Representations of GB Railfreight Limited
| Date | 18 March 2010 |
| Section | DBS Regulation 29 appeal regarding access to the Port of Felixstowe |
First
GBRf
18th March 2010 '15-25 Artillery Lane
London
E17HA
Tel:
02079043393
Fax:020 7983 5170
Paul McMahon
ORR
One Kemble Street
London
WC2B4AN
Dear Paul
DB Schenker Application under Regulation 29
for
Rail Access at the Port
of
Felixstowe
I am writing with regard to the above application and subsequent ORR
consultation.
As you will be aware First GB Railfreight operates 5 daily services from the
Port
of
Felixstowe to a number of inland destinations. We operate a
combination of fully contracted and "shared user" train services and have
been running trains from Felixstowe since 2001.
The Allocation
of
Rail Capacity at the Port
of
Felixstowe
Since 2001 the number of daily rail services from the Port of Felixstowe has
increased from 14 to 28 and both First GBRf and DBS have been
beneficiaries of this growth. Of the 14 new paths allocated at Felixstowe First
GBRf has secured 5, DBS 2 and Freightliner the remaining 7.
In order to facilitate the allocation of rail capacity in a structured manner the
Port introduced an informal bidding process which ensured each party
presented its case
for
capacity in a consistent and comparable format. This
process allows the Port to evaluate each bid in line with its wider commercial
objectives and considerations and specifically allows them visibility of where
allocating rail capacity will contribute to achieving those objectives.
We would be very concerned if Port rail terminal owners could be forced to
allocate rail capacity in a way that could result in them not achieving their own
commercial objectives. It is the ability for rail to contribute positively to the
achievement of such goals that drives third party facility owners such as
FDRC to invest in modern equipment and additional capacity. With this
freedom removed I cannot see such investments being made and rails growth
in this sector will stagnate.
The Efficient Use
of
Rail Capacity in Ports
Having secured valuable rail capacity at a port it is the job of the port rail
management team, train operators and adjacent network operators to ensure
that this capacity is utilised in the most efficient manner and container
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