Response to Consultation on Draft Planning Policy PPS11

January 14th 2004
 

Freight on Rail welcomes the opportunity to comment on the Draft Planning Policy PPS11

The format of our response is a short introduction on Freight on Rail , its membership, recent statistics on rail freight and then responses to specific questions

Freight on Rail, a partnership between transport trades unions, freight operating companies, the Rail Freight Group and Transport 2000 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.

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

Background to rail freight

Rail freight traffic has grown 51% since 1994, and now commands 12 per cent of the surface freight market in the UK. Freight on Rail supports the Government’s ten-year Transport Plan target of 80% growth in rail freight throughout the UK in the period 2000 – 2010 and believes without this growth, the government will not reach its congestion or pollution reduction targets, nor comply with EU air pollution regulations.

The simple statistic showing that an average freight train can remove 50 HGVs from our roads clearly and simply illustrated what rail freight contributes to our economy and society.

The use of rail relieves the road network of thousands of lorry movements per day, thus easing road congestion. As well as the economic benefits of rail freight derived from road congestion amelioration, there are significant environmental and social advantages. Society has to shoulder the external costs of road and air transportation. International Railway Union (UIC) 2000 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.
 

Introduction

Freight on Rail fully supports the objective of better integration between transport and spatial planning and the use of Regional Transport Strategies RTS as an important element to achieve this integration.

The significance of RTS cannot be underestimated with the imminent transformation of RPG into Regional Spatial Strategies (RSS’s) which for the first time will have statutory force including presumably the infrastructure proposals they recommend.

Freight on Rail believes regional strategies are key to integrated transport policies which address an individual region’s requirements and at the same time follow national policy. Without national and regional statutory documents it is difficult to pursue transport infrastructure improvements which benefit the wider community because of the local nature of planning decisions and the political implications.

Purpose and scope of a RSS
1.3 Timescales
If the aim of the RTS is to provide long term planning, then the timescales allowed for transport infrastructure from initial planning to implementation need to be far longer than fifteen years. In fact, in many instances indicative regional transport infrastructure planning should operate to a longer horizon than spatial planning.

The Government recognises the validity of long timescales in transport planning in much of its work. UK airports policy and related civil aviation policy is currently prepared in a thirty year timeframe and major Multi-Modal Studies have been developed with an horizon in excess of twenty years.

Therefore we believe 30-40 years is the right timeframe for major transport infrastructure projects

1.5 The RSS should also not be constrained by short-term budgetary limits. It should be a document which identifies what a region’s future transport needs are.

We expect rail costs, currently at a high historical level for a number of reasons, to fall back in response to the pressures being exerted by Government and its agencies so that rail-based initiatives will regain their ability to provide value for money in the long-term.

We also note that RTS will be informed from advice from the SRA in case of rail projects and we are very concerned that the SRA’s Regional Planning Assessments (RPA) may fail to provide this long-term guidance if short-term budgetary limits are imposed. Short-term financial problems hinder strategic planning.

We believe that it is imperative that these documents should provide long-term strategic guidance which is not constrained in scope by short term financial budget limits. We refer to page 8 of the SRA Railway Planning Framework: Regional Planning Assessments – ‘However the SRA will need to ensure that the Core Scenario (their bolds) of each RPA is deliverable and realistic within its funding constraints, which are established by the Ten Year Plan.’ SRA funding is provided on the rolling three year Comprehensive Spending Review cycle. Regional planning looks at least 15 years ahead, longer than the ten year period.

While it needs to address the regional issues in terms of rail freight it must also take into consideration adjoining regions and the national picture - as for example in location of rail freight interchanges. Rail freight services are driven by demand and freight flows will often cross several regions. Regions must look beyond their boundaries and there needs to be a mechanism to assist them in this function.

Freight on Rail agrees that the regions must prioritise transport needs. This involves tough policy and political decisions to decide what the transport investment priorities are. It cannot just be a shopping wish list as this approach discredits the RTS. The lack of regional budgets makes this a real danger.

Rigorous data rather than subjective political bargaining processes should determine regional transport priorities.
 

Sub regions

The sub regional level is also very important and Freight on Rail is concerned that the loss of county councils may make it more difficult to achieve a joined up approach at this level where local authorities work together. The expertise in transport and planning from county councils must be retained if integration between transport and planning is to be maintained.

An RTS should identify its region’s transport priorities, define the specific needs of the region, capture functional relationships which cross local authority boundaries, provide sub regional guidance and stimulate local transport plans especially across boundaries.

Currently one can find conflicting policies in the same conurbation. Unified RTS and sub-regional strategies could resolve this to provide unified policies across local authorities.

Sub-regional strategies should exist where appropriate, e.g. Thames Valley in SE.

There is a need for appropriate definitions of sub regions, which can vary for different purposes ie housing and transport.

As well as national policy informing regional policy it is important that the dialogue works in reverse with regional needs informing national policy. It is important that RTSs are not just bolted onto the national policy.

Annex B

Requirements for preparing RTSs

3. Main Aims of Regional Transport Strategy

We are very concerned that the development of rail (and inland waterways) been dropped from the draft Consultation Report. For example, bullet point two of the Guide reads:
“ A strategic steer on the role and future development of railways, airports, ports and inland waterways in the region, for both passengers and freight, consistent with national policy;”
while the draft Consultation Paper reads:
“ a strategic steer on the future development of airports and ports in the region consistent with national policy;”
We note that the draft RTS now says advice on the promotion of sustainable freight distribution where there is an appropriate regional or sub-regional dimension. These are serious omissions which we urge be rectified.

Identifying investment and management priorities
19. As mentioned above Freight on Rail has serious concerns about the ability to deliver transport infrastructure projects in the RSS timeframe, taking into account the likely level of resource available for transport over this period.

We are aware that the SRA is improving its planning capabilities at regional level, and it is important that there should be clear agreement between the Regions and the SRA on the priorities to be addressed.

It is apparent that there should be agreement on the advice received from the SRA in case of rail projects.
Certain freight funding in the form of private investment is outside the SRA budgets and needs to be taken into account.

We believe that it is imperative that these documents should provide long-term strategic guidance which is not constrained in scope by short term financial budget limits. We refer to page 8 of the SRA document the Railway Planning Framework: Regional Planning Assessments – ‘However the SRA will need to ensure that the Core Scenario (their bolds) of each RPA is deliverable and realistic within its funding constraints, which are established by the Ten Year Plan.’

If high unit costs are brought down as required by the ORR, more projects will become better value and can therefore be implemented.

21. Can be difficult to make the business case for existing facilities.

22. Timescales again

Freight on Rail takes issue with the following … proposals should also only be included if there is a realistic prospect of delivery within the RSS timeframe for reasons explained in 1.5 and 3.19
 

23 Affordability

Finance
We support the approach that the RPB should seek advice from the relevant delivery agency on estimated costs, timeframe and likely value for money of scheme proposals but does not accept that regional objectives should be constrained by financial budget limits. These documents should provide long-term strategic guidance which is not constrained by short term financial budgets.

Budget
Regional bodies do not have a regional budget, funding is either allocated at the national or local level. This makes prioritising projects a problem: without budgetary provision there must be a danger that regional proposals are simply a ‘shopping list’.

Monitoring RTS
DfT monitors RTSs however the LTPs are monitoring by the ODPM to see if they give value for money. What is the mechanism to integrate this?
 

30. Freight

Problem of suitable sites for rail freight interchanges

Without suitably located interchanges rail freight volumes cannot grow. The refusal of planning permission for sites such as LIFE in the South East illustrates the extent of the problem in securing planning permission for rail freight terminals. Availability of suitable sites adjoining railway lines with the necessary capacity and capability is a problem generally through out the UK. However in particular regions, such as the SE, scarcity of sites and land values means that this is an even bigger problem as without suitably located interchanges rail freight volumes cannot grow.

RTSs are vital instruments if the wider public good of rail freight is to be realised. Otherwise planning permission cannot be obtained for projects which have wider social and economic benefits because the local impact overshadows this.