Freight on Rail Response to the Department for Transport Consultation into National Policy Statement (NPS) on Planning for Ports Inquiry
Thank you for the opportunity to comment on the consultation
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.
Executive Summary
The Planning System sets the spatial planning and transport framework upon which transport decisions are made. It is therefore crucial that the economic, social and environmental benefits of rail freight are full reflected in the Ports NPS. Freight on Rail has long campaigned for national spatial planning to set the policy framework and to give guidance to regional and local transport and spatial planning.
Therefore we are supportive of National Policy Statements (NPSs) in principle; however we believe that the Ports NPS should give a stronger steer towards rail and water modes. The DfT has issued its long-term vision for rail freight in the Strategic Freight Network (SFN) of 2009 and we believe that port development should be structured around the SFN with ports contributing to it, where appropriate.
The case for stronger support for rail freight in the Ports NPS
Transport is one of the largest sources of greenhouse gas emissions, accounting for at least 21% of UK CO2 emissions and freight contributes almost 30% of that which comes almost entirely from road freight. Rail freight has an important role in reducing freight’s emissions and has the potential to deliver a 70 per cent reduction in CO2 emissions compared to equivalent road journeys1.
Most of the country’s major ports now have a strategy for transport which involves modal shift from road to rail with the greater rail market share being a key component of the sector’s drive towards sustainability. In support of these plans there is considerable investment in rail being proposed or under way;
- Within the ports - investment in rail terminal capacity.
- On the rail network - public investment in the “Strategic Freight Network” involving capacity and gauge enhancement specifically to serve the intermodal market - supported by contributions from ports and Development Agencies.
- At inland terminals - approaching 40 proposals nationally, at various stages of development, to create expanded private inland rail interchange facilities to capitalise on modal shift.
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.
Rail Freight Group/Freight Transport Association forecasts of June 2008, indicate that by 2030 rail freight volumes will have more than doubled. The majority of this growth will be in the intermodal (container) sector, much of it to and from ports – from 6 billion tonnes.km today to over 30 billion.km in 2030.
Intermodal traffic gained market share in recession
Despite the fact that major ports traffic over the quay is down between 10-20% rail volumes increased by 1.1% in quarter 2 09/10 (ie July, August September 09) compared to the previous Q2 results for 2008/09. This shows that rail has increased its market share over the period and continues to win new business showing that the growth in intermodal traffic is being sustained, even in difficult trading conditions.
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.”
Consultation Question 2
The Ports NPS lack of support for sustainable transport sets a poor precedent for the National Networks NPS and the energy NPSs. It treats carbon dioxide as one of the problems among many and does not prioritize the need to reduce emissions and does not recognise the potential rail has to reduce emissions, road congestion and road accidents by increasing its market share out of and into ports.
DfT has confirmed that local and regional authorities will have to take material consideration of NPSs in their planning and transport decisions and therefore this point should be made in all the NPSs.
Question 4
Given that the need to reduce carbon dioxide emissions has been recognised by the Government in its Climate Change Act, which commits in statue to an 80% reduction in CO2 emissions by 2050, and in the DfT’s vision for Developing a Sustainable Transport System (DaSTS) the Ports NPS should have stronger policy support for rail freight, where there should be a presumption in favour of rail and water where possible.
Rail freight can contribute to all five of the DaSTS goals, ie
- supporting economic competiveness and growth
- Reducing transport’s emissions
- Contributing to better safety security and health
- Improve quality of life and promote healthy natural environment
- Promote equality of opportunity
Freight on Rail recognises that rail and road complement each other; however, rail can transport long distance freight more sustainably and more safely while reducing road congestion and resulting delays.
Rail freight is an important part of the transport solutions at ports with approximately 50% of rail freight volumes either emanating from or going to UK ports, therefore the Ports NPS is important in this context. Given both the volumes of freight handled by rail from and to ports and the need to reduce carbon dioxide emissions, set out in the Climate Change Act of 2009, we believe that the Ports NPS needs to give a much stronger support for rail freight.
Rail’s customers want more capacity and capability at UK ports
Customers have stated their preference for using rail out of ports
As an industry we need all the rail freight we can get MD Maersk Sealand
“Having a rail alternative is more economic, cuts delivery times and is more reliable”- Arthur Koutstall ECS European containers
The case for rail freight
Rail freight has a crucial role in helping the Government to achieve the low carbon economy and green jobs we all need.
- Carbon reduction - As your Department’s Logistics Perspective of December 20082 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 accidents3 than cars due to a combination of size, lack of proper enforcement of drivers hours, vehicle overloading and differing foreign operating standards.
Question 16
Ports Management
Ports should provide low carbon power for ships to use while in port so that they do not have to use their own engines which are heavily polluting to the area around ports.
Question 36
There is a danger that the scrutiny of the Ports NPS could be rushed as it seems odd that the TSC oral submissions and evidence are being conducted before the end of the formal DfT consultation. It is therefore crucial that the written consultations to the TSC and the DfT consultation are given full weight.
1. Detailed response to the Department's consultation on the Ports NPS
DfT NPS scrip in Italics
Section 2.17
P15 question 2
Paragraph 22
Coast shipping and the use of inland waterways and rail connections can have advantages over road transport since they generally act to de-congest the road network with associated travel-time and safety improvements and may have environmental benefits relating to noise and pollution levels
The DfT Logisitics Perspective document of December 2008 shows that rail freight produces 70% less CO2 than the equivalent road journey. Therefore we believe that the wording may is inappropriate in the context of environmental benefits.
Paragraph 23
The definition of most cost-effective modes needs to take into account whether the different modes pay for all the external costs imposed on society, otherwise sustainable modes such as rail and water are penalised.
Climate change mitigation
2.13.1 This paragraph recognises the environmental benefits of modal shift to rail and water; however this support for modal shift to sustainable modes is not carried forward in the NPS in particular in the transport policy, climate change adaptation and the guidance for decision makers.
Paragraph 2.13.6 Page 33
The decision-maker should have to give full not limited weight to the estimated likely net carbon emissions performance of port developments for the reasons spelt out in the answer to TSC question 2.
Mitigation Page 33
2.13.7 Good design for rail freight facilities can minimise emissions and other local pollutions such as noise.
Climate change adaption
P34 2.14.2
The fact that previous global greenhouse gas emissions will result in continued climate change for the next 30 years, makes the case for rail even stronger to ameliorate these effects.
Transport 2.17
2.17.1
Given that rail and water reduce the adverse environmental, social and economic impacts of goods entering and leaving ports the Ports NPS should state a preference for rail and water.
2.17.2
The wording - There are also environmental impacts or road transport compared with rail and water transport in terms of emissions does not adequately acknowledge the known emissions benefits of rail and water.
2.17.3
Neither is rail’s ability to reduce road congestion and delays nor its role in reducing the need for container storage adequately recognised here.
2.17.5
We believe that the applicant should have a strong duty to demonstrate why rail cannot be used.
Modal share P47
2.17.17
Stronger support for rail should be given in this paragraph
2.17.19
Gauge is not a problem for on unitised goods and in the case of hi cube containers lowered wagons can be used if routes do not have W9/10 gauge. There is particularly important for smaller ports where increasing the gauge may not be practical. There are also wagons which cater for short sea containers.
2.17.21
We accept that conditions should be structured flexibly but think that the current wording could enable developers to avoid investing in rail.
2.17.22
We believe that target modal shares are a good mechanism for encouraging rail freight. Another mechanism is incentivising developers to sponsor rail freight services.
Philippa Edmunds Freight on Rail - 9th February 2010
philippa@freightonrail.org.uk; Tel 020 8241 998
1. Source DFT Logistics Perspective Dec 2008 P8 p 8 section 10 Rail produces around 0.05 kg of CO2 per tonne km compared to around 0.17 kg of CO2 per tonne km for road transport;
2. Page 8 section 10
3. Source: Road Statistics 2008, Tables 3.2 and 3.6, Road Freight Statistics 2008 Section 5, both UK Department for Transport
