Freight on Rail Response to The Draft Planning Policy PPS12

15th January 2004

Freight on Rail welcomes the opportunity to comment on The Draft Planning Policy PPS12

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

Definition of Freight on Rail

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, i.e. excluding congestion are eight time less per tonne kilometre than air freight and four times less than road.

Planning Policy statement 12 Local Development Frameworks

Local Development strategies should enable local plans to be translated into detailed and robust assessments of existing local infrastructure and services and strategies for local action to achieve rail freight growth, modal shift and environmental benefits.

This is the basic planning building block and it is important that transport developments are not obstructed or even fail due to decisions taken by Local Development documents. e.g. land allocations which would preclude the development of a rail freight interchange.

Chapter 2
Plan content and level of detail
Page 15

It is vital to promote, protect and set the agenda and framework for rail-freight through Local Development frameworks if rail freight is to prosper. In order to achieve this objective the following criteria should be followed:-

Make sure that local planning and transport plans evaluate rail freight thoroughly.
Identify and protect sites, lines and sidings with existing or possible future rail potential, taking into account the strengthening of PPG13 which allows Councils to protect disused railway land for potential use even if that use is not currently identified. The ability to protect land in local development framework is key to promotion of rail freight as illustrated in the judgement in the case of Mansard County Homes Ltd v Surrey Heath Council which showed councils countrywide that they could protect disused railway land for future potential railway use, without fear of litigation, even where there is no immediate evidence of future possible use. This judgement means that councils can safeguard railway sites, routes and railway infrastructure and stop them being lost to the nation forever. It is worth emphasising that once sites are gone, they are gone for ever - e.g. various avoiding lines lost to station car parks.
Make links with Local Transport Plans so that major freight flows are recorded and targets such as lorry journeys to be saved are set.
Set targets such as scale of & growth in rail’s share in local freight market to measure progress.
Promote new terminals & upgrade existing ones with good road and rail access and allocate suitable locations in the local plan.
Rail freight interchanges do not necessarily need to take up large areas of land. There is a misconception that interchanges need large areas of land which is not always true.
Plan new industrial developments to be accessible by rail
Identify and define suitable locations in the local plan
Improve the integration of the road network with major transport interchanges so as to promote greater use of rail network
Make sure that opportunities for greater use of rail freight are being taken into account in land use planning decisions.
Monitor and aim to reduce the road freight transport intensity of economic growth
Disseminate information across business promoting rail freight benefits to business
Develop personal contacts and talk to the experts
Organise events which bring together rail operators, key councillors, trades union members and local environmental groups and potential customers

Understand local factors

Do not underestimate the importance of this element, which, if wrongly handled, can kill a project
Consult & understand local opposition and promote the wider environmental benefits
Choose the right location and size, use green vehicles, sustainable building design and landscaping.

Avoidance of Blight

Page 16 2.28 Given the nature of transport infrastructure projects we do not believe that it is possible that major proposals can always realistically be implemented during the plan period as the correct timescale for major transport infrastructure plans can be as long as 30-40 years.

2.29 It is vital that suitable sites, lines and sidings remain protected even though no foreseeable rail associated use may be apparent at the time and that this is laid down in the local plan.

Page 19 para 2.5.1
A key area that will be influenced by regional strategies. There is potential for the use of "limited suite of policies" to marginalise transport policies in influencing development and use of land and buildings.
Page 20 para 3.1.1
There is a need for transport pressure groups to be involved at community level. We suggest that a series of short briefing papers would assist in this process.

Page 25 para 4.2.1
There will be a need to challenge assumptions on transport systems including current negativity due to short-term funding constraints on any new developments. Need to stress potential of rail routes and sites e.g.

will current pressure on reductions on disposal of domestic waste as landfill not require more efficient transport systems to more efficient regional recycling facilities?
will the UK need to protect mineral sites for the long term e.g. for cement manufacture if multi-national companies corner the market and force up prices?

Page 26 para 4.3.4
It is crucial that links are established between RSSs and development plans. PPG11 provided a firm base for regional planning including transport strategies but every region needs to produce an RSS that takes a positive view on the role of rail supported by the SRA.

Page 27 para 4.4.2
It is critical that representations on rail routes and sites are fully recorded.

Page 33 Transferring to the new system
There will be a need to ensure that nothing is lost at this stage. Adopted structure, local and unitary development plans will become "saved" plans for three years. Particular care is needed with UDPs where the protection of transport corridors is less well defined than in SPs and LPs.

Page 36 para 1.1.7
A reference to transport, and rail in particular, should be included in the Core Strategy. Again important to ensure that specific sites are identified for rail use.

Page 37 para 2.1.2
Specific map locations are one of the most difficult areas for future rail freight facilities. Questions arise about area, site access, warehousing and environmental concerns/issues that could be used to challenge any development. But suggest link with para 2.1.3 and the need to safeguard areas.

Page 40 para 1.1
Again that key reference to community strategies. Councillors need to be mindful of the wider social, economic and environmental benefits of rail freight facilities so that local opposition can be contained.(see para 1.1.2 v)

Page 41 para 3.1.2
There is a need for an emphasis on the plan needing to "look forward over a reasonable length of time" and to take into account future growth or road traffic and the resulting congestion implications.

Page 42 5.1 Integration of transport and land-use policies
The expertise in transport and planning from county councils must be retained if integration between transport and planning is to be maintained.

Page 42 para 5.1.5
Again need to avoid being deflected by timescale and also emphasis on importance of LTPs in setting priorities.

Page 45 Consultees
Transport pressure groups, such as ourselves, do not appear on the list