applicable reasons would appear likely to only be sustainable in a limited number of cases, the eight hours in any 24- hour period restriction on the operation of ===== PAGE 21 ===== TROs would need to apply. This may represent too short a window for the measure to achieve its purpose, given that delivery companies often operate outside, for instance, a 09:00- 17:00 working day and, thus, the relevant legislation may need to be changed to amend the TRO Restrictions or a further restriction would need to apply in order to give the purpose the best chance of being achieved. ### 3.3 Charging delivery vehicles to enter a particular area Further restriction could apply in the form of a charge for delivery vehicles to enter the city centre at times other than those in which they were prohibited by a TRO. Under the Transport Act 2000, local authorities can implement local charging schemes in respect of the use of vehicles on roads if it is desirable for directly or indirectly achieving the local transport policies of the charging authority. This power is broad in terms of what can trigger the charge or the class of vehicles in respect of which it is imposed. The appropriate national authority can also provide for exemptions from the charge or reduced rates, which, as above, could be used to exempt those vehicles being used in the area other than for provision of services for the transport of goods. However, as noted above, although arguably possible, this approach is likely to be difficult to implement and enforce. As an aside, roads can only be subject to one charging scheme under the Transport Act 2000 at a time, meaning that where a city has an existing charging scheme, such as a clean air zone, any scheme for the purposes described in this report would need to be built into the existing scheme. Therefore, it is currently possible under English law to implement a prohibition on delivery vehicles entering an area and ensure that, where they cannot be prevented from entering an area, they are at least charged for doing so. TROs can be enacted for purposes relating to improving air quality and preventing damage to an area. Charging schemes need to further local transport policies, which could include both or either element. ### 3.4 Building a CUCC Whilst TROs and charging schemes have been successfully implemented, the power to build a CUCC and compel delivery to/from it is otherwise unprecedented in the UK and may require novel use of existing laws. Where a charging scheme is introduced under the Transport Act 2000, there is also the power to build any building or structure to be used in connection with the operation of a charging scheme. Therefore, if the charging scheme were connected to the CUCC (such as, potentially, by the local transport policy), it could be argued that the Transport Act 2000 gives the local authority power to also build the CUCC. In addition, the appropriate national authority may issue guidance to local authorities relating to the discharge of their functions under the part of the Transport Act 2000 relating to charging schemes. Local authorities shall, in exercising those functions, have regard to such guidance. Therefore, the guidance could be used to lead authorities towards using the model described in this section of the report. Under the Environment Act 1995, local authorities must have regard to the national air quality strategy (Clean Air Strategy 2019). This includes cutting air pollution from transport. The Environment Act 1995 gives the Secretary of State power to make directions requiring local authorities to take specified steps if, among other reasons, it appears to him/her that air- quality standards or objectives are not being achieved within the area of that authority. This broad power could be used to directly require that local authorities implement a charging scheme and build a CUCC in order to improve air quality. Indeed, the Secretary of State has already made a number of such directions, which, for example, require local authorities to make a plan to secure compliance with the legal limit for nitrogen dioxide as quickly as possible and, in any event, by a certain date. These directions could already be used to give support to a CUCC. However, delivery companies that operate electric vehicles may argue compellingly that any measure introduced following such a direction pose no good reason to affect them, meaning a new direction directing implementation of a charging scheme and a CUCC in order to improve air quality in a wider sense than just nitrogen dioxide emissions could be required to remove the ambiguity. Therefore, arguably, existing powers allow the Secretary of State to direct local authorities to build and operate a CUCC. The local authorities can build one under the Transport Act 2000, if accompanied by a charging zone, and the Environment Act 1995 gives further support to any policies with the aim of reducing ===== PAGE 22 ===== air pollution from vehicles. In order to build and operate a CUCC, an authority is likely to require funding because, as noted in Section 2.11 of the Literature Review, any cost savings achieved by carriers in not delivering 'the last mile' are typically not passed on, and under this structure would have little or no ability to be passed on. ### 3.5 Compelling a delivery to a CUCC The legislative review has not revealed any clear existing powers that could compel delivery companies to deliver to a CUCC. There is an argument, but a far from compelling one, that the power to require deliveries be made to/from CUCCs lies in section 101(3)(c) Postal Services Act 2000 under which the Secretary of State can give directions relating to the provision of postal services to any or all postal operators for reasons including to facilitate the discharge of an international obligation, which could include the Paris Agreement 2015. Section 27(3) Postal Services Act 2011 defines 'postal operators' broadly as 'a person who provides: (a) the service of conveying postal packets (letter, parcel, packet, or other article transmissible by post (post is undefined in that act)) from one place to another by post; or (b) any of the incidental services of receiving, collecting, sorting, and delivering postal packets. The ability for this power to extend to all delivery companies is not clear cut, but would seem at least arguable and may turn on the definition of 'post' and an argument that a person can be a postal operator if delivering parcels, which can be transmitted by post, but that such parcels need not actually be being transmitted by post in order for the person to be a postal operator (were post deemed to be something different from delivery of parcels). Were an argument that all delivery companies were postal operators to succeed, such classification may have further implications under the Postal Services Acts which are beyond the scope of this review. ### 3.6 Delivery from a CUCC The legislative review has not revealed any clear existing powers that would permit an authority, or other carrier, to complete the last mile of a package's delivery from a CUCC, without the agreement of the delivery company that the original order had been placed with. Therefore, unless new legislation is passed, cooperation of the delivery companies will be required in order to effect delivery to the final destination. Standard contractual provisions would be expected to apply with respect to the transfer of liability for loss or damage to the package from the original carrier to the carrier for the last mile. Liability would also need to be agreed with the CUCC operator in respect of the transfer of risk while the package was in the CUCC between delivery by the original carrier and collection by the last mile carrier. There is no legislation which would compel the liability level of one carrier to be the same as another carrier for different parts of the package's journey. ### 3.7 Delivery models identified in the Literature Review The Literature Review identified three different models of consolidation centre that have been successfully utilised throughout Europe: Vicenza, Utrecht, and Sweden. Although these were used in different legal jurisdictions and their legal bases not examined for the purposes of this report, this section sets out some commentary relating to the implementation of similar schemes under current legislation in England and Wales. ### 3.7.1 Vicenza The local government of the city of Vicenza took, in summary, the following actions: - setting up a pedestrianised and limited traffic zone (ZTL) covering a small area based around one street in the historic centre of Vicenza (initially allowing delivery vehicles into the area at certain times of the day);- establishing a mainly public-capital company (Veloce) for deliveries/collections with electric vans to addresses within the ZTL and to manage a CUCC; and- following a cumulative strengthening of traffic-restriction measures prescribed by local ordinances, restricting access to the ZTL to electric Veloce vehicles. A number of international express carriers challenged the validity of the municipal ordinances in court. In the court of first instance, the express carriers were successful, and the ordinances were annulled. However, on appeal, the Italian State Council overturned the lower court ruling. No further appeals were made by the ===== PAGE 23 ===== express carriers. The Italian legal system is significantly different to UK law. However, a key feature of the Vicenza case is that the appeal court ruled that the decision to restrict traffic in a historic centre cannot be annulled based on the accusation it limits free competition. Vicenza is a relatively small town with a city centre that has UNESCO world heritage status. As such it is likely that the ZTL would only have minimal effects on competition. The same conclusion may not have been reached in a city without world heritage status, or where the ZTL extended over a larger area. #### 3.7.2 Utrecht The local government of Utrecht took, in summary, the following actions: allowing three existing distribution centres of private carriers to operate as Urban Distribution Centres (UDCs); funding the 'Cargohopper', an electric vehicle, owned by a private company. It is unclear how this was legally implemented and what, if any, legal privileges it enjoys. Operators of UDCs benefit from: an exemption during certain time windows from a prohibition of entry of vehicles to the city centre's pedestrianised zone up to a maximum of five vehicles at a time; and access to selected bus lanes up to a maximum of five vehicles at a time. Any carrier can operate a UDC provided it meets the following requirements: it makes collections and/or deliveries from/to 100 addresses per day in the city centre; it has a distribution centre within \(10\mathrm{km}\) of the city centre and \(5\mathrm{km}\) of the city's motorway exit; its vehicles meet certain emission standards; it agrees to accept third parties' goods for delivery/collection in the city centre; and it completes a monitoring form twice a year. Potentially the Utrecht model could be implemented in England via the use of TROs restricting the delivery of goods within a certain area to those carriers who operate a UDC. The Utrecht approach does not compel delivery to and collection from CUCCs, but instead leaves delivery companies that do not do so disadvantaged. It is beyond the scope of this review to comment on why Utrecht determined that three UDCs should be permitted, but one possible reason is that there only were three existing distribution centres and therefore the approach taken by the authority simply enhanced the status quo. #### 3.7.3 Sweden Under the Swedish model the public sector is encouraged to procure goods separate from logistics. Existing procurement legislation in England and Wales would permit the public sector to procure goods in this way, or alternatively to require delivery to a CUCC. This could be made a requirement within public sector procurement through the issue of a procurement policy note. However, in order to comply with such directions, it is likely that funding would also need to be made available to the relevant public sector bodies. Depending on how the CUCC is operated and funded, there could be implications under the Subsidy Control Act 2022, as the provision of goods or services or any transfer of funds could constitute a subsidy (for example, if the entity receiving the benefit of the CUCC were the distributor due to reduced logistics costs). To the extent any subsidy was given, it would need to take account of the principles in the Subsidy Control Act 2022, and it would, among other things, need to be shown that the subsidy was proportionate to and necessary for the policy objective it wished to meet and the least distortive means of achieving that objective. ### 3.8 How could the implementation of these delivery models be challenged? Any challenge would be dependent upon its own particular facts, for example in Vicenza the carriers argued that in order to provide express postal services, a carrier must be considered a 'regulated agent', which required a degree of training, and that while the carriers were qualified, Veloce was not, meaning Veloce was conducting business illegally. Therefore, this review does not attempt to set out all potential routes of challenge, but rather highlight the more obvious potential pitfalls. ===== PAGE 24 ===== Whether new legislation is introduced, or existing powers used, it is very likely that multiple consultation processes would be required to implement the above. This presents an opportunity for interested parties, such as delivery companies or businesses who would be affected by the plans, to raise objections. Outside London, it has often proven difficult to obtain public support for proposals that restrict traffic, as evidenced by resistance to the Greater Manchester Clean Air Zone charging scheme and York City Council's failed attempt to impose restrictions in relation to Lendal Bridge and Coppergate. Beyond public consultations, both before and after the passing of any enactments, the exercise of any powers referred to above are subject to challenge in the courts through judicial review and will have to be used in a way that allows the user of the power to demonstrate that it has not acted in a way whereby its exercise of the power: a) is illegal or irrational; b) has involved procedural unfairness; and/or c) is inconsistent with any legitimate expectation as to the way in which it will act. The Postal Services (Universal Postal Services) Order 2012 (the Order) contains a description of the services that Ofcom considers should be provided in the UK as part of the universal postal service, and the standards with which those services need to comply. Article 4 of the Order sets out to where the postal package is to be delivered. This article essentially requires postal packages to be delivered to the address on the postal package unless the addressee has requested that the postal package is delivered elsewhere. Although Article 4 permits Ofcom to approve different delivery addresses, this power is only intended to be used in exceptional circumstances. The requirement to deliver goods to the CUCC would be in breach of Royal Mail's obligations as Universal Service Provider. Given the wide definition of postal services, even if letters and small parcels are excluded from the requirement to be delivered to the CUCC, there would be a reasonable argument that Royal Mail's Universal Service Provider obligations could not be complied with and as such the requirement to deliver to a CUCC could be challenged for being ultra vires, illegal and/ or irrational. Therefore, in order to require the Royal Mail to deliver to the CUCC, it is likely that legislation relating to the Universal Postal Services would need to be amended or repealed. There are further potential grounds of challenge under particular pieces of legislation. Depending upon how a CUCC was implemented and the reasons for such implementation, there would be a reasonable argument that the above proposals were a breach of the Human Rights Act 1998 in that the delivery to a CUCC, and either collection from the CUCC, or potential delay in delivery from the CUCC, could interfere with peaceful enjoyment of a person's possessions, which could include goods being sent or received, possessions used by a delivery business and even shares in a business affected by the above proposals. Any interference would have to be within the general interest and a fair balance struck between that and the rights of the owners of property. If found in breach, the claimant could receive an award of damages and incompatible legislation could be declared incompatible with the Human Rights Act 1998 or, in the case of secondary legislation, struck down. The Equality Act 2010 could also provide a route of challenge. Any person exercising a public function or providing a service to the public must not discriminate when doing so, which can include indirect discrimination against people with protected characteristics (including perhaps of particular relevance in this case disability and religion or belief). It would be plausible that, on the assumption the implementation of a CUCC slowed down deliveries/collections, there would be scope, for instance, for arguments that the scheme was discriminatory. It would then fall to the public authority to argue that the discrimination was for a legitimate aim, such as perhaps reducing air pollution or protecting an area from damage, and the claim would therefore turn on whether the means were proportionate to the aim. In addition, there is a duty on public bodies to make reasonable adjustments to avoid disadvantage caused to disabled people. In the case of the CUCC, this could mean that goods to be delivered to certain people may need to be excluded from the requirement to be delivered to the CUCC. If the Equality Act 2010 is breached, the claimant may be entitled to an injunction, which could compel the authority to do or refrain from doing something, or to an award of damages. ===== PAGE 25 ===== ### 3.9 Summary 3.9 SummaryThe review has shown that there are potentially existing powers that could provide for the restriction of delivery vehicles entering a city centre and the construction of a CUCC, e.g., through the implementation of a clean air zone and the compulsion to use such CUCC, through a direction of the relevant Secretary of State. However, to use such powers in this way would be novel, unusual, and far from clear cut. There are also several avenues of potential legal challenge to the proposals, some of which would either require legislative change, or exemptions from the requirement to use a CUCC. To have an unambiguous right, it is likely that both new legislation and the repeal of existing legislation would be required. ## 4. Stakeholder Consultations ### 4.1 Introduction This section of the report outlines the findings of the consultation exercise associated with research relating to the feasibility of Compulsory Urban Consolidation Centres (CUCC) for the Department of Transport. This research ensures that the views of those likely to be affected by CUCCs inform the findings of the project. ### 4.2 Approach Between June and July 2022, engagements with stakeholders were undertaken. These represented face- to- face appointments as well as an opportunity to complete and return a survey. The following questions were asked of those who engaged face- to- face and/or completed a survey: What Compulsory Urban Consolidation Centres are you aware of? What are (non- compulsory) Consolidation Centre success/failure factors? What are your views on the potential/actual benefits/disbenefits of Compulsory Urban Consolidation Centres? What barriers are there to the creation of CUCCs? What would need to be in place to ensure the success of CUCCs? Are there any sectors/markets a CUCC should or should not serve? What models of operation would be most effective (public/private/3rd party)? How do you think a CUCC could impact operations/business/competition in the sectors/organisations you are most familiar with? These discussion points were produced to develop an understanding of how CUCCs work now, how they could work and what the impact of regulation in this area would be. To do this we spoke to a variety of stakeholders from the public and private sectors as well as associations who represent the freight sector. These included: Royal Mail UPS DHL Logistics UK Chartered Institute of Logistics and Transport (CILT) Bristol City Council Hampshire Council Association of International Courier and Express Services (AICES) Parcelforce Road Haulage Association (RHA) ===== PAGE 26 ===== - Cross River Partnership- Amazon Logistics- Zedify ### 4.3 Awareness and rationale of CUCCs There was awareness of non- compulsory Urban Consolidation Centres (UCCs) in place around the UK, as well as high- profile examples of CUCCs such as Heathrow and for the Houses of Parliament. A few respondents (such as DHL) have operated or are operating UCCs and have first- hand knowledge of how they work. Councils such as Bristol are exploring the concept and have previously funded UCCs. There was less certainty regarding the international examples such as Monaco, although this was cited by a small number of stakeholders. There was concern from operators and associations that CUCCs as a concept (although not necessarily wrong in principle) would not be effective at addressing the issues they are designed to solve and confusion as to what impact they would have. It was felt that a CUCC would likely increase road miles and inefficiencies in the sector and that every time additional movements are added costs (time, damage, losses, overheads, labour) increase. Public sector respondents were interested and broadly supportive of CUCCs and generally there is an understanding of their rationale. Benefits cited include improvements in air quality, efficiency improvements for operators/suppliers (in contrast with statements from freight operators), congestion reduction, contribution to sustainability/Corporate Social Responsibility goals for businesses/operators using it and income for landlords. Difficulties with finding available and suitable space (particularly in London), scale, and the cost of land were all cited as issues. However, the extra time, cost and risks associated with them means they are not popular with those expected to use them. It was noted that local authorities often promote consolidation through their policies but don't undertake it themselves. Examples across Europe of both CUCCs and UCCs were highlighted, however the lack of a commercial case in most instances mean they require public funding to operate, and once that is withdrawn the consolidation centre often closes. It was noted that it is often difficult to find out when a consolidation centre closed. Respondents felt the solution to the issues identified was enhancing the availability of land for logistics. Land is often taken over by competing land- use types such as residential, particularly in urban areas. Non- optimum locations for depots and warehousing result in unnecessary road miles and inefficiencies. Respondents also felt that there were alternative means of achieving the same objectives, with the example of delivery arrangements during the London Olympics cited and the success of bringing those affected onboard with the temporary restrictions. It was felt that these measures and the issues they cause would be disproportionate to the problems that DfT are looking to solve, namely the reduction of congestion and environmental impacts of deliveries. Delivery companies are increasingly important to the facilitation of trade and stimulating the economy, and with the growth of ecommerce they are more prominent in the public consciousness, however it was felt that there was little statistical evidence that they are the greatest contributors to these issues. ### 4.4 Barriers to CUCCs #### 4.4.1 Efficiency of the Freight Sector It was felt that as the UK's freight sector is highly efficient there is not the spare capacity and empty running that a CUCC would look to address. Margins are tight and the sector (particularly the parcel sector) is highly competitive. As such, load factors (how full the vehicle is) are high and delivery schedules are optimised using complex software. Therefore, it was felt that a CUCC would represent full vehicles being unloaded and the goods loaded onto another vehicle for final delivery. This would be inefficient and not reduce the number of freight vehicles in the affected area (unless larger vehicles were used to combine loads, which results in different issues). These inefficiencies would increase costs, which would then be passed onto the customer, raising prices. It is very expensive to run a vehicle, most of the costs are in the last mile delivery leg, and therefore freight operators reported being highly incentivised to reduce empty running. ===== PAGE 27 ===== 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). #### 4.4.2 High Service Levels 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). ### 4.4.3 Tracking of goods 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. ### 4.4.4 Third Party Risk 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. #### 4.4.5 Customer expectations and the value of brand 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. ### 4.4.6 Software compatibility and commercial sensitivity 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. ===== PAGE 28 ===== It was felt that for CUCCs to work, customer data would need to be shared with third parties, this would introduce issues with data security efficiencies and introduce extra liabilities. There is also the issue of how duties and taxes are collected for international shipments. #### 4.4.7 Political Barriers Public sector respondents highlighted potential political opposition to CUCCs, which would occur if there were concerns amongst voters or the business community if a CUCC were to represent overregulation or unnecessary market interference. ### 4.5 What models of operation would be most effective? Generally, the concept of a CUCC was not well received by respondents and there was little support for the approach under any model. It was felt that if there were efficiencies associated with the approach then the freight sector would have already capitalised on this, with other interventions being more effective. It was felt that specifying commodity groups (e.g., particular groceries or retail items) that a CUCC would handle would be difficult to enforce and represent a burden to the sector. An example given was the Palletline network, where palletised goods are transported by multiple operators to a single depot on a 'hub and spoke' basis. The goods are then delivered by that operator to end customers. This arrangement is undertaken on a purely commercial basis and cited as evidence that freight operators do collaborate where there are potential efficiencies and cost savings. AICES stated that whilst members utilise their own consolidation centres for delivery, there is a concern around 'area mandated' consolidation centres for towns and cities. Whilst consolidation centres can work to help reduce congestion and costs, area mandated consolidation centres which are not administrated, or have a degree of control by express operators cause several issues. Respondents stated that CUCCs need to be at an optimum location within a walkable/cyclable distance from the centre, lockable, secure, good access to road network, flexibility in contracts, with business buy- in or an engaged group of businesses that are keen to use it. One successful example of CUCCs cited by several respondents was at airports, where security clearance requirements mean it is advantageous to drop and collect parcels from a location on the perimeter of the security cordon. These could then be transported within the airside area of the airport by dedicated vehicles and avoids the need for security clearance for all vehicles serving the airport. Access to islands (Such as the Isle of Wight and Scottish Islands) were felt to work well for consolidation, with consolidation arrangements already in place at both these locations. This helps reduce crossing costs and vehicle movements on rural and less developed highway networks once a vehicle was on an island. The concept of micro- consolidation/micro hubs was also felt to have potential, with certain goods being brought to a site near those receiving the goods and the 'last mile' being undertaken by cycle logistics or walking deliveries (although the RHA outlined limitations in the size/weight of goods that could be carried and potential issues around a lack of regulation for e- cargo bikes). The respondent from Amazon was keen to emphasise use of the term 'transhipment' rather than consolidation as that is what they are developing in places such as London. The example of Regent Street in London, where limited storage space and high land values means retailers struggle to retain enough stock in stores was suggested as a successful example and one where there is a commercial basis for the intervention. Note that this differs from the literature review which suggested that only a minority (20- 30%) of deliveries into the Street were being consolidated. Parcel lockers were also cited as an opportunity for consolidation, which is being rolled out by the freight sector, often in 'carrier agnostic' banks of lockers with the customer representing the first/last mile. Construction consolidation centres were also felt to have merit and examples were highlighted that significantly reduced vehicle movements associated with construction sites in urban areas. Planning conditions could be used to enforce their use as the development is under construction. Public Sector respondents felt that collaborations between public and private sector to create partnerships were key and that harnessing a combined skillset of regulatory powers, innovation, practical experience in ===== PAGE 29 ===== delivering projects, connections and networks and specialised knowledge on a variety of subject matters was vital. They felt that voluntary consolidation centres often only captured a minority of vehicles and often the freight sector (especially major retailers/grocers) operates efficiently without the need for support. ### 4.6 Summary Whilst responses to the concept of consolidation centres were generally neutral or favourable, there was strong resistance to CUCCs. Freight operators felt it was unnecessary market intervention that would increase inefficiencies in the sector, increase costs and not meet stated environmental and social aims. The parcel sector had numerous barriers (operational, technological, financial) to working with competitors in this way and that regulation forcing these changes would represent a major deterioration in service for customers. There were, however, specific sectors and areas where CUCCs might work (and to an extent are already in place). These include airports, those serving islands and major construction sites and the case has been proven for these by previous or current examples. There was also support for micro consolidation/micro- hubs which are relatively small in scale and served by cycle logistics or walking deliveries. Freight operators are currently exploring this concept and see potential for further expansion. Overall, the stakeholder consultation revealed there are significant barriers to the introduction of CUCCs and it was felt that they would not be effective other than in specific applications and otherwise represent a burden to the freight and logistics sector as well as the wider supply chain. ===== PAGE 30 ===== ## A.1 Literature Review Methodologies ## A.1.1 Introduction Literature reviews are utilised to help build understanding of extant knowledge, identify gaps, and draw out concepts to frame a field. Such framing may be used to inform research or consultation questions, and then to judge those further outcomes. Most literature reviews in social sciences are 'narrative' reviews, developing an overview of a field through a reasonably comprehensive assessment and critical reading of the literature. An alternative approach, originating in medicine and traditional sciences is the 'systematic' review. This applies a transparent, replicable, and often quantitative methodology to literature identification and review. In some highly quantitative fields, a researcher may adopt a meta- analysis, extrapolating and synthesizing results from multiple papers. The use of full or partial systematic literature reviews in operations management, transport and logistics research has increased in recent years [22- 26]. The Critical Appraisal Skills Program (CASP) has developed methodologies for systematic and critical reviews of literature since 1993 [27]. With roots in UK healthcare, it is not tied to any discipline and has been deployed for qualitative as well as quantitative sources [28]. The approach, which acts as an inclusion/exclusion protocol is viewed as rigorous but flexible and has in recent years been adopted by operations and transport researchers in both systematic and semi- systematic reviews [29]. It has been noted that a weakness of literature reviews in the field of transport, was the lack of explicit methodology [30]. To mitigate this, we adopted a "semi- systematic review". This is a review guided by a systematic review in terms of literature survey and selection [31], combined with "framing a written discourse about the literature which may be established as a part of a thesis or other research" [32]. This hybrid approach allows for an emphasis on such features as transparency about searching, and the potential for comprehensiveness. These "systematic" protocols have been evidenced in use to create replicable research search procedures, for cross- checking or follow- up research in another place or at a later time. The narrative phase of the review allowed for insight from reading and understanding to allow a "plurality of knowing [33]". This addressed the suggestions that a metric- driven meta- analysis is not appropriate for transport- based literature reviews, due to the "fact that many variables influence an independent variable (e.g., travel behaviour) in a complex way, resulting in complex causal relationships, and a multitude of data analysis methods and interpretations" [30]. The protocol adopted is shown graphically, as a flowchart, in Figure 1 below. ===== PAGE 31 =====
Figure 8: Semi-systematic literature review, [34]
## A.1.2 Systematic Review The first steps of the review resulted in various results, detailed in execution and interim findings as follows. ## A.1.2.1 Top-level scoping Explicit searches were run to report the overall range and depth of literature in this top- level field. This was completed using Web of Science [WOS]4, Google Scholar [GS], the EU Transport Research and Innovation Monitoring and Information System [TRIMIS5], EUR- LEX and the Addleshaw Goddard databases. A large proportion of non- peer- reviewed literature existed in this field, often from research projects in the form of reports and other deliverables. Bryman called this 'grey' literature - of great value in many fields of research into people and systems. To enable a semi- systematic review of such materials, we utilised research outputs catalogued within the NOVELOG toolkit6 [35]. Since research and innovation projects and ===== PAGE 32 ===== interventions had preceded academic publication in this field, this database provided a comprehensive but parallel inventory for the grey literature review process. #### A.1.2.2 Top-level results The field in which the review was carried out and renewed many times, lay in the enquiry into and about the role of compulsion in the setting up and operating of urban consolidation centres. Initial reading and personal insight had revealed this to be variously defined as 'urban logistics', 'city logistics', and/or also 'urban freight'. Searching for ("urban freight" or "urban logistics" or "city logistics") in abstracts in the WOS reported 2,204 records as of \(10 / 5 / 2022^{7}\) . The papers were published in fields largely related to transportation, management, urban studies, and environmental studies as shown in Figure 2 below.
Figure 9: Domains associated with Urban Consolidation Centres (UCCs), Wed of Science
It was apparent that this field was novel and, over recent years, the number of publications and citations had risen sharply: suggestive of a field of research emergent in academic research. ===== PAGE 33 =====
Figure 10: Recent publications regarding UCCs, Web of Science
Publication dates offered further evidence that this was a newly emergent area of publication, with around \(51\%\) of all articles published after 2016 as shown in Figure 3 above. These preliminary searches were followed up by a focused series of searches. #### A.1.2.3 Focused Searches Focused searching followed using keywords and search terms developed further from the core research questions and the top- level scoping. This subset of the literature was then examined against an inclusion/exclusion list. These focused searches formed the body of work for the next step, which was a narrative review of the key literature. These focused searches cover the timespan 1970- 2022. This approach was applied to each of the topics identified above, as shown in Table 1 below:
Review topicExplicit WOS search termsWOS Result s8TRIMI S9 Result sGS
consolidation/distribution centre/center((AB=("urban consolidation centre")) OR AB=("urban distribution centre")) OR ALL=("urban60161,91 0*
===== PAGE 34 =====
consolidation centre")) OR ALL="("urban distribution center")
Urban land use and planning with freight/logistics((AB="urban") OR (AB="city")) AND ((AB="("land use")) OR AB="("town planning")) AND ((AB="("freight") OR AB="("logistics")))1117147*17,8 00*
Urban freight consolidation/distribution centre/center((AB="("Urban freight consolidation centre")) OR AB="("Urban freight consolidation centre") OR (AB="("Urban distribution centre")) OR AB="("Urban freight distribution center")))11834*
Urban/city logistics/freight and compulsory or mandatory measuresAB="("urban freight" or "urban logistics" or "city logistics") AND ("mandatory" OR "compulsory"))2311
Table 2: Topic search terms [\\* excluded] ## A.1.3 Grey Literature The grey literature- focused review was firstly based on the 19 projects recorded in the NOVELOG database, then investigated further, primarily on GS as more suited to finding non- peer- reviewed reports, handbooks, and other grey literature. Reading and judgement of the key deliverables drew attention to certain key bibliographic projects, listed in Table 3 below, which focused on good practice collection, taxonomy, and conceptualisation of the field.
Project Name(s)Source
Co-gistics 2014-2017[36,37].
CIVITAS urban freight initiatives 2002-present[38].
The Smartfusion 2012-205 and STRAIGHTSOL 2011-2014 projects[39,40].
SUGAR 2009-2011, BESTUFS 2003-2008, BESTFACT 2012-2016 etc.[41-43].
===== PAGE 35 =====
NOVELOG 2015-2018[44].
TURBLOG 2013-2014[45].
Trailblazer 2010-2013[46].
Table 3: Key Bibliographic Projects on Grey Literature In addition to the original items found, and after consideration of the wider field and certain key items of grey literature from UK and EU projects, additional works were added. These primarily reflected the top authorship in the field and personal expert knowledge, leaving a final review bibliography of 578 articles,reports and documents as recorded in Table 1 above. Once completed, the CASP systematic review protocol was applied. In many cases, the authors of papers, project managers and global colleagues were consulted informally by phone, messaging, or email to round out details, discover new sources or elicit follow-up information. This was in parallel to the more formal consultations. # A.1.4 CASP Inclusion/Exclusion Process The articles and grey literature were imported as documents and citations10 into the Mendeley reference manager. The resulting database was deduplicated and then filtered through the inclusion/exclusion protocol.A source had to receive a 'YES' in all boxes of the CASP checklist, following reading and reader judgement,as detailed in Table 3 below. CASP inclusion/exclusion protocol for literature review
A: Screening question: Does this work address a clear question?YesNoCan't tell
1 Does this work address a clearly focused issue?
a A clear statement of the aims of the research?
b Have an appropriate study design?
2 Is the work relevant to the research questions and the purposes of the literature review?
B: Are the results of the study valid?
3 Does the work clearly explain it's research methods?
4 Does the work clearly explain it's data collection?
5 Does the work elaborate concepts or theory in a meaningful fashion?
C: How are the results?
6 Are the results of the work explicit and easy to understand?
7 Is the work and the conclusions sufficiently presented to support descriptive findings?
8 Does the work add to the knowledge or theory in the field?
9 Are the results important in practice?
Table 4: CASP list for inclusion/exclusion adapted from [27] Works that explored theoretical and conceptual matters were given a greater qualitative weighting in the assessment for question A2 (above in Table 3). Largely empirical works were likely to be excluded at A2, or questions C8 or C9 (ibid) with minimal contribution to knowledge, theory, or practice. Following the application of the CASP, the number of works was reduced from 598 to 31 from which we drew out the concepts to construct and narrate a framing. # A.1.5 Framing The concepts identified were organised into a conceptual framing, to support both the analysis, inform the consultation process, and seek advice from the legal advisors in the team. ===== PAGE 36 ===== ## A.2 References NB: This may include references that were not in the literature review. The full list of the final sources for the review are in Appendix A.3. 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