Way To Go

Freight on Rail is pleased to respond to this consultation and is pleased to take part in any stakeholder engagements and consultations undertaken by the GLA. We were active members of the London Sustainable Distribution Partnership and are keen to build on work carried out by the group.

 
1. Summary

Freight on Rail supports the policy to improve London’s environment and tackle climate change and would like to highlight the role that rail freight can play in providing a sustainable alternative to road for certain cargos.
As the Stern report of December 2006 stated it is an economic as well environmental imperative that carbon dioxide emissions are controlled if climate change is to be avoided so rail freight should be at the heart of any distribution policy.

We note the lack of mention of rail freight in this document and trust that the Transport Strategy will take its policies from the TfL Rail Freight Strategy which was published in August 2007 and supported by Freight on Rail. Freight on Rail sat on the working party during the writing of the rail freight strategy.

The TfL rail freight strategy and its accompanying documents highlight the importance of rail freight to the capital and we endorse its aims. The strategy was published with a Planning Policy Toolkit,a Development Control Toolkit and a list of potential small to medium sized sites for rail freight development in London which we believe will help the boroughs both protect key rail freight alignments and suitable sites for terminal and plan rail freight projects. 

We believe that together they form a very important planning resource to assist the development of rail freight terminals in London.

The sites list also serves as a companion to the GLA’s
‘Supplementary Planning Guidance – Land for Transport Functions’ which supports the protection and safeguarding of rail freight sites and alignments for future rail use.

Produce SPG for rail freight as well as the planned one for water freight
We request 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.
 

2. Why rail freight is important to London

We trust that the policies from the Rail Freight Strategy will be incorporated in London’s forthcoming revision of the Transport Strategy.

As the rail freight strategy states:-

Rail freight is a safe and sustainable alternative to lorries, producing less casualties and up to 5 times less carbon dioxide per tonne carried.

It can have a major impact on reducing road traffic – an average freight train can carry the equivalent of 50 lorry loads and an aggregates train can carry the equivalent of 120 lorry loads.

Forty per cent of all London deliveries to the construction industry are now carried by freight trains, a figure which is growing due to the increasing competitiveness of rail.

To achieve shift to rail freight it is necessary to ensure there is capacity on the network for freight trains and develop the right facilities, such as modern warehouses next to rail links. Without these warehouse facilities, there is no realistic alternative to road freight for the distribution industry.

As recognised in the TfL Rail Freight Strategy, rail freight plays a vital specialist role of freight serving London. In particular, the construction industry in London is heavily reliant on rail for the distribution of stone, cement etc around the city. 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.

The key existing and potential markets for rail freight are:-

• Bulk freight – construction materials, waste and containers
• High value freight – cars car parts food and drink and containers
• Premium freight – express parcels and second class mail
• International freight – through the Channel Tunnel and ports 

The greater part of rail freight in London is travelling through the city and doesn’t serve it directly and this situation will not change. The largest element of this ‘transit’ freight is deep sea container flows between the major ports to the East of London and the rest of the country. Other flows include Channel Tunnel traffic and flows of nuclear waste for reprocessing between nuclear power stations in the East and South East of England and Sellafield. While a limited amount of the traffic from the Haven Ports can be diverted via Nuneaton, on what is known as the Cross country route, once major  capacity and capability upgrades have been completed, the majority of the rail freight traffic which transits London, will have to carry on using this route. In fact demand for this route will increase when the Thames Gateway comes on stream in 2011.

This situation reflects London’s position as the hub of the UK rail network.
The railways were built as a series of radial routes serving the main London termini. The ‘orbital’ routes (North, West, South London Lines, Gospel Oak to Barking route etc) allow freight to pass between these radial routes and are crucial to the UK economy so we fully support the capacity and capability enhancements being undertaken on this route. These upgrades will allow passenger and freight services to prosper and are crucial to cater for suppressed demand rail container services which are forecast to increase 5 fold across the country by 2030 according to RFG/FTA forecasts of August 2008.

Rail offers a carbon dioxide reduction solution to GLA

Emissions from road freight present a growing problem in London which rail freight can help ameliorate.

Based on 2006 data, the estimated contribution from freight transport in
London is 2.2m tonnes of carbon dioxide (CO2) emissions, which accounts
for 23 per cent of the total ground-based transport and 5.1 per cent of the
Capital’s CO2 production and energy use.
HGVs alone, which account for around 6% of road traffic miles, are responsible for 22% of all road transport carbon dioxide emissions and 20% of carbon dioxide emissions from all domestic transport

HGV traffic has grown by 20% since 1990 with a the 14% rise in CO2 emissions1

Tonne for tonne moved, rail produces between three to five times less carbon dioxide2 than road freight (depending on cargo).

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 roads3.”  

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

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

Lack of compliance with existing speed restrictions which 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

Lack of level playing field between modes

Because road freight does not pay for all the external costs imposed on society, such as road accident costs, it is hard for rail and water freight to compete.  

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 society4.  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
 

3. Land use Planning policies

The right land use planning framework is crucial if rail freight volumes are to increase in line with the need to reduce carbon emissions from freight. 

The GLA can set this policy framework:-
a) by providing the right planning framework through the Transport Strategy and the London Plan which enables planning permission to be gained for terminals which entails
- Protecting suitable sites by the railway with good road connections for potential terminals
- Protecting rail alignments for possible future rail use, eg East London line is using the old route to Broad Street. As once rail sites are lost to the railways, they are lost  for ever to society.

The SRA SRFI Strategy of 2004 and the subsequent endorsement of these polices by the DfT in  October 2005, subsequent to the end of the SRA, have identified the need for an additional four major terminals in the London area. In addition it stated that there was a requirement for at least an additional 18 smaller terminals. Since then Howbury Park has received planning permission for a SRFI in SE London. The support of TfL and GLA was crucial in obtaining this permission.

It is important to protect sites which may have no potential rail use at the moment but as shown with the East London Line example, which was safeguarded, may be needed in the future. This is particularly so now that the imperative to reduce carbon dioxide emissions are universally recognized.

Freight on Rail believes that the London Plan and Transport Strategy should state that rail lands should be protected even where there is no evidence of future possible use because, as shown with the disposal of avoiding lines, economic factors change so it is critical to safeguard rail lands for future possible use. Once rail lands are gone, they are gone for ever to the railways and society. The judgment in the case of  Mansard County Homes Ltd v Surrey Heath Council 2002 showed councils countrywide that they can protect disused railway land for future potential railway use, even where there is no immediate evidence of future possible use as long as the sites are protected in their Local Development Frameworks.

One of the factors is that there are a limited number of sites which have the right criteria to be viable for rail freight facilities making it all the more crucial that the ones that are suitable are safeguarded. 
Cricklewood rail lands are an example of a strategically important national site, which prior to long standing redevelopment proposals, was a thriving rail freight terminal, which is strategically placed for bringing freight into the heart of London in a sustainable mode and therefore needs support from the GLA and TfL.

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 support the policy to ensure that suitable sites and facilities are made available to enable the transfer of freight to rail through the protection of existing sites and the provision of new sites.

We would ask that the GLA gives guidance to the London boroughs that they should protect suitable sites in their the Sub Regional Development Frameworks (SRDF), Local Development Frameworks (LDF) and Local Implementation Plans (LIP) otherwise the sites will be used for non rail purposes. It is the planning system at the GLA level and local levels via LDFs  which protect rail lands including sites for rail freight sidings and rail alignments.
 

4. Key rail freight projects

a) Upgrade of the North London Line
Freight on Rail supports the crucial upgrade work to the North London Line for both passenger and freight services including the DfT announcement of the £54m to four track west of Camden Road announced in the Pre-budget report.

b) Olympics
Rail freight has a key role to play in ensuring that the target of moving 50% of materials by non-road haulage is met.

c) Additional terminal capacity for rail freight interchanges in Greater London

Philippa Edmunds
Freight on Rail  Campaigner   January 15th 2009

 

1. Carbon Pathways DfT 2008
2. EWS 2007
3. Network Rail 2008
4. Source Heavy Lorries do they pay for the damage they cause by MTRU and peer reviewed by Institute for Transport Studies Leeds. April 2008