Dear Ms Barker

It is crucial that land use planning and transport planning are integrated if carbon emissions from transport are to be controlled in line with the Stern Report recommendations. We agree that the planning system needs to be more streamlined and that big infrastructure planning has been inadequate in the past.  The new system must take into account the full environmental and social implications of projects as recommended by the Stern Review.

White Papers can provide clarity on national needs and should provide a context within which local and national needs can be weighed up. A national policy framework can also help to rule out some proposals at an early stage.

1. The economic and environmental case for rail freight
   Rail freight is ideally placed to meet this environmental challenge as it produces between four to ten times less emissions than road haulage, depending on the weight of the product moved.
   
   Rail freight has an important role to play in alleviating road congestion and according to research it is likely that road pricing will increase the demand for rail freight.
   


An aggregates train can remove 120 HGVs from our roads – Network Rail  2006

Full and thorough consultation is important as is a better system of funding local government so that local communities benefit from developments.

We believe that there is a strong environmental and economic argument for directing authorities to cite new warehouses and factories near rail lines on the basis that location of developments will dictate what type of transport is used. Thus giving businesses the option to use rail.
 
2. The need for national, regional and local guidance on rail freight
   Setting the right national regional and local planning framework for rail freight is crucial and that is why Freight on Rail, a partnership of the rail freight industry, the transport trade unions and Transport 2000, was set up to work with regional and local authorities to get the right spatial planning policies in place. To make provision for rail freight, authorities need to identify and protect existing and disused sites, lines and sidings with potential as suitable interchange locations. In particular, planning permission for rail interchanges, without which rail freight will find it more difficult to increase, will not be secured unless the right policies are enshrined in the spatial planning framework at national, regional and local levels and the national and regional benefits of rail freight spelt out.
   
   National rail freight planning guidance is needed to give direction outlining the national and regional benefits of rail freight if strategic rail freight sites and routes are to be protected for this use, otherwise these sites will loose out in the market-place to housing and retail and rail alignments will be obliterated. Without the support of the SRA, the freight railhead site at Cricklewood, which is a national strategic site, could have been allocated to housing to the exclusion of rail.
   
   The current example of Radlett shows that adequate road links are needed for interchanges. The Highways Agency is recommending refusal of the planning application to build an intermodal rail freight exchange on the grounds that the road network could not handle the traffic generated.

Another current example where more national guidance and analysis is needed is over rail freight terminals, with Significant proposals being advanced by private developers. In the absence of national policy, these decisions will be decided by local interests with national policy considerations coming only after potentially lengthy inquiries and then only a case-by-case basis. The L.I.F.E. public inquiry was long-winded and costly for the industry and failed largely due to lack of national and regional policy. It also discouraged prospects for developing similar schemes as the private sector was hesitant about taking forward similar rail freight interchange projects.

We welcome the recognition that major infrastructure proposals need to be evaluated in the context of national and regional benefits. We however envisage that the majority of planning applications for rail freight schemes will not be of sufficient scale to be considered by the Planning Commission and will continue to be determined at a local level.

These smaller schemes will also need strong national, regional and local plans to see the projects come to fruition. The lack of a rail agency makes the need for guidance for regional and local authorities crucial. With clear guidance, planning permission for rail freight terminals can be forthcoming which is vital if rail freight is to play its part in serving the economy and reducing carbon emissions.

We have campaigned vigorously on the strategic need for national and regional policy to set the framework for rail freight. In our previous submission to the interim Barker   Review, as shown in the boxes below, we make the case for strong national and regional guidance.

3. Case for Detailed rail freight planning guidance
    
   Freight on Rail has made the case for detailed rail freight planning guidance for planners to partially fill the vacuum in rail land use planning, since the demise of the SRA.
    
   After discussions with Freight on Rail and others, the Department for Transport Logistics division agrees that there is a need to produce this detailed planning guidance for local and regional authority planners and for Examinations in Public/Public Inquiries. Your recommendations support this need for guidance
    

4. Need to formalize position on land use planning issues relating to the railways
   With the demise of the SRA, it is important to formalise Network Rail’s position in land use planning terms and what the DfT’s role is. The lack of clarity has implications in   planning terms for the railways as it means that there may not be strategic rail representation at:-
   
            Public Inquiries and Examinations in Public
            Local planning authorities
   
   In the case of roads the Highways Agency represents road interests at Public Inquiries, EIPs and for local planning authorities. The Highways Agency also has regional representatives who comment on Regional Spatial Strategies and Local Development Frameworks.
   
   This situation makes detailed rail freight planning guidance all the more crucial to protect strategic sites and routes. This policy document would give authoritative guidance on strategic rail freight interests for planners at local, regional and national levels. It will aid in the preparation of planning strategies at
   
   Regional levels i.e. Regional Spatial, Transport & Freight Strategies, DfT Rail Regional Planning Assessments, Route Utilisation Strategies (RUSs) prepared by Network Rail.
   
   At local levels i.e. Local Development Frameworks, Unitary Development Plans and Local Transport Plans
   
   At Public Inquiries and Examinations in Public, a role previously performed by the SRA.
   
   Future versions of the National Freight Route Utilisation Strategies (FRUS)

5. Under Major projects
   3.8 Statements of Strategic Objectives - need for guidance on rail freight
   Proposals that clearer national policy statements should guide major infrastructure projects are welcome. We believe that rail freight guidance is needed which lays out clear criteria so that rail becomes easier to use.
   
   For example, planners should be encouraged to plan so that warehousing could be planned along rail corridors. Defined criteria would allow authorities to identify suitable sites for rail freight and exclude unsuitable sites.
   
   For example the Eddington Report highlighted the importance of international gateways and stated that national guidance on inland distribution from ports was needed. Rail freight carries a quarter of the share of intermodal cargoes through the ports. Container imports through the ports is expanding at six per cent per annum and so is the demand for rail to carry intermodal traffic.  We therefore welcome the TIFs announcement which states that crucial rail freight projects to increase capacity and capability which will enable rail to carry a larger percentage of the market thus alleviating road congestion will be taken forward by the DfT and Network Rail as part of the DfT’s Transport Innovation Funding (Productivity) (TIFs). We point out that the funding arrangements for these schemes will be critical.

Criteria for location of strategic rail freight interchanges,

To be effective interchange terminals must:

• Be on an existing  railway line – this sounds obvious but as building new railway lines is extremely expensive there is little chance of new lines for freight

• Have good road access suitable for HGVs – full –size lorries need to be able to serve railheads safely and with minimal impact on other road users.

• Be of sufficient size – today’s freight trains are often over 500 metres in length, modern handling methods safe working areas and value-adding activity (storage, processing, re-packing) need space.

• However we would like to qualify that there are however many examples of small profitable bulk terminals as opposed to intermodal terminals.

• Be capable of 24 hour operation – a requirement of many customers, which often means that activity at railheads must be able to take place outside these times. Residential property in the vicinity should be designed so that sleep is not disturbed.

• As well as needing new terminals it is important to push for expansion at existing sites also.

6. PPG13 Protection of transport lands identified in Local Plans
   PPG13 is important in the context of protecting rail lands at a local level. This ability to protect sites at a local level is dependent on national and regional policy which enables authorities to justify protecting transport lands.
   
   The judgment in the case of Mansard County Homes Ltd v Surrey Heath Council (Feb 2002 see our web site for full details) shows councils countrywide that they can protect disused railway land for future potential railway use, even where there is no immediate evidence of future possible use. This ruling means that authorities can protect railway sites and routes.
   
   In summary, planning and funding need to work together so that mode share is funded and can be delivered. We believe there is a need for defined national regional and local policies so that there is certainty for developers, rail industry and authorities if planning inquiries are to be streamlined. 

Yours sincerely

Philippa Edmunds
Campaigner