Consultation on Transport 2025

1. Freight on Rail is pleased to respond to this consultation.
    

Definition of Freight on Rail

 
The members are as follows: - Rail Freight Group, EWS, Freightliner, RMT, ASLEF, TSSA, Amicus, Network Rail and Transport 2000

1. Comments on Transport 2025 (T2025)

Executive summary

P7 T2025 rightly highlights tackling climate change, enhancing the environment, reducing traffic congestion and road accidents as key transport objectives. Rail freight has an important role in reducing road congestion and carbon emissions within the distribution sector, as the following statistics a) b)  & c) illustrate.

Transport, the economy and the environment 2.4 P27

No mention is made here of the impacts of freight and the role rail freight has in reducing road congestion, road accidents and harmful emissions

a) Congestion

An average aggregates train can remove 120 HGVs from our roads – Network Rail 2005

An average intermodal freight train can remove 80 HGVs from our roads – Freightliner 2005

Road congestion is claimed to cost businesses in and around the capital £1.2 billion per annum - Draft Freight Strategy, Transport for London Summer 2005

b) Emissions

Tonne for tonne rail freight produces 90 per cent less carbon dioxide than road transporti

Freight Transport: Average emissions in grams per tonne-kilometreii

Mode	PM10	CO	NOx	CO2	VOC
Rail	0.004	0.032	0.31	15	0.021
HGV	0.048	0.33	1.74	180	0.15

Key: PM10 particulate matter of less than 10 microns; CO carbon monoxide; NOx oxides of nitrogen; CO2 Carbon dioxide; VOC volatile organic compounds. 

c) Reducing road accidents

Road Statistics

There were 12,516 accidents involving HGVs where injuries were sustained, of which 472 were fatal and 2,142 serious injuries

In 2004 2,883 HGV drivers and passengers were injured, of which 453 were killed or seriously injured.

HGVs were involved in 12,516 accidents where injuries were sustained of which   472 were fatalities.

Source Road Casualties Great Britain for 2004 issued September 2005

Rail Statistics

Rail safety – 5 passengers died during 2004 Health and Safety Executive (rail figure excludes trespassers and suicides)
 
Richard Eastman divisional Director for Network Strategy at Highways Agency in Freight magazine interview May 06 stated that

“Many of the worst incidents involve HGVs. It takes time to physically clear heavy vehicles from the carriageway and by their nature, accidents involving them tend to be more serious”.

Introduction P11

Freight distribution is not mentioned in this section. The importance of promoting the shift to sustainable freight distribution using rail should be made in the context of serving the economy and improving the quality of life. 

A mayor transport challenge is to manage traffic levels and road capacity

P42

Freight demands

We support the policy to encourage modal shift and accept that the scope is limited.

However on Page 43 the wording in the penultimate paragraph which states that

There are very limited alternatives to roads for freight as most origins and final destinations cannot effectively be served by rail or water, is unduly pessimistic and suggest the word very should be removed which would be consistent with P42.

Rail freight has a proven record in certain sectors and as the London Rail Freight Study of 2004, commissioned by TfL  stated the following are strong markets with potential for growth:-aggregates, construction, waste, intermodal and energy did however highlight that there is an urgent need for more rail freight terminals and transhipment points if the modal shift to rail is to be realised.

P50 Tackling climate change

There is no mention in this section of the environmental benefits of rail freight in terms of tackling climate change. An explanation of the benefits of rail freight should be given.

Tonne for tonne rail freight produces 90 per cent less carbon dioxide than road transportiii

Freight Transport: Average emissions in grams per tonne-kilometreiv

Mode	PM10	CO	NOx	CO2	VOC
Rail	0.004	0.032	0.31	15	0.021
HGV	0.048	0.33	1.74	180	0.15

Key: PM10 particulate matter of less than 10 microns; CO carbon monoxide; NOx oxides of nitrogen; CO2 Carbon dioxide; VOC volatile organic compounds. 

Policy Options

P63

Last paragraph Freight consolidation centres

Where possible freight consolidation centres should be rail connected.

P64  Encouraging modal shift

In addition to better use of the waterways it should be stated that there are opportunities to remove freight from the congested road network to rail.

Land use policy 4.2.2 P64

Freight on Rail fully supports work to integrate land use planning and transport policy and would like to see this important subject covered in more detail in T2025. The document does not explain why integration of land use planning and transport is so key in order to get modal shift. Nor does it explain the crucial role local and regional authorities play in defining land use planning practice.

There is, however, no mention of PPG13 which states that rail lands can be protected if identified in Local Development Frameworks by local authorities even where there is no potential rail use envisaged. The important issue is that once the rail land is gone it is lost as part of the railways and to society for ever. And often it is not possible to forecast whether a site or track bed may be needed in the future as markets and redevelopment etc change. There are examples of strategic rail and water freight sites, redeveloped for housing, which should have been reinstated for transport use. 

PPG13 states that transport lands can be protected even where there is no identified transport usage as long as it is identified in the Local Plan as railway lands.  PPG13 clearly indicated that even where there was not a reasonable chance of future use of an old transport link, unnecessary severance was still to be avoided. See precedent set by Mansard County Homes LTD v Surrey Heath Borough Council 2002

There is huge competition for development of brown field sites, encouraged by Planning Policy Guidance note 3 which gives priority for housing on brown field sites.  This makes a strategic lead by TfL all the more important if suitable sites for freight terminals and railheads are to be retained.

Partnership role of central, regional and local government

Central and Regional Government should promote partnerships between the rail industry and other interests, such as councils, developers, employers, tourism bodies and development agencies, to improve the railway locally. Local authorities in particular have an important role in brokering partnerships of this nature, alongside Network Rail, to implement new rail schemes. The London Sustainable Distribution Partnership is an example of an important partnership.

Crossrail

It is vital that existing and potential freight services are fully catered for alongside Cross rail services.

Rail 2025 - 4.3.2

There is no mention of the beneficial environmental footprint of rail freight, nor of its role in the economy and its amelioration of road congestion.

Any passenger rail improvement must take into account existing and forecast rail freight flows and not disadvantage rail freight services or the potential for shifting more freight to the railways.

Under the section improvements P73

It should be pointed out that rail enhancements benefit both passenger and freight services and that it is a shared railway.
Work to improve capacity and capability on the north London lines should be mentioned and identified, in particular on the Tottenham to Hampstead line.

P74 Rail freight

We would support the recognition given to meeting the forecast growth in rail freight demand in the period but would ask that the policy details the key measures needed to meet the forecast demand, i.e.

Capacity and capability upgrades on the Tottenham to Hampstead line which will relieve pressure on the North London Line including Stratford and also act as a diversionary route when maintenance work needs to be carried out on the NLL. 

As far as noise is concerned, research has shown that noise from railways is perceived as less invasive than the noise from road freight.

The ability to bring European gauge trains to London, with the opening of the second phase of the CTRL, represents a major opportunity to bring goods to London from mainland Europe efficiently and with low environment impacts.  Freight on Rail welcomes the work TfL Rail is undertaking to investigate the viability of extending terminal facilities at Barking to facilitate this traffic. As mentioned, the next steps are to extend this continental gauge route across London.

The consequences of not investing 4.5 P84/5

Investment in rail capacity and capability is key to controlling climate change, reducing road accident and road congestion. There is no comparison of the actual emissions differences between the modes only reference to the benefits of sustainable modes. Given that there is such a stark difference between the emissions from rail versus road and air, we believe that a chart should be inserted.

Overall rail produces less than one per cent of the total U.K. emissions of carbon dioxide, the principle greenhouse gas, compared with 21 per cent from road transportv. Rail freight can act as a freight bypass by offering a more reliable alternative to road.

Issues facing road transport

• Road congestion is causing extended and less predictable journey times.
   
• Existing driver vacancies 47,000 with the average HGV driver age now 55.
   
• Working Time Directive is estimated to require another 30,000 and to cost the road freight industry an extra £1 billion per annum.

Road congestion is claimed to cost businesses in and around the capital £1.2 billion per annum - Draft Freight Strategy, Transport for London Summer 2005

 
Philippa Edmunds Freight on Rail Campaigner August 2006
Telephone: 020 8241 9982
Email:Philippa@freightonrail.org.uk

i. AEA Technology for Strategic Rail Authority, October 2004
ii. SRA February 2005
iii. AEA Technology for Strategic Rail Authority, October 2004
iv. SRA February 2005
v. The Railway Forum 2005