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Local Transport Plans 3 Draft guidance responseFreight on Rail welcomes the opportunity to comment on Local Transport Plan3 guidance. The members are as follows:- The format of our response is a short introduction with a definition of Freight on Rail , its members, and then responses to specific sectionDefinition of Freight on Rail 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. In particular, it aims to help local authorities through all stages of the process such as planning a rail-freight strategy, accessing grants and dealing with technical matters. General We welcome the emphasis on integration with other policy priorities in LTP3 such as planning, social inclusion, environment such as air quality. We also welcome the fact that no authority will be exempt from producing a LTP. We believe that there should be a requirement to align LTP timescales to new regional strategies. However, we believe that the guidance underplays the potential role of the railways given that reducing carbon emissions from transport is the joint top challenge identified by the Government in its DaSTS policy and the Climate Change Act. Ref P11 2.8 22. Environmental policies and guidance. Rail freight has a crucial role to play in the low carbon economy and local authorities need to be strongly encouraged to plan and make financial provision for rail freight schemes. An example of funding provision is for road links to an intermodal terminal. We believe that the DfT needs to do more than merely make recommendations. It is unclear what if any sanctions there are on local authorities if they do not plan for CO2 reductions. We believe that the Government needs to help Las create a framework to enable/encourage success as there is currently no penalty for poor performance and no incentive or reward for good performance and no real accountability to the public. It is not clear what incentives the DfT is offering LAs to minimise emissions, nor does there seem to be any funding implications for reducing or not reducing emissions. Therefore we believe that the national goals in DaSTS need to say more clearly what success looks like, if they are to be useful to LAs. In particular, firmer guidance is needed to state that addressing climate change has to be a key aim of LTPs. We do not believe that the guidance fully recognises rail’s role in providing sustainable transport solutions. The following statistics highlight the benefits of rail freight.
According to the Government’s own figures Road fatalities cost the Government £3bn per annum. Overall, road accidents cost around £18 billion per annum according to the Road Safety Foundation. Consultation Questions Question 1. Is it clear what is required of LAs in producing an LTP? 3.4 climate change Once carbon reduction strategy is launched this summer is it the DfT’s intention to revise LTP3 in line with this Government policy? Once NPSs are published then LTPs need to take account of them 3.5 LTP funding LTP funding 3.5 RFA2 are the latest example of the gap between policy and actual schemes submitted by local authorities. RFAs has shown that many regions have put forward schemes which do not reduce carbon dioxide emissions in line with DaSTS and yet the Transport Minister Paul Clark has said that he does not intend to ask regions to revisit their schemes unless something stands out. 31/32 We welcome the reference to using the expertise of partner bodies. These should include environmental organisations. Safeguarding rail alignments and sidings in LDFs is crucial if rail freight volumes are to increase so that freight emissions, road congestion and road accidents can be reduced. Clear National and regional rail safeguarding policies are needed if rail is to play its full role in reducing carbon emissions from transport ref P16 section 5 National Policy Statement on national networks or another national mechanism should be used to list alignments/corridors of interest. There is a danger that if there is not a mechanism to protect land for the railways that through Delivering a Sustainable Transport System (DaSTS) corridor processes we will get safeguarded alignments for roads but not for rail. Up until now, safeguarding has relied on local authorities but this does not allow a wider vision for the low carbon economy. Currently the General Development Procedure Order (GDPO) mechanism allows Secretaries of State to safeguard corridors which have been identified as needed, as in the Crossrail example but there needs to be a mechanism to protect possible corridors for rail which should be protected for long term use. Reference P19 3.7 paragraph 23 and 4.4 needs to make a stronger case for integrating land use planning and transport by explaining the need to safeguard rail corridors in LDFs and LTPs. Planning Policy Statements Planning policy statement PPG13 is very important to protect rail alignments, sidings and sites for rail freight terminals for possible future rail use, even when there are no definite rail plans envisaged during the life of the plan. So Freight on Rail asks that PPG13’s safeguarding policies are not watered down in any forthcoming revision and streamlining process of Planning Policy Statements. In fact , Freight on Rail would like to see PPG13 strengthened in its safeguarding element in order to protect rail corridors as part of the move towards the low carbon economy. However, new PPS12, 2008, is already causing problems on route safeguarding, where local authorities are interpreting the guidance as only protecting routes which not only have plans which will be carried out during the life of the local plan but also need to be fully worked up in terms of cost, engineering and financial feasibility. This will have a dramatic effect on local authorities ability to protect rail routes for future possible use which is vital if the country is going to cut its carbon emissions from transport. New PPS12 places an emphasis on having a "sound" evidence base and being able to guarantee "deliverability." i.e. a scheme must have been fully worked up in terms of cost, engineering and financial feasibility, otherwise LAs may not be able to include future safeguarding. We support the policies outlined in Ref Chapter 3 Strategic Policy framework National Transport goals 3.2 and 3.4 that clearly define not only the need to plan schemes to reduce carbon emissions from transport but also that they assume that constraints on the UK’s greenhouse gas emissions will become more challenging ref 3.4. However, we believe that the DfT needs to make it even clearer to local authorities that they must comply with national guidelines on reducing carbon dioixide emissions by stating that the DfT will assess LTPs ref 3.10 It will be vital that national government insists to regions/local authorities that options and packages of solutions to problems in their areas make progress on all the Government’s 5 goals and the challenges, and that this progress is measurable and effective. For example, sub-national government must contribute to meeting carbon reduction targets; it cannot opt out of this as some regions have during the current RFA2 round. We urge the Government to insist that regions/local authorities do give effective weight to a full range of options including modal shift and land use changes. The regions will need to be given clear directions from Central Government about the urgency of reducing carbon emissions so that rail schemes are fully evaluated. The allocation of funds to developing schemes will be important as many local authorities have dedicated staff to develop roads but not rail - DfT may have to moderate its insistence on early or easy deliverability to allow longer-term planning for sustainability. It is important that there is early collaboration between DfT, Network Rail and authorities with clear guidance from DfT on rail schemes. It is not clear how ministers will ensure local delivery of national goals or even receive consistent information on delivery, when local authorities have more freedom to pursue their own agenda as invisaged currently. Better safety security and health goal Rail is a safer mode of freight transport which should be taken into account when appraising the inherent benefits of different modes. Safety aspects of rail freight 1 rail passenger died during 2007. According to the Government’s own figures Road fatalities cost the Government £3bn per annum. Overall, road accidents cost around £18 billion per annum according to the Road Safety Foundation. The Transport Select Committee report – Ending the scandal of Complacency October 08 that there is a degree of underreporting of serious accidents and stated that These are startling conclusions. If the degree of under reporting is as great as that suggested then the Government’s apparent success in reducing serious accidents and possibly deaths on the roads largely evaporates away. Freight on Rail is concerned that this under reporting could mean that the inherent dangers of HGVs are underplayed. Lumping together deaths and serious injuries makes analysis more difficult and should be replaced with separate reporting and targets in 2010. By lumping together “killed and seriously injured” in the targets for 2010, there is an incentive for the authorities (including the police) to under-classify injuries. The Transport Select Committee report – Ending the scandal of Complacency October 08 While we support policies to reduce road accidents, we would point out that transferring freight to rail will reduce road accidents significantly because HGVs, because of their size and weight are disproportionately more likely to be involved in fatal accidents for example. On motorways, HGVs are over three times as likely as cars to be involved in fatalities from road accidents per billion kms travelled. DfT figures dispel the myth that lorries are safer on motorways than other roads. In terms of road safety of different types of vehicles, what really matters is how dangerous HGVs are on different types of roads in relationship to other vehicles. Lorries are in fact less safe on motorways than A roads, because of the forces involved, ie weight and speed implications of HGV traffic travelling faster on motorways. Sources for Tables 2 & 3: TSGB 2007, Goods Vehicle Statistics 2007, Goods Vehicle Accidents and Casualties 2007, all DfT In order to implement the goal -Reduce the social and economic costs of transport to public health including air quality impacts – local authorities need to consider the following policies:-
b) Shifting freight to rail can reduce road maintenance costs for authorities and reduce emissions and road congestion Question 2. We believe that the guidance should give more advise, guidance and checks to authorities on how to promote modal shift through its plans. Need for detailed rail freight planning guidance Now that the Act has gone through, we believe that this project should be undertaken to advise local authorities about rail freight and the IPC, public inquiries as it is difficult for authorities to be specialists in rail freight. It is difficult for local authorities to be experts in rail freight therefore clear guidance which explains the structure of the industry and how the planning framework relates to rail freight is crucial as so many planning decisions about terminals are made at a local level. Without planning permission for more terminals, it will be impossible to shift more freight to the railways. 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. Chapter 4 4.6 Governance Process of developing LTPs ref 4.7 Para 26 – local hubs are not just a transport issue – danger that a pure transport approach to local hubs would ignore the “place” side of things compared to “movement” Freight Consolidation centres should be sited at locations that are capable of being rail connected so that rain can offer the trunk haul and road complete the final leg into city centres. Paragraph 30 D Appraisal of transport options The appraisal system should not penalise smaller schemes because appraisal is more difficult for them. Need to reform appraisal in order to reduce carbon emissions from transport
Para 33 – It should be noted that the rising costs of road schemes could mean that they are not actually deliverable (as in RFA briefing) Partnership working ref 4.12 Also the DfT Logistics Perspective of December 08 is not mentioned We believe the annex should mention Freight on Rail publications and website Philippa Edmunds
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