Consultation on Local Transport Plan Guidance - July 2004

Freight on Rail welcomes the opportunity to comment on Local Transport Plan guidance.

The members are as follows:-
Rail Freight Group, EWS, Freightliner, GB Railfreight, RMT, ASLEF, TSSA, Network Rail and Transport 2000

The format of our response is a short introduction with a definition of Freight on Rail , its members, and then responses to specific sections.

General

Freight on Rail welcomes many aspects of the guidance but is disappointed by the absence of guidance on freight transport. We would like to emphasise the importance of consulting the rail freight industry, operators, the Rail Freight Group, Freight on Rail and users in preparing plans. The Freight Transport Association alone cannot represent rail freight interests.

However, we believe that the guidance underplays the potential role of the railways. This is also true of the White Paper, ‘The Future of Transport’. Rail services can provide a frequent and high capacity alternative to car journeys and promote economic regeneration. Rail, both passenger and freight provides a serious alternative to combat road congestion which is crucial for the economy as well as for society and the environment.

An average freight train can remove 50 HGVs from our roads. Two port examples of the importance of rail freight’s role in alleviating road congestion are Southampton and Felixstowe. Both the A14 and the A34 are key artery routes which are very congested. Currently rail freight services remove over a thousand lorries a day from both local and trunk routes from these ports. More freight could be transferred to rail with Government support for infrastructure enhancements. Both regions are experiencing economic growth which requires sustainable transport infrastructure development.

We do not believe that the guidance recognises rail’s role in providing sustainable transport solutions. The following statistics highlight the benefits of rail freight.

“Rail has a crucial role to play in the climate change debate; per tonne carried rail produces less than one fifth of the CO2 emissions of road transport . Office of National Statistics figures released 27th May 2004 showed that emissions from road freight transport increased by 59 per cent between 1990 and 2002.”

Rail travel is nine times safer than car travel, per passenger mile Rail Safety and Standards Board (RSSB) 2003.
The alarming increase in global carbon dioxide emissions, announced on 11th October. show what a key role rail freight can play in reducing air pollution and climate change. There has been a sharp increase in carbon dioxide increases in the atmosphere over the past two years with levels over 2 parts per million (ppm) in contrast to an average of 1.5 ppm over the previous 50 years.
 

Freight Transport

Given the scale and importance of freight transport it is regrettable that these is so little guidance to local authorities on what they can do to promote sustainable transport, in particular help facilitate modal shift and to limit the impacts on the community of freight transport . We believe that local authorities have a crucial role in shifting freight onto the railways as local and regional authorities set the framework upon which rail freight operates through the planning system via Regional Planning Guidance and Local Development Frameworks. So it is vital that regional and local spatial planning makes adequate provision for rail freight. It needs to identify and protect existing and disused sites, lines and sidings and suitable interchange locations. In particular, planning permission for rail interchanges, without which rail freight cannot increase, will not be secured unless the right policies are enshrined in the spatial planning framework. The recent case of Mansard County Homes v Surrey Heath shows councils countrywide that, with the strengthening of Planning Policy Guidance PPG13, they can protect disused railway land for future potential railway use, without fear of litigation if this land is identified in local transport plans even where there is no immediate evidence of future possible use. In addition to meeting some of the shared priorities (road congestion reduction, improving road safety and air quality) modal shift can generate savings in road maintenance costs and this should be reflected in the asset management section of the guidance.

Part 2 Developing a high quality LTP
2/19 Ref SRA. We believe the functions of the SRA Regional Planning team and the Freight Executive are crucial in specifying rail services and liaising with local and regional authorities. This is an important mechanism to help integrate land use planning and transport planning.

2/21 Strategies for sea ports should specifically include development of rail freight and not just of ‘freight vehicles’ which implies only road transport. Rail freight has considerable economic, environmental and social benefits as mentioned in our introduction which are important in the development of infrastructure at ports with high volumes and distances involved.

4/42 – 44 We do not understand why this section does not mention freight. Rail freight can be important in contributing to meeting the shared priorities. Freight on Rail works with local and regional authorities and the industry to promote rail freight. This guidance should also encourage authorities to identify flows and developments where rail might be feasible. This can feed into Transport Asset Management Plans where rail can remove large freight flows and thus remove road maintenance costs. A good example of this being traffic around quarries.

Annex B
Consultation
We would like to emphasise the importance of consulting the rail freight industry, operators, the Rail Freight Group, Freight on Rail and users in preparing plans. The Freight Transport Association alone cannot represent rail freight interests.

We believe the annex should mention Freight on Rail publications and website

Philippa Edmunds on 020 8241 9982
email philippa@freightonrail.org.uk
12-18 Hoxton Street London N1 6NG

Go to www.freightonrail.org.uk for press releases, case studies and links to members sites, key rail organisations and literature listed below:

Dispelling commonly held myths and setting the agenda for rail freight – a summary guide for local authorities

Freight on Rail’s Goods without the Bads – a detailed guide to planning and developing a rail freight strategy