Freight on Rail response to Centro Freight Strategy consultation
Firstly, we would like to welcome the fact that you are writing a freight strategy which we believe is very important and thank you for the opportunity to comment.
Chapter 1 Context
P5 Our transport networks
In addition to mentioning the West Coast Main Line in the context of freight, we believe that it is necessary to take into account the following routes and regions in terms of destinations and origins of freight flows.
Routes to the
a) East Midlands and Yorkshire, and the North East
b) South West and Wales, the South Coast
The case for re-opening the Walsall to Stourbridge route which is based on both passenger and freight benefits, is predicated on freight flows between the South West/South Wales as well as regions north of the West Midlands.
P8 National Policy context
Your strategy rightly highlights the need to reduce freight’s carbon emissions in the context of Government report to the Committee on Climate Change legislation. Freight is a big CO2 emitter; domestic transport is 20% of UK total emissions and HGVs around 20% of that with limited scope to reduce its emissions; electric HGVs are not a option with current technology as the battery would weigh more than the vehicles’ payload. Therefore rail freight, which produces 70% less carbon dioxide emissions than the equivalent road journey, is the only practicable means of achieving the massive reductions required in carbon dioxide emissions from long distance freight on this corridor.
Proposed Freight Strategy objective P10
Freight on Rail supports the two key objectives of sustainable economic growth and reducing carbon emissions. However, we believe that other key LTP objectives such as health ( air quality), social inclusion and improving road safety need to be given due prominence.
Question 2 Do you support our vision
Freight on Rail is supportive of the need for a freight strategy as explained above
Your vision on P13 chapter 2 does include safer logistics movements so we ask for more consistency in your vision and objectives
In the final bullet
Reduce the quality of life impact freight movements can have on
people’s lives, improving safety for other transport users.
Add in reference to improving safety to include employees in the freight sector as well as other transport users. Eg train and HGV/van drivers, fork lift operators.
Rail freight is safer than long-distance road freight using major roads, as HGVs are over 3 times more likely to be involved in fatal accidents than cars due to a combination of size, lack of proper enforcement of drivers hours, vehicle overloading and differing foreign operating standards. Source: Road Statistics 2010 Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT
Chapter 3
Question 2 Do you agree with our proposed strategic approach and rationale to enhancing, supporting and investing in freight?
You mention the role of LEPs in promoting economic growth. However, LEPs do not have statutory status so it is crucial that local authorities, Integrated Transport Authorities and, Passenger Transport Executives are given a role in the strategic approach alongside National Government in promoting freight.
Promotion of co-modality is important. Rail and road complement each other and it is important that the different modes play to their strengths.
Chapter 4
Road Freight movements Part A
With reference to the DfT ten year trial of 2 metre longer lorries we would like to state that we do not believe that increasing HGV trailers by 2 metres will lead to the environmental and economic improvements stated by the Government .But we do agree with the Government analysis that, these longer trailers will reduce consumer rail freight growth by two thirds over the next 20 years. The assessments undertaken significantly under-estimate the safety, road congestion and environmental impacts of longer lorries on society and the economy and put certain lorry industry interests ahead of road safety and carbon reduction. The safety analysis seriously under-estimates the increased collision risks associated with longer trailers. Instead of exposing other road users to the increased risks associated with longer trailers the Government should adopt policies to improve existing road safety and enforcement of existing road regulations. The case for longer lorries relies on the same questionable presumption used in the past to justify each increase in lorry dimensions, that there would be fewer but bigger trucks on the roads. In practice however, since the previous increases in dimensions there is no direct evidence of larger or heavier lorries leading to improvements in average payloads or a reduction in empty running. In fact the Government own research shows that almost half of HGVs are neither constrained by weight or volume and that one in four HGVs are driving around empty 1. A reduction in empty running would have a far greater impact on congestion and emissions than increasing lorry dimensions.
Infrastructure costs to local authorities are not calculated in the DfT longer trailer research
The Technical Advisors Group (TAG) calculates that the additional costs for footway and kerbs based on generic asset costs will be around £410 million. At present there is a cost of around £21 million per annum across English urban authorities in repair and maintenance of current damage caused by HGV’s. Additionally TAG estimated that administrative costs per Controlled Parking Zone could be between £10k to £100k per zone - the 12 inner London boroughs alone have over 150 CPZ’s.
Any further increase in lorry dimensions and weights, which are being considered at a European Level as part of review of directive 96/53 would have adverse impacts on road congestion, pollution and road safety as trainloads of freight would be forced back onto our roads
Rail Freight part B P28
The benefits of rail freight in terms of reducing road congestion should be included in this section. This is important in terms of improving reliability of the road logistics sector as well as offering a crucial alternative freight mode.
Even though Government’s announcement on building HS2 has been made since the Freight Strategy consultation was launched, we would stress our opposition to the comments on P31 stating that either additional freight path availability requirements not being met or even removal of freight train paths for passenger services.
Centro should include the need for a European gauge cleared route between HS1 and HS2 so that the Midlands can take full advantage of these services which can carry high volumes of freight from the continent.
P32 The Initial Industry Plan schemes which are relevant to the West Midlands should also be listed.
P34 Proposed Freight Strategy approach
We support the new to develop intermodal terminal of all sizes to help shift freight to the railways as part of a sustainable freight policy.
In the context of national policy the following should be mentioned:
a) The Strategic Rail Freight Interchange Policy issued on 29th November 2011 as part of the Logistics Growth Review which recognises the role of Strategic Rail Freight Interchanges (SRFIs) in supporting economic growth and creating new jobs. It highlights that which stated that a network of freight interchanges are needed near the business markets, to link key supply chain routes, with good rail and road connections to facilitate trade links between UK regions and the European Union.
b) Draft National Planning Policy Framework, which is due to be published in March/April 2012 recognises the need to build rail freight terminals to achieve these aims through modal shift and the need to develop large scale facilities such as rail freight interchanges.
Strategy needs to include the fact that Strategic Rail Freight terminals are important in stimulating short-sea and domestic intermodal business as well as deep sea container traffic.
Key issues Rail Freight accessibility and connectivity P35
There is a strong passenger and freight case for re-opening the Walsall-Stourbridge line in terms of a diversionary route for freight and freeing up capacity for new passenger services.
Rail access for terminals on the route would enhance the benefits of the route and optimise the opportunities for rail freight. An additional benefit is the avoidance of the Lickey Incline for freight traffic.
Existing terminals for bulk traffic have not been mentioned in the strategy.
Regional Logistics sites P37
The different sections of the strategy and references to intermodal rail freight terminals and then the separate section on regional logistics sites need better cross referencing as it is difficult to understand the layout at present.
1. DfT figures CSRGT MTRU report 2011 P24 Chart 6
