Mayor’s Transport Strategy
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. Freight on Rail Definition
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.
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 to central, regional and local government.
Summary
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
a) by providing the right planning framework which enables planning permission to be gained for terminals
b) Supportive policies and funding for rail enhancements give industry the confidence to invest in rail freight long term.
c) capital and revenue grants show commitment to rail and enable business to offset some of the initial start up costs of the shift to rail.
d) SPG for rail in addition to water freight.
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.
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 and infrastructure 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 society1. 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.
We 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 and should therefore be retained and promoted as such.
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.
Question 1 of GLA consultation
We agree that it is crucial to integrate land use planning and transport policies in order to reduce the adverse impacts of transport in environmental, social and economic terms.
We believe that clear guidance is needed from the GLA to the boroughs in the Transport Strategy if the London boroughs are to achieve the best sub regional and local outcomes for Londoners in terms of low emissions, improved quality of life and success economy.
Regional policies in the form of the London Plan and the Transport Strategy have statutory status and given crucial direction to planning and transport planning decisions. The GLA has the ability to provide the regional perspective which local authorities cannot meet. For example in planning decisions about rail freight terminals, local councilors cannot take the wider regional and sub regional benefits of a rail freight terminal into account, unless the Transport Strategy states clearly its support because normally there are local disbenefits such as increase HGV traffic movements.
Given the need to reduce the capital’s carbon dioxide emissions and recognition that rail provides a low carbon, safer energy-efficient alternative to road freight which reduce road congestion, Freight on Rail believes that policies and support for modal shift should be given a greater emphasis in
the transport
Strategy. Ref P11 Tackling climate change, P15 2.2 Providing a better quality of life for all Londoners/P18 2.5 Tackling climate change
P14 Delivering an efficient and effective transport system
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 roads2”
P19 2.6 Delivering the London 2012 Olympic and Paralympic Games
Rail should play a greater role in delivering construction materials to the Games and removing waste and spoil. However, for these opportunities and the inherent benefits for society to be fully realized, consultants who understand rail need to be employed to set up the right consolidation centres.
Question 2
P23 Internationally
Rail freight can offer a high speed low emission alternative to both rail and air freight for high speed mail and parcels services via the Channel Tunnel rail link to the capital as long as access off the HS1 into a terminal at Barking with European gauge capability is forthcoming. As mentioned in section 66 P23
P24
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 over 3 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 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. This rail freight traffic does not appear to be mentioned in this section of the strategy in the figure 3 diagram on P25. In fact demand for this route will increase when the Thames Gateway comes on stream in 2011.
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. Extra capacity will be needed for freight traffic when Crossrail comes on stream.
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.
Suppressed demand for rail freight because of current limitations of rail network
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.
If the rail network were enhanced significant amounts of freight could be transferred to rail. New RFG/FTA demand forecasts show a 30% increase in tonne km from 2006 to 2015 and more than doubling by 2030. However the growth in intermodal traffic is forecast to be very much higher; more than doubling by 2015 and a fivefold increase by 2030.
Industry endorsements
As an industry we need all the rail freight we can get
MD Maersk Sealand
“Having a rail alternative is more economic, cuts delivery times and is more reliable”- Arthur Koutstall ECS European containers
P26
London-wide
We believe it is important that the Transport Strategy clearly states that there is a need for interchanges/terminals
We believe that there is a need for right regional planning framework through the London Plan which gives strategic direction to local authorities, without which it would be difficult to get planning permission for rail freight terminals, an essential element if freight is to be shifted from road to rail.
Difficulty of getting planning permission for terminals/interchanges unless the new London Plan explicitly supports the shift to rail and has a stated policy of an approximate number of how many large SRFIs are needed and how more small to medium sized terminals are needed as previously stated in the London Plan. London Plan specified that 3-4 SRFIs were needed in the Greater London area. In the interim Howbury Park has been given planning permission so likely that around 3 additional SRFIs are needed with an additional 18 small to medium sized terminals needed also in the Greater London area.
Without this overarching London policy it is difficult for boroughs and Public Inquiries to give planning permission for terminals where there is local opposition and local disbenefits such as increased lorry movements.
Under the terms of the new Planning Act, strategic interchanges of 60 hectares and over will be evaluated by the Independent Planning Commission where the need for such terminals will already have to have made through regional spatial and transport strategies including a New London Plan and the National Policy Statements.
The London Plan needs to give direction to the local authorities so that a wider national, regional and sub regional perspective can be taken on transport planning. Therefore we support the aim of A new London Plan to integrate land use planning and transport planning.
We agree that Howbury Park is an important interchange for the SE of London and look forward to its development.
Another key location for an interchange is Cricklewood so we appreciate the support of TfL in securing the best possible new rail freight facility and waste transfer station at this location as part of the redevelopment of the Cricklewood lands. Prior to the period of blight, there have been significant rail freight facilities at Cricklewood which offers the only strategic site for rail freight in that part of north London and must therefore be protected and build as defined by the Barnet UDP. This project is an example of how crucial GLA/TfL role is in directing local authorities to safeguard sites for rail freight and promote the building of rail freight facilities.
P38
Figure 10
Rail freight can help improve access to commercial markets for freight movements
This will necessitate enhancements to the rail freight network as mentioned.
Also has an important role in quality of life, safety and climate change issues by reducing CO2 emissions and being a safe form of transport as well as the road congestion relief of rail freight.
Question 3
In order to achieve consistent outcomes across boroughs it is crucial that the GLA gives strong direction to the boroughs on the need to reduce carbon emissions from freight transport, give strong support for modal shift to rail freight stating its environmental social and economic benefits. Without this direction it is difficult for boroughs to justify investigating rail freight opportunities in their borough and the sub region.
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.
Question 4 Transport Interventions needed to support economic growth
Crossrail
P40
We support the Crossrail project and ask TfL to ensure that rail freight services and capacity are not adversely affected by Crossrail services on either the Great Western or Great Eastern lines.
Improving TfL Rail and National Rail p41 & P42
Section 117
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.These upgrades are crucial for cross London rail freight coming from Tilbury, Thames Gateway and the Haven Ports to cater for existing and future demand once Thames Gateway is opened.
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
Section 119 P42
Enhancements to freight gauge and capacity on the Felixstowe to Peterborough route for cross country rail freight are crucial to cater for the demand out of the Haven ports. The gauge work and some capacity work is part of the Strategic Rail Freight Network commitments, however the route needs considerable additional capacity enhancements which are so far not funded as part of SFN in CP4. Therefore GLA support and contributions towards the additional capacity work would mean that more rail freight could go direct to Nuneaton avoiding the need to go via London which would free up capacity for rail freight from Tilbury and Thames Gateway.
P47 139 Rail freight
We fully support the Howbury Park interchange and Cricklewood rail freight facilities. However as previously mentioned, we believe that it is crucial that the GLA continues to states in its Transport Strategy an approximate number of how many large SRFIs are needed and how more small to medium sized terminals are needed as previously stated in the London Plan. The Previous London Plan specified that 3-4 SRFIs were needed in the Greater London area. In the interim Howbury Park has been given planning permission so likely that around 3 additional SRFIs are needed with an additional 18 small to medium sized terminals needed also in the Greater London area.
It is impossible to shift freight to rail without terminals and unless there is supportive GLA policy in the Transport Strategy and London Plan, it is difficult for terminals to be justified and planning permission obtained.
A terminal is needed to cater for European high gauge rail freight from HS1 in the Dagenham/Barking area.
Continuation of this high gauge link with electrification across London as far as Acton is needed so that european traffic could access the following mainlines the MML, WCML,GMML, ECML, GEML when decisions are made about electrification of routes.
It is also important to note that any plans for High Speed2 HS2 should ensure that HS1 is linked to HS2 with a european gauge electrified route.
We support plans to electrify the Gospel Oak to Barking line.
P48 Improving traffic flow
Rail can act as a freight by-pass see full details on economic case for rail freight Question 6 below
Question 5
Land use
Need for safeguarding policies for rail freight sites and lines in London Plan and Transport Strategy– see your question 3 our page 6 on need for land use planning frameworks and strategies
Question 6
We believe that GLA should give modal shift to rail a stronger emphasis and list it as one of its policy objectives as it contributes to all the identified objectives a) to e) in this question.
Benefits of rail freight
Economic
Rail freight can help regenerate areas and provide work
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”
P51 Air quality
Rail freight can improve air quality and CO2 emissions P53 Tackling climate change
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 emissions4
Tonne for tonne moved, rail produces at least three and half times less carbon dioxide5 than road freight.
P52 Road Safety
Rail is a safe mode of freight distribution, therefore a shift to rail can reduce exposure to road accidents.
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 three times as likely to be involved in fatal accidents as cars in 2007 –DfT Transport Statistics Traffic Speeds Figure 3.5C for 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
Philippa Edmunds
Freight on Rail Campaigner July 10th 2009
1. Source Heavy Lorries do they pay for the damage they cause by MTRU and peer reviewed by Institute for Transport Studies Leeds April 2008
2. Network Rail 2009
3. Network Rail 2009
4. Carbon Pathways DfT 2008
5. DfT Logistics Perspective Dec 2008 P8 rail produces 0.05kg per tonne, road 0.17kg per tonne
