Draft London Plan

Freight on Rail welcomes the opportunity to comment upon the draft London Plan:

The members are as follows:-

Rail Freight Group, EWS, Freightliner, Railtrack, RMT, ASLEF, TSSA and Transport 2000

The format of our response is a definition of Freight on Rail, followed by an introduction on rail freight in London and its benefits Pages 1& 2 and then specific answers by GLA Plan Section. Pages 3-5
 

Definition of Freight on Rail

Rail freight traffic has grown 50% since 1994, and now commands 12 per cent of the surface freight market in the UK. The GLA Plan recommendations will play an important part in whether the Government’s ten-year Transport Plan target of 80% growth throughout the UK in the period 2000 – 2010 will be realised. Without this growth the government will not reach its congestion or pollution reduction targets.
 

What Rail freight currently does in Greater London

• One quarter of all non-bulk freight moves to/from London
  
• A further quarter moves in or out of SE Region
  
• 7m tonnes aggregates to London by rail
  
• ½ million tonnes of waste removed
  
• 40,000 containers to/from Port of Tilbury
  
• 1½ million tonnes of goods to/from the Channel Tunnel for London
  
• 42 mail trains nightly from Princess Royal Distribution Centre
  
  

The use of rail relieves the road network of thousands of lorry movements per day, thus easing road congestion and the pollution and intrusion it causes. This activity can expand in the future with a combination of the right policy framework and industry commitment. The Strategic Rail Authority identifies substantial growth potential for rail freight in London, which Freight on Rail strongly supports. Freight on Rail would like to stress how important the provision of four freight interchanges in the London area will be in enabling the shift from road to rail. There is a huge shortage of suitable available sites in London. The site at Cricklewood, currently under negotiation for redevelopment, is one such site. The strategic nature of this site in terms of rail freight and waste provision cannot be underestimated.
 

Statistics showing the benefits of rail freight

• Research shows that rail freight’s external costs, ie excluding congestion are eight time less per tonne kilometre than air freight and four times less than road. International Railway Union (UIC) 2000
  
  
• Nearly 40% of CO2 emissions from road transport came from buses and lorries though only representing 12% of vehicles on the road, (of which buses would represent about 3%). Motorists' Forum 2000
  
  
• Compared with the equivalent journey by road, freight by rail produces: one seventh of the carbon monoxide: one quarter of the nitrous oxide: one fifth of the particulates: half of the carbon dioxide.
  
  
• An average freight train can remove 60 HGVs journeys from our roads
  
  
• Although accounting for only 6% of vehicle kilometres travelled, lorries are responsible for 18% of road deaths. In 1999 HGVs caused 617 out of 3423 fatalities. Road Accidents GB
  
  
• HGV’s are up to eight times more dangerous than cars in terms of fatalities per mile travelled. T2000 research 1995

 
Rail freight can play an important part in implementing many of the GLA policies listed below:-

• Greater use of sustainable modes such as rail to move London’s freight
  
  
• Safeguarding of sites for railheads so that existing and new rail freight can reach its customers
  
  
• building “strategic” freight transfer complexes on London’s periphery and of smaller facilities within Greater London
  
  
• Greater use of rail-served docks and wharfage
  
  
• Providing rail-served transfer stations to handle London’s waste
  
  
• Providing railheads to supply materials for London’s construction industry
  
  
• Establishing a partnership between the GLA, TfL and stake-holding organisations
  
  
• Close co-ordination between the GLA, TfL and the Strategic Rail Authority
  
  
• Addressing the special considerations of night-time freight movements
  
  
• Minimising the impact on the community made by the movement of waste
  
  

There is also the potential for some of London’s mainline terminal stations to serve as railheads during the night so that goods can be moved with minimal intrusion to the very heart of the city.
 

Comments on sections
 
Section 1

1b14 London is a world transport hub

While Freight on Rail supports the aspiration to divert non London bound freight away from the capital it does not believe that this aim is realistic in the time scales of the London Plan in view of other more pressing major infrastructure demands on the UK network. The SRA has set out its priorities in its Strategic Plan January 2002 and there is no mention of a south to west freight bypass. Huge rail investment and political will to push through alternative routes would be necessary to enable rail freight to be diverted, making it currently unrealistic.

In the meantime, freight can not afford to loose rail paths on the network through London otherwise more freight will be forced back on the congested road network.

Freight on Rail notes that the planned enhancements between Felixstowe and Nuneaton which are part of the SRA Strategic Plan will enable some intermodal rail freight to avoid London but this will have limited impact on the tonnage which still needs to traverse London.
 

2B10 & 2 B 101

Opportunity areas in North London
Cricklewood is not former railway land, it is existing railway land with an operational rail freight terminal and a waste disposal plant which uses rail freight. Cricklewood is an important regeneration area and retention of the right type of rail freight terminal/interchange is key to the GLA being able to meet its stated aim to use more sustainable distribution methods. It is a strategic site and one of very few left available for such purposed. Freight on Rail notes that Barnet has one of the highest population growths in the area which will mean pressure for housing but also the means to service the population with goods and facilities.
 

3C11 Land Retention Problems

Freight on Rail is supportive of the guidelines in this section which highlight the need to protect land for transport purposes and freight handling and would emphasis how few suitable sites are available. This is in line with PPG13. This issue should be addressed by the Supplementary Planning Guidance on land for transport functions.
 

3C4 Reducing congestion

While Freight on Rail supports the aspiration to divert non London freight away from the capital as stated in 1B14 we must stress, as mentioned before, that huge investment in infrastructure and political will to push through alternative routes would be necessary to enable rail freight to be diverted. However, in the meantime, freight can not afford to loose rail paths on the network through London otherwise more freight will be forced back on the congested road network.

Freight on Rail notes that the planned enhancements between Felixstowe and Nuneaton which are part of the SRA Strategic Plan will enable some intermodal rail freight to avoid London but this will have limited impact on the tonnage which still needs to traverse London. The most crucial routes for rail freight are the West London Line and the North London lines. In the case of the latter, there are practical measures that can be undertaken to improve the capacity constraints and conflicts between the aspirations of passenger and freight services. However, in the case of the West London line rail freight cannot relinquish any existing paths otherwise freight will be forced back onto the congested road network. The plans for increased passenger services on this line could cause conflict with the requirements of rail freight which already avoids the peak hours.

A possible alternative would be to encourage the development of light-rail schemes to deal with some of the increasing passenger demand.
 

3C5

Improving freight movements and the distribution of goods and services

Freight on Rail fully supports the GLA’s plan to promote sustainable development of rail, road and waterborne freight facilities in London. However, as previously stated in 1B14 and 3C4 while it supports the aspiration of diverting non London freight away from the capital, does not believe this aim is realistic in terms of the timescales of the London Plan for the following reasons:-

1. the infrastructure costs would be huge and are currently not viewed as a priority given all the other enhancement requirements on the UK network.
   
   
2. There is no mention of this work in the SRA Strategic plan.
   Freight on Rail would like to stress that that the long term goal of diversionary routes away from London should not be used as a reason/justification for converting existing freight paths to passenger ones in the meantime, because that would go against the GLA aim of promoting more
   sustainable freight movements. Any reduction in freight paths would mean thousands more lorries on the already congested road network and the resulting social health and environmental consequences.

We believe that the role of councils through UDPs is crucial in promoting rail freight as these documents form the framework upon which the shift to rail freight can be justified. Without defined policies in UDPs so that planning permissions can be given in favour of rail freight proposals it is difficult for existing and potential rail freight interests to be protected given adverse commercial pressures for land usage. The revised PPG13 has been instrumental in protecting railway lands from non railway use. This was shown in the recent case Mansard County Homes v Surrey Heath Council, where the council was able to protect railway land for future potential railway use, although none was identified in the foreseeable future, because this policy was laid down in the LTP. We view this case as an important precedent.

The GLA must be ready and willing to intervene in the planning process whenever London boroughs fail to abide by this policy.
 

3C55 Need for rail freight terminals

Rail freight cannot increase without the provision of more freight interchanges in the London area, as outlined in the SRA Strategic Plan. Freight on Rail supports the SRA’s plan for 3-4 large multi-modal freight facilities on the periphery of London and the SRA’s comments that a number of smaller facilities within the urban area will be required.
Cricklewood is an important regeneration area and retention of a suitable rail freight terminal/interchange which allows for bulk and aggregates traffic with sufficient warehousing, is a key facility needed to support the GLA aim to use more sustainable distribution. It has strategic importance and is one of the few remaining suitable sites in Greater London
 

3C57,58 The role of the Ports

Freight on Rail endorses the Mayor’s view that the PLA’s facilities are a “vital gateway for London” and that the development of the Thames Gateway “should be maximised”. Shipment freight represents a major market for rail. Development continues and new rail facilities have opened recently or will soon do so at Tilbury and Chatham, with further prospects for rail access to the Northfleet area. Between them, these sites generate large volumes of rail traffic must inevitably be routed via the London area. If this is not to lead to substantial additional road congestion then rail must be used to move as much of the shipment freight as possible.
 

3C58 Supplementary Planning Guidance on planning freight facilities in London will be important in identifying the policies on suitable sites, which are in short supply in the London area.
 

4A Waste

Freight on Rail supports the aim of increasing waste removal by rail and water and the protection of waste disposal sites using rail. It would like to highlight the importance of the existing waste disposal site at Cricklewood and stress that the redevelopment plans should retain this rail connected facility with proper road access.

Rail moves over 900,000 tonnes of London’s domestic waste per year. In addition EWS is currently moving some 1.4 million tonnes of spoil from the Channel Tunnel Rail Link construction site at Kings Cross – up to 11 trains a week are operating, each carrying 1,300 tonnes of waste material, equivalent to 50 44-tonne lorryloads. As with other bulk materials, direct rail access to the customers’ sites – waste transfer and compaction centres in the case of domestic waste – is vital. Such sites are very scarce in Greater London and that their availability is a key factor in determining whether or not rail will be able to move more of London’s waste in future. This issue should be addressed by the Supplementary Planning Guidance on land for transport functions.
 

4A5 Spatial policies to support the better use of aggregates

Freight on Rail supports the policy to safeguard existing railhead capacity to handle and process aggregates and minimise the movement of aggregates by road
Nearly 3.4 million tonnes of construction materials (crushed rock, marine-dredged aggregate, sand, building blocks and cement) are moved by rail into London. As with waste, suitable railheads are vital for this process to continue and to expand: The rail freight industry is continually searching for additional sites to meet new enquiries for business from the construction industry. The growing use of secondary materials has done nothing to reduce the pressure for more sites since rail can move these too. Freight on Rail is currently working with partners in the rail freight industry to ensure that an aggregates railhead can be established on railway land at Cricklewood
 

4a29 Noise

Road versus rail noise pollution
You mentioned that noise from rail freight was a substantial consideration. We ask that rail freight is not penalised but should be treated fairly with road transport. A substantial volume of research shows that noise from trains is not regarded as being as intrusive as road noise. The research showed that intermittent noise, characteristic of rail transport is less annoying, at a given level of decibels than the continuous noise from road traffic. Engineering and maintenance work at night is often responsible for night noise, for which freight should not take the blame. We also believe that it would be helpful if the Government gave the industry incentives to replace older noisier rolling stock and infrastructure.
 

Section 5.1 Working in partnership

Freight on Rail would like to thank the GLA for its partnership approach through the LSDP and is keen to take an active part in this partnership with GLA TfL and SRA and other parties as an important tool to make improve freight distribution in Greater London more sustainable.