Crossrail Bill Environmental Statement May 2005

Department for Transport
Crossrail Bill Consultation Manager
Major Projects Division 3
Zone 2/08
76 Marsham Street
London SW1P 4DR
16th May 2005

Dear Sir/Madam

Crossrail Bill Environmental Statement

We are responding to the Department for Transport (DfT) April 7th News Release asking for comments on the Crossrail Environmental Statement, deadline 17th May 2005.

Freight on Rail, a partnership between transport trades unions, freight operating companies, the Rail Freight Group and Transport 2000 works to promote the economic, social and environmental benefits of rail freight both nationally and locally. It advocates policy changes that support the shift to rail and provides information and help on freight related issues. In particular, it aims to help local authorities through all stages of the process such as planning a rail-freight strategy, accessing grants and dealing with technical matters.

Freight on Rail members are EWS, Freightliner, Rail Freight Group, ASLEF, TSSA, RMT and Transport 2000
 

Summary

We would like to stress that , in principle we are supportive of the Crossrail project and view it as an opportunity to full integrate the network.

There are four key areas where the effects of the proposed Crossrail bill are not adequately handled

• Line Possessions during the construction period
  
• The compulsory purchase or temporary use of freight sidings
  
• Removing access from freight paths to remaining freight sidings
  
• Giving priority to Crossrail services on the existing congested network

We believe there are workable solutions to these problems which could have been considered earlier, had the rail freight industry been consulted when the Environmental Statement (ES) was being written. In particular, alternatives on the following issues:-

• Intention to move freight traffic from the slow to fast lines
  
• Intention to give priority to Crossrail on the shared sections of the route.

Failure to comply with Office of the Deputy Prime Minister's Guidance on Environmental Impact Assessments Consultation

The rail freight industry was not consulted. This guidance states that there should at least be preliminary consultation with parties affected by the proposals. Additionally the Environmental Statement should give a detailed description and its implications. For example, the ES should state likely impact of the proposed project on rail freight interests.

The European Community Directive also states that an ES should outline the main alternatives considered and the environmental impacts of the final scheme.

Any modal shift to road, as a result of Crossrail, will have significant environmental consequences as this recent statistics shows.

Work undertaken for the SRA by AEA Technology Environment shows that rail freight produces about one tenth of the emissions per tonne kilometre of HGVs. November 2004
 

Congestion on the existing network

No consideration is given for an option that takes into account existing congestion on the network for both passenger and freight services. In particular no assessment has been made of the scheme's impact on rail freight tonnage.
Transferring freight services to the "fast" tracks will cause difficulties in accessing freight terminals which are located adjacent to the existing "slow" lines on the Great Western Main Line.
 

The Construction Period

Use of rail for transportation of aggregates and construction materials

We believe that it is important that the opportunities presented for rail to service the construction of Crossrail are taken, in line with recommendations from the Great Western Route Utilisation Study undertaken by the SRA. (Ref Page 22 for rail to deliver rail-borne aggregates and construction materials.)
 

Network Availability at night and weekends

A significant number of freight services run during these periods so that plans to close lines during these periods to carry out work will severally affect freight services, especially at night.
 

Access to Rail Freight terminals and impact on road congestion

No environment assessment has been made of the impact of the temporary closure of many terminals which will result in freight having to go by road during the construction period. It is always hard to shift such flows back to rail. No assessment has been made of the impact the scheme will have on road traffic as a result of displaced rail freight. These issues will also impact on the CO2 emission projections discussed in the ES and should be taken into account.
 

Rail Freight Lands

Significant pieces of lands are exposed to compulsory acquisition However there is no assessment of the impact of displacement of the activities carried out on these sites and how much land will actually be needed.
 

Actual Crossrail Operations

The ongoing operation of the scheme will have a number of impacts on the environment that have not been properly examined in the ES. The Crossrail Bill, with which the ES was deposited, provides ongoing powers and obligations to the Office of Rail Regulation including giving Crossrail operation preferential treatment when it comes to the allocation of track access upsetting a transparent and established process accepted by the railway industry.

No assessment is made of the loss of rail freight traffic as a result of these plans to give Crossrail operational preferential treatment and the resulting environmental and safety implications as well as the likely increased road congestion.
 

Safety

Lorries are involved in 22 per cent of fatal crashed but only account for 7 per cent of road traffic - Transport Statistics GB 2004 edition
 

Congestion relief

An average freight train can remove 60 HGVs from our roads
An aggregates train can remove 120 HGVs from our roads -
Network Rail 2004

We refer to Government policy in 'The Future of Transport: A network for 2030' July 2004
"Goods need to be moved freely, reliably and efficiently, while minimising the impact on safety, the environment and other transport users"

On 6th December 2004, the Minister for Transport indicated in his second reading speech to Parliament on the Railways bill (which was subsequently enacted on 7th April 2005) the Government's strong commitment "…to give Network Rail clear responsibility for operating the network and for its performance, timetabling, route utilisation and so on.". The Crossrail Bill now provides Crossrail, through the proposed statutory preference imposed on the Office of Rail Regulation, with the ability to renege on this commitment without assessing its impact on the rail freight industry or the knock-on effects to the environment.

As track and depot access preference will be statutorily provided to Crossrail, rail freight operations will be less efficient. The environmental implications of which have not been accessed.
 

Access rights onto the Network

With reference to the Minister for Transport second regarding speech on the Railways Bill of 6th December 2004, an undertaking was given by the Minister that "[the] track will remain under the ownership of Network Rail…[and] we have no plan at all to transfer the track...". Contrary to this commitment the Crossrail Bill will provide the Secretary of State with the power to transfer the ownership of any land, including land upon which tracks are located, from Network Rail to another person or entity. This does not comply with the Government's white paper 'The Future of Rail' July 2004 in which it acknowledges that "to compete effectively with road haulage, rail freight operators need certainty about their long-term access rights and what they will costs".

No environmental assessment has been made of the likely impacts of these changes.
 

Summary

It would appear that full assessment of the environmental costs and economic impacts have not been carried out for this scheme as yet. However we trust this situation will be addressed as a matter of urgency.

Yours faithfully

Philippa Edmunds
Campaign Co-ordinator