Freight on Rail is a campaign working to get goods off roads and onto rail as an important step in developing a more sustainable distribution system.

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.

2. Benefits of rail freight

Tonne for tonne moved, rail produces over three times less carbon dioxide1 than road freight.

Rail can act as a freight by-pass
Rail freight can help ameliorate road congestion. Road congestion is claimed to cost businesses in and around the capital £1.2 billion per annum - Draft Freight Strategy, Transport for London Summer 2005

Remember an average freight train can remove 50 HGVS from our roads and an aggregates train can remove 120 HGVs from our roads2

Rail is a safe mode of freight distribution.
Safety comparison – 1 rail passenger died during 2007.
2946 people died in road accidents during the same period - Transport Statistics 2007 & Office of Rail Regulation (rail figure excludes trespassers and suicides)

DfT research stated that because of their size and weight, when they are involved in accidents the level of injury tends to be higher.

HGVS were twice as likely to be involved in fatal accidents as cars in 2007 – Road Statistics Traffic Speeds Chart 10 p 115 2007, issued July 2008

TRL stated that when trucks are in a smash they do serious damage. HGVs in the UK account for only 6% of all vehicle-km driven but are involved in 17% of road accidents where there are fatalities – Iain Knight Commercial Motor 17th July 2008

Lack of compliance with existing road regulations puts other road users at extra risk

Over 82% of HGVs exceeded their speed limit of 50 mph on dual carriageways and almost three-quarters exceeded the 40 mph limit on single carriageway non-built up roads in 2007. Source: DfT Transport Statistics Traffic Speeds Figure 3.5C for 2007 issued July 2008

Vosa spot-checks 1st,5th October 2008 found that half of all the UK registered lorries stopped were breaking the law. IFW 21st October 2008

3. Summary response to A new plan for London

Given the need to reduce the capital’s carbon dioxide emissions and recognition that rail provides a low carbon energy-efficient alternative to road freight, Freight on Rail believes that policies and support for modal shift should be given a greater emphasis in A new Plan for London

The reasons being:-
A new Plan for London is a statutory strategic document which defines the policy framework for land use planning for London which all planning policies and decisions have to take into account at the GLA and borough levels.

P10 section 6 states that London Plan also legally forms part of the development plan in each London borough. Therefore we believe it is crucial that the new London Plan supports modal shift in order to be able to meet its stated challenges of improving air quality, to improve quality of life, achieve the highest environmental standards and avoid climate change as stated in the Mayor’s vision

If rail freight is to play its role in reducing road congestion, carbon emissions and road freight accidents, strategic spatial plans need to explicitly support rail freight by stating support for the shift to sustainable freight distribution, need to safeguard suitable sites by railways for interchanges, rail alignments in the same way that wharf sites need to be safeguarded for water freight opportunities.

This is necessary because
a) Suitable land beside railways is scarce and therefore needs to be protected. There is also conflict with housing needs for brownfield lands.
b) There is suppressed demand for rail freight

If the rail network were enhanced significant amounts of freight could be transferred to rail. New RFG/FTA demand forecasts show a 30% increase in tonne km from 2006 to 2015 and more than doubling by 2030. However the growth in intermodal traffic is forecast to be very much higher; more than doubling by 2015 and a fivefold increase by 2030.

Industry endorsements
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

c) It is hard for rail and water freight to compete, because road freight does not pay for all the external costs imposed on society, such as road accident and infrastructure costs.

Research this month by Campaign for Better Transport stated that HGVs are only paying between one to two thirds of the costs they impose on society3. Research from the European Commission also estimates that HGVs only pay around two thirds of their external costs averaged across EU member states.

Therefore given the economic and environmental imperative to reduce carbon emissions from freight, it is vital that the Government and the GLA support rail freight through the following

a) by providing the right planning framework which enables planning permission to be gained for terminals
b) Supportive policies and funding for rail enhancements give industry the confidence to invest in rail freight long term.
c) capital and revenue grants show commitment to rail and enable business to offset some of the initial start up costs of the shift to rail.
d) SPG for rail in addition to water freight.

The Mayor’s role
Planning Decisions
Freight on Rail believes that the Mayor has a crucial strategic land use planning role which can ensure that the right planning decisions can be made for London and for the wider national benefit. Through its powers as a regional planning authority it can ensure that sustainable strategic decisions can be made which have regional and national significance by highlighting the wider economic, social and environmental benefits of rail freight.

We believe that there is a need for right regional planning framework through the London Plan which gives strategic direction to local authorities, without which it would be difficult to get planning permission for rail freight terminals, an essential element if freight is to be shifted from road to rail.

Difficulty of getting planning permission for terminals/interchanges unless the new London Plan explicitly supports the shift to rail and has a stated policy of an approximate number of how many large SRFIs are needed and how more small to medium sized terminals are needed as previously stated in the London Plan. London Plan specified that 3-4 SRFIs were needed in the Greater London area. In the interim Howbury Park has been given planning permission so likely that around 3 additional SRFIs are needed with an additional 18 small to medium sized terminals needed also in the Greater London area.

Without this overarching London policy it is difficult for boroughs and Public Inquiries to give planning permission for terminals where there is local opposition and local disbenefits such as increased lorry movements.
Under the terms of the new Planning Act, strategic interchanges of 60 hectares and over will be evaluated by the Independent Planning Commission where the need for such terminals will already have to have made through regional spatial and transport strategies including a New London Plan and the National Policy Statements.

The London Plan needs to give direction to the local authorities so that a wider national, regional and sub regional perspective can be taken on transport planning. Therefore we support the aim of A new London Plan to integrate land use planning and transport planning.

Safeguarding role of GLA
As well as promoting rail freight, the London Plan also gives guidance to local authorities to protect disused rail alignments and sites suitable for terminals. This is crucial because once suitable sites by the railway are gone to the industry, they are lost to society for ever. The loss of wharves to residential development has presented similar problems for water freight. There are a very limited number of sites adjoining the railway which have the right characteristics, and access to suitable roads.

Often it is not possible to forecast whether a site or track bed may be needed in the future as markets and redevelopment etc change. Examples of where old lines have been crucial in enabling new or reopened routes is the East London line and Chelsea to Hackney for the planned Crossrail project. Cricklewood is an example of a key rail freight facility site which has needed protection in GLA and local plans.

There are examples of strategic rail and water freight sites, redeveloped for housing, which should have been retained for transport use. It is more difficult to reinstate transport use after a non transport redevelopment. Given the economic and environmental imperative to reduce greenhouse gas emissions, it is crucial that these mistakes are not made again.

The support of the GLA for rail freight gives direction and guidance to local authorities to enable them to give planning permission for rail freight terminals which are for the wider good but can suffer from local opposition because of local disbenefits such as lorry movements to the rail interchange.

Therefore we urge the GLA to maintain these policies to safeguard rail alignments and transport corridors for future possible rail use.
PPG13 allows local authorities to protect sites and alignments for rail even where there is no planned potential rail use as long as there sites are defined in local plans.

We believe that the London Plan as the spatial strategy has a key role in promoting sustainable distribution and offers an overarching framework for sub regional working

4. Detailed comments on chapters
Regeneration Chapter 2, P34 and Chapter3
Important to protect suitable brownfield sites beside railways for terminals and sidings and alignments for future rail use, otherwise these sites will be lost for ever to society which needs to be able to take advantage of low carbon rail distribution if the country is to meet its legal climate change targets.

You will be aware that there is huge competition for development of brownfield sites, encouraged by Planning Policy Guidance note 3 which gives priority for housing on brownfield sites. This makes a strategic lead by the GLA all the more important if suitable sites for freight terminals and railheads are to be retained.

Chapter 4 London’s economy and Chapter 5 London’s response to climate change
Rail freight’s role in servicing the economy and reducing freight footprint need to be recognised. An average aggregates train which comes into the capital can remove 120 HGVs4 from its roads. DfT Logistics Perspective December 2008 states that rail produces over a third less CO2 emissions per tonne carried than road5.

P58 Minerals policy fails to mention the importance of rail transport as a means of reducing the carbon footprint in this sector. Approximately 60% of the quarried stone used in London is transported by rail, and overall rail plays a role in the transport of 40% of all construction materials used in the capital.

In the same way, the policy does not recognise the role of rail in removing industrial waste from construction sites.

Chapter 6
P62
Section 167
We believe it would be helpful to mention the benefits of transferring to low carbon freight modes and use rail freight as an example as well as cycling and walking and electric cars as freight emissions are a significant and growing issues in the capital. And as mentioned before Government figures confirm that rail freight produces over three times less carbon emissions than road freight. Industry figures show that rail is up to fifteen times better than road in terms of other noxious emissions.

While we fully support the safeguarding of strategic wharves we would point out that it is crucial to protect strategic sites for rail freight interchanges and rail alignments beside the railway. The re-opening of the East London line demonstrates how important rail alignment protection is and similarily measures to protect the rail freight facilities at Cricklewood have already been key in safeguarding a nationally significant site in London for rail freight facilities.

Integration of land use planning and transport section166
We fully support this policy and believe that it is necessary for the new London Plan to give strong guidance to the boroughs on promoting sustainable freight alternatives to road. It has to be recognised that there is not a level playing field between road and rail which makes it crucial that national, regional and local government put strategies in place to protect rail routes and sites and state their support for modal shift to rail and water. See Page 3 section C

P62 para graph 169
Crucial that land is safeguarded for transport see our section on safeguarding on P4
It is important also that the policies in PPG13 which support safeguarding are retained

PPG13 states that

Identify and, where appropriate, protect sites and routes, both existing and potential, which could be critical in developing infrastructure for the movement of freight (such as major freight interchanges including facilities allowing road to rail transfer or for water transport) and ensure that any such disused transport sites and routes are not unnecessarily severed by new development or transport infrastructure. In relation to rail use, this should be done in liaison with the SRA which is best placed to advise on the sites and routes that are important to delivering wider transport objectives;

It is vital that the GLA guidance to the London boroughs directs them to protect such sites.

We believe a stronger policy direction is needed to encourage rail freight than that mentioned in 169 for the reasons given, if low carbon energy efficient safer modes like rail and water, are to develop, because road freight does not internalise all its costs which is therefore picked up by society which makes it difficult for rail and water to compete.

Connecting London
In reviewing the London Plan we ask that improving rail freight access to ports and across London is mentioned as a priority

Similarily the second highlighted list of proposals does not mention freight whatsoever and therefore we believe that freight/rail freight should be mentioned.

Appropriate transport in the Thames Gateway must recognise the role of rail freight in transporting deep sea containers from the Gateway to destinations across the UK.

Reducing road congestion

As mentioned in Page 1 of our response rail freight has a key role in reducing road congestion and can be used to bring certain cargoes into London such as aggregates, construction materials and container traffic and remove others such as industrial waste

Freight P 64/65
We support the promotion of SRFIs, item 1 in highlighted section on P65

However we believe that the term interchanges is a better term than transfer capacity in the second bullet on P65 as interchanges offer more added services such as warehousing than just freight transfer.

We believe the policy to protect railheads should not just be confined to aggregates as railheads handle various cargoes now such as waste, spoil and container traffic and it is important that flexibility is allowed in the London Plan to cater for market changes and rail network enhancements which open up new opportunities.
Examples include European gauge freight flows through the Channel Tunnel to Barking which should come on stream in 2010 with opportunites to expand the network further across the UK. Example of suitable cargo is premium freight, ie express parcels and mail from the continent which could significantly reduce emissions with transfer from road and air currently being used.

The policy should support rail to road consolidation centres as well as breaking bulk road consolidation centres.

Consolidation centres need to be designed appropriately and include rail access if the low carbon advantages of using rail are to be realised. We believe that greater use of rail would be feasible for delivery to the Olympic Games construction if the logistics consultants specify the criteria needed for consolidation centres, to maximise the use of rail. This would reduce lorry movements and emissions and exposure to road accidents in the capital and beyond.

We believe that the environmental, economic and social benefits of rail freight for the capital should be exploited therefore recognition of rail’s role in addition to the Blue ribbon scheme is needed if London is to improve its air quality, overall quality of life and regenerate the economy.

We believe that the GLA should produce SPG for rail freight in addition to the planned one for water freight given the imperative to reduce greenhouse gas emissions from freight. Rail and water freight need similar land use planning protection and Government and GLA promotion, given that the other modes do not pay either for the external costs imposed on society or for road congestion which makes it hard for the sustainable modes to compete. There has been a sea-change in governmental and public perceptions of the need to accommodate more freight on rail so policies which support and promote modal shift to rail are crucial if the GLA and the Government is to meet its emissions targets and reduce lorry movements.

EIP
Retention of rigorous EIP procedures is important as the existing procedures have been able to test the robustness of regional strategies.

Freight on Rail was pleased to take part in the EIP of the London Plan and gave evidence at the inquiry into important policy definition for strategic rail freight terminals.

SPG for Transport has been important in both promoting rail freight and protecting suitable sites for rail freight interchanges and should therefore be retained.

Development control powers over strategic important applications should be retained and used where necessary.

We believe that it is important that the Mayor and GLA gives strong direction to the local authorities to protect and safeguard suitable rail freight sites and alignments and also gives direction to local authorities to reduce carbon emissions. Without direction from the GLA it can be difficult for councillors to support rail freight facilities which have regional and national benefits but encounter local opposition due to local disbenefits.

We support the London Rail Freight Strategy August 2007 which is a daughter document of the Freight Plan and urge the GLA to retain the policies enshrined in this strategy. We endorse the three separate documents have been produced to accompany the Strategy and urge the GLA to promote this rail freight strategy and encourage the London boroughs to do so also.
A Planning Policy Toolkit, aimed at assisting Borough planning officers in
designating suitable sites for rail freight in Borough development plans
A Development Control Toolkit, to assist Borough development control officers in
reacting to rail freight planning applications
A list of suitable sites for rail freight
in London Boroughs

It is important to safeguard suitable sites for rail freight interchanges for possible rail use in London Plan and borough Local Development Frameworks. Important that boroughs are aware of their responsibilities in this regard.

FoR is pleased that the Rail Freight Strategy identifies the need to ensure that adequate network capacity exists for both passenger and freight needs.

Philippa Edmunds Freight on Rail Campaigner June 17th 2009

1. DfT DaSTS Logistics Perspective P8 rail produces around 0.05 kg of CO2 per tonne km compared to around 0.17 kg CO2 per tonne km for road transport.

2. Network Rail 2009

3. Source Heavy Lorries do they pay for the damage they cause by MTRU and peer reviewed by Institute for Transport Studies LeedsApril 2008

4. Network Rail 2009

5. DfT DaSTS Logistics Perspective P8 rail produces around 0.05 kg of CO2 per tonne km compared to around 0.17 kg CO2 per tonne km for road transport