Consultation on London Freight Plan

1. Freight on Rail is pleased to respond to this consultation and welcomes this strategy, and the forthcoming rail freight strategy, which is a daughter document of the London Freight Plan.

Appendix B

We would like to point out that we believe that the qualitative assessment of the contribution LFP6, to promote modal change, makes to the identified high-level objectives based on economic, environment and social criteria are far too low. Following your qualitative assessments LFP should represent the maximum point score on all the pillars of sustainable distribution.

Definition of Freight on Rail

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.

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

1. Comments on Draft Freight Plan

We welcome the recognition given to the importance of land use planning if modal shift is to take place. However, we believe its importance should be mentioned in the summary so that the objectives of LFP 6 can be realised.  LFP 6 mentioned planning changes but does not explain why integration of land use planning and transport is so crucial in order to get modal shift.  

 As part of this process we welcome the appointment of a planning specialist to co-ordinate planning issues and provide continuity and cross referencing across different policies such as the London Plan, Land for Transport SPG and Local Development Frameworks LDFs). This liaison is particularly important with the boroughs so that they are given guidance which enables to set the right framework for rail freight in LDFs, SRDFs, LIPS and LTPs.

We also welcome the attention given to setting up a unit to produce annual freight data reports. Aggregate rail freight data has been minimal which inhibits modal shift.

P21 2.1.1 Mode

It should be noted that in addition to the potential to utilize spare rail capacity

Additional capacity will be needed to fulfill the aims of LFP6  

P23. Road accidents figures are given for 2003. Rail accident figures should also be included for 2003. There were no passenger deaths on the railways, excluding suicides and trespassers, for the same period.

P24 Emissions

There is no comparison of the actual emissions differences between the modes only reference to the benefits of sustainable modes. Given that there is such a stark difference between the emissions from rail versus road and air, we believe that a chart should be inserted. (Freight on Rail gave this data during previous consultations)

To protect the environment

Rail freight makes a vital contribution to protecting the environment and helping the Government to meet its commitments to improving air quality and tackling climate change. Overall rail produces less than one per cent of the total U.K. emissions of carbon dioxide, the principle greenhouse gas, compared with 21 per cent from road transporti.

Tonne for tonne rail freight produces 90 per cent less carbon dioxide than road transportii

Freight Transport: Average emissions in grams per tonne-kilometreiii

Mode	PM10	CO	NOx	CO2	VOC
Rail	0.004	0.032	0.31	15	0.021
HGV	0.048	0.33	1.74	180	0.15

Key: PM10 particulate matter of less than 10 microns; CO carbon monoxide; NOx oxides of nitrogen; CO2 Carbon dioxide; VOC volatile organic compounds. 

Congestion benefits of rail not explained in sufficient detail

An average aggregates train can remove 120 HGVs from our roads – Network Rail 2005

An average intermodal freight train can remove 80 HGVs from our roads – Freightliner 2005

Rail freight, acting as a freight by-pass, can reduce road congestion which according to the UK Government is set to grow by up to 37 per cent by 2010.

To offer an alternative to other issues facing road transport

• Road congestion is causing extended and less predictable journey times.
• Existing driver vacancies 47,000 with the average HGV driver age now 55.
• Working Time Directive is estimated to require another 30,000 and to cost the road freight industry an extra £1 billion per annum.

P22 using Bus lanes for HGVs

Support your comments that HGVs using bus lanes could be dangerous for cyclists as the following statistics indicate -

Pedal cyclists were involved in 367 accidents involving 1 HGV, of which 101 were killed or seriously injured.

There is also the issue of effect it would have on bus operations which could make people go back to using cars.

This could also give road freight an unfair advantage over rail which could lead to more freight using the roads with all the resulting external costs to society.

However your reservations about using bus lanes for HGVs is not reflected in the actual policy. On P25 under Actions needed item 3 and on P51 under task one implies that it would be considered on a case-by-case basis. The views expressed on P22 state doing this on a case by case basis would be complicated for all road users.

We believe that thorough research would need to be undertaken to evaluate whether vulnerable road users’ safety could be safeguarded if HGVs were allowed to use bus lanes. Existing statistics indicate that it would be dangerous for cyclists.

Bikes work well with buses because they have a similar average speed in town, and when a bike needs to pass a stopped bus or vice verse there is not a major requirement for more road space.  Bikes can always get around or clear if the space is in short supply.  On the M4 the exclusive bus lanes actually speeded up the journey times for cars as well as buses, because the 2 types of traffic were segregated.  

P25

Action needed

We support the item Develop inter-modal transfer opportunities to other forms of transport to reduce congestion and greenhouse gas emissions.

We believe this should be a high priority

Please also add in the reduction of other emissions and also reduction in road accidents. See statistics below which illustrate the safety benefits of rail over road.

Road Statistics

There were 12,516 accidents involving HGVs where injuries were sustained, of which 472 were fatal and 2,142 serious injuries.

In 2004 2,883 HGV drivers and passengers were injured, of which 453 were killed or seriously injured.

HGVs were involved in 12,516 accidents where injuries were sustained of which 472 were fatalities.

People are almost twice as likely to be killed in accidents involving lorries than cars per kilometer traveled 2004.

Source Road Casualties Great Britain for 2004 issued September 2005

Rail Statistics

Rail safety – 5 passengers died during 2004 Health and Safety Executive (rail figure excludes trespassers and suicides)
 
Page 26 21.1.2 Rail freight challenges

Reference to working with FQPs in paragraph 3

Freight on Rail welcomes the work TfL is doing to provide guidance on rail issues to boroughs, particularly important because of the lack of a rail agency.

We would therefore ask that the RWP and the Planning working group work closely with the rail freight industry. In particular that the Planning function within the Freight Group liaises with Freight on Rail to ensure that opportunities for modal shift are maximised and the boroughs understand what a crucial role they have in planning and protecting rail lands to achieve this shift. There are certain boroughs where there are potential rail freight flows and scope for interchanges while other boroughs may not be suitable.

P27 - It should be noted that the Felixstowe to Nuneaton cross country route will be needed for increased volumes from the Haven Ports and cannot be expected to reduce the Haven Ports existing rail freight traffic via London.

We welcome the recognition of the importance of capacity and capability upgrades to the Tottenham & Hampstead route which is important to take pressure off Stratford, the North London Line and Forest Gate, as well as its strategic importance as a freight diversionary route.

2.1.2.5 Construction freight challenges

Rail freight has an important role to play in distributing construction materials and already moves a fifth of this UK market with over seven million tonnes of aggregates coming into London by rail each year.

Therefore higher priority should be given to making construction consolidation centres rail connected.

Because of the longer lead times to organize transport by rail higher priority to initial planning should be given for a range of construction products, in particular 2012 Olympics, Thames Gateway and Crossrail.  It is vital that the boroughs are guided to use rail as a preference to road, otherwise the opportunities to use rail could be lost.

2.1.2.6 Waste challenges

Rail is well placed to remove recycled waste in addition to the municipal waste it currently removes for both the West & East London Waste Authorities. Rail also has an important role in removing industrial waste.

2.2 Freight challenges Supporting freight activities

2.2.1 Communications information and organisation

Freight on Rail welcomes the work being carried out by the Freight unit to improve communications between TfL, local authorities and the freight industry. We are pleased to take part in the writing of the Rail Freight Strategy.

Because of the nature of rail freight, projects require access to industry expertise so the members of Freight on Rail are pleased to offer expert advice, as applicable.

Therefore under actions needed on P36

Stronger action needed to achieve modal shift from road.

As part of this process we welcome the appointment of planning specialist to co-ordinate planning issues and provide continuity and cross referencing across different policies such as the London Plan, Land for Transport SPG and Local Development Frameworks (LDFs). This liaison is particularly important with reference to the boroughs so that they can set the right framework for rail freight in LDFs. We believe that planners need a detailed reference document to consult so they are aware of current transport and land use planning policies

These lines of communication are all the more important since the abolition of the SRA, there is no rail agency now. DfT Rail has an emerging role in rail freight;  Boroughs should consult Network Rail, The Rail Freight Group and Freight on Rail on suitability of sites

Situation is much clearer with road

• Highways Agency can give evidence at Public Inquiries
• Highways Agency has formal status in the planning system
• It has article 14 directions - which means it can put a stop on developments beside trunk routes and demand traffic assessments and ultimately reject applications

While we fully support conventional FQPs, their relevance is greater for road freight. We would however support the importance of FQPs, for example in the form of the RWP, which is crucial if more freight is to be shifted to rail.

Freight on Rail is pleased to take part in the implementation of the borough toolkit and training programmes for the boroughs. It has already run 10 events for local and regional authorities, jointly with the English regions and Wales Assembly Government with a second event scheduled in the West Midlands for 15th September.

2.2.2 The role of planning

As stated above we are pleased to see the recognition of the role planning has in improving freight distribution and in achieving modal shift.
 
There is, however, no mention of PPG13 which states that rail lands can be protected if identified in Local Development Frameworks by local authorities even where there is no potential rail use envisaged. The important issue is that once the rail land is gone it is lost as part of the railways and to society for ever. And 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. There are examples of strategic rail and water freight sites, redeveloped for housing, which should have been reinstated for transport use. 

PPG13 states that transport lands can be protected even where there is no identified transport usage as long as it is identified in the Local Plan as railway lands.  PPG13 clearly indicated that even where there was not a reasonable chance of future use of an old transport link, unnecessary severance was still to be avoided. See precedent set by Mansard County Homes LTD v Surrey Heath Borough Council 2002

There is huge competition for development of brown field sites, encouraged by Planning Policy Guidance note 3 which gives priority for housing on brown field sites. This makes a strategic lead by TfL all the more important if suitable sites for freight terminals and railheads are to be retained.

Central and Regional Government should promote partnerships between the rail industry and other interests, such as councils, developers, employers, tourism bodies and development agencies, to improve the railway locally. Local authorities in particular have an important role in brokering partnerships of this nature, alongside Network Rail to implement new rail schemes.

3.1 Delivery Plan

LFP1 Support the development of sub-regional Freight Quality Partnerships and improved means of communication

In addition to roadshows, there should also be rail shows to update and educate local authorities on:-

• Crucial role authorities have in setting the planning framework for rail freight in LDFs, SRDFs.
• ail freight developments and opportunities

As far as communicating with the boroughs it is important to stress that the rail freight industry is committed to advising boroughs on the viability of projects and acting as experts. As mentioned above, boroughs need to be made aware of their roles in setting the framework for modal shift.

LFP3 Training

It is important that there are training programmes to advise the boroughs on how to help the modal shift to rail.

LFP6 Promoting sustainable distribution

We support this policy. However TfL needs to identify the task of working with Network Rail and the industry to identify ways to upgrade the rail network.

P65 Appendix B Assessment of proposals

LFP6

All three high level aims, that is economy, the environmental and social contributions of modal change are given far too low a qualitative assessment, given the importance of reducing congestion, combating climate change and quality of life issues, identified by the Mayor in his proposed revisions of the London Plan.

LFP 6 should have 3 blue chevrons for all seven columns covering economy, environment and social.

Finally Freight on Rail’s contribution to the LSDP and the Freight Plan was missed off in error so I would appreciate this being rectified as we have taken an active part in the process from day one.

 
Philippa Edmunds Freight on Rail Campaigner August 2006
Telephone: 020 8241 9982
Email:Philippa@freightonrail.org.uk                 
Correspondence please to
4 Beresford Avenue East Twickenham Middx TW1 2PY

i. The Railway Forum 2005
ii. AEA Technology for Strategic Rail Authority, October 2004
iii. SRA February 2005