Freight on Rail Response to the DECC consultation into National Policy Statement for Energy (EN-1)

Thank you for the opportunity to contribute to the consultation on the overarching Energy NPS (EN-1).

Freight on Rail definition
Freight on Rail is a partnership between transport trades unions, freight operating companies, the Rail Freight Group and Campaign for Better Transport. It 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 to central, regional and local government.

1. Executive Summary
The Planning System sets the spatial planning framework upon which transport and planning decisions are made. It is therefore crucial that the economic, social and environmental benefits of rail freight, for transportation purposes, are full reflected in all the Energy NPS with a default for rail or water, where possible.

We urge that the points we make in EN-1 are fully taken into consideration in all the energy NPSs where appropriate.

Freight on Rail has long campaigned for national spatial planning to set the policy framework and to give guidance to regional and local spatial planning therefore we are supportive of National Policy Statements (NPSs) in principle. DfT has confirmed that local and regional authorities will have to take material consideration of the DfT led NPSs in their planning and transport decisions and therefore this point should be made in all the NPSs.

The NPS implies that many of the sites will be the same as existing ones and presumes that there will only be the existing transport links. Just because there are no rail connections currently at a site, it does not mean that rail should not be the preferred option in the future.

The case for stronger support for rail freight in all the Energy NPSs

Rail already has a significant market share in the movement of coal to power stations from ports and from domestic mining. It also has a significant market share in moving spent nuclear waste. Rail should be used for delivering biomass which this NPS recognises as increasingly important. In the construction phases rail should be used for transporting building materials to the sites for energy projects and for the removal of industrial waste. Rail or water should be used to remove gypsum from power stations, where appropriate.

Rail freight has a crucial role in helping the Government to achieve the low carbon economy and green jobs needed.

Carbon reduction - As DfT Department’s Logistics Perspective of December 20081 shows rail freight produces 70% less carbon dioxide emissions than the equivalent road journey.
Road congestion relief - An average freight train can remove 50 long distance HGVs from our roads with the largest freight trains each now removing up to 160 long distance HGVs
This means that moving more freight to rail can also have an economical impact; considering that the DfT estimate the cost of congestion being £1 per lorry miles on the most congested roads.
Safety - Rail freight is safer than long-distance road freight using motorway and A roads, as HGVs are over 3 times more likely to be involved in fatal accidents2 than cars due to a combination of size, lack of proper enforcement of drivers hours, vehicle overloading and differing foreign operating standards.

Government Policies support the need to reduce carbon emissions

Climate Change Act, which commits in statue to an 80% reduction in CO2 emissions by 2050=

The DECC commitment -To contribute to sustainable development by seeking energy infrastructure development that helps reduce climate change while also minimising negative impacts on the local environment

The DfT’s vision for Developing a Sustainable Transport System (DaSTS)

Rail freight can contribute to the DaSTS goals of supporting economic competiveness and growth, reducing transport’s emissions, contributing to better safety security and health and improve quality of life and promote healthy natural environment.

Rail Freight volumes and potential
Rail freight, which has 11.5 per cent of the surface transport market (rail and road), was estimated to have removed 6.7m long distance lorry journeys from UK roads equating to 1.4 billion lorry kilometres in 2007/08. Coal moved in 2008‐09 was 7.91 billion net tonne kilometres.

Rail Freight Group/Freight Transport Association forecasts of June 2008, indicate that by 2030 rail freight volumes will have more than doubled.

All these factors are backed up by a report published by the Institution of Mechanical Engineers in early 2009, which states that: “ as an option for the reduction of carbon emissions, the rail freight sector is leagues ahead of all the other options available. The target should therefore be to deliver far greater levels of growth in the rail freight sector than are currently projected.”

In view of the NPSs acknowledgement of the need to reduce carbon emissions, we believe that the Energy NPSs should have stronger policy in favour of rail freight for transportation and should have a presumption of using rail and water modes, where possible.

2. Scrutiny and consultation process
There is a danger that the scrutiny of the Energy NPSs could be rushed as it seems odd that the Energy and Climate Change Committee sessions and evidence are being conducted before the end of the formal DECC consultation. It is therefore crucial that the written consultations to the DECC consultation are given full weight.

3.Detailed response to DECC consultation

Detailed response to the Department's consultation on Energy EN1 NPS
2.1.4 Transition to low carbon economy
This should include recognition of the importance of reducing the transport and construction carbon elements of power generation
Traffic and Transport impacts
4.28. We fully support the preference for water-borne or rail transport in 4.28.8 and state that this policy must be part of all the applicable energy NPSs. This should be clarified to make sure that measurement of cost effectiveness takes into account carbon, safety and congestion benefits of rail.

Mitigation
4.28.6
This provision for demand management should only apply for road infrastructure as we do not believe that demand management should be a substitute for investment in rail.

4.28.9 The IPC should also be able to make use of rail a mandatory planning condition both for the ongoing use and construction phase. Example of this was the use of rail for the construction of Terminal 5 at Heathrow.

Waste management 4.29
Rail and water should be stated as preferred waste removal modes for industrial and energy waste.

Philippa Edmunds Freight on Rail - 11th February 2010
philippa@freightonrail.org.uk; Tel 020 8241 9982

1. Page 8 section 10

2. Source: Road Statistics 2008, Tables 3.2 and 3.6, Road Freight Statistics 2008 Section 5, both UK Department for Transport