Planning for a Better London

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.

Summary
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.

We believe that the GLA should produce SPG for rail freight in addition to the planned one for water freight given the imperative to reduce greenhouse gase 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. 

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 emissions1

Tonne for tonne moved, rail produces between three to five times less carbon dioxide2 than road freight (depending on cargo).

Rail can act as a freight by-pass
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”  

Rail is a safe mode of freight distribution.

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 twice as likely to be involved in fatal accidents as cars in 2007 – Road Statistics Traffic Speeds  Chart 10 p 115 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

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 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 society4.  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 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.

There is suppressed demand for rail freight
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

The Mayor’s role
Planning Decisions
Freight on Rail believes that the Mayor has a crucial strategic land use planning role which can ensure that the right planning decisions can be made for London and for the wider national benefit.

Through its powers as a regional planning authority it can ensure that sustainable strategic decisions can be made which have regional and national significance by highlighting the wider economic, social and environmental benefits of rail freight.

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.

Safeguarding role of GLA
As well as promoting rail freight, the London Plan also gives guidance to local authorities to protect disused rail alignments and sites suitable for terminals. This is  crucial because once suitable sites by the railway are gone to the industry, they are lost to society for ever. The loss of wharves to residential development has presented similar problems for water freight. There are a very limited number of sites adjoining the railway which have the right characteristics, and access to suitable roads.

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 retained for transport use. It is more difficult to reinstate transport use after a non transport redevelopment.  Given the economic and environmental imperative to reduce greenhouse gas emissions, it is crucial that these mistakes are not made again.

The support of the GLA for rail freight gives direction and guidance to local authorities to enable them to give planning permission for rail freight terminals which are for the wider good but can suffer from local opposition because of local disbenefits such as lorry movements to the rail interchange.

Examples of where old lines have been crucial in enabling new or reopened routes is the East London line and Chelsea to Hackney for the planned Crossrail project.

Role of integrating land use planning and transport policy is critical

Therefore we urge the GLA to maintain these policies to safeguard rail alignments and transport corridors for future possible rail use.
PPG13 allows local authorities to protect sites and alignments for rail even where there is no planned potential rail use as long as there sites are defined in local plans.   

We believe that the London Plan as the spatial strategy has a key role in promoting sustainable distribution.

We also believe that this spatial plan offers an overarching framework for sub regional working and can allow the wider benefits of rail freight to be recognised  where they may be local disbenefits.

We also support the plan for Inter Regional planning forum

We welcome the initiative by the three SE RDAS known as Greater SE which is working on the Thames Gateway project and trust that it will recognise the role rail freight has in servicing this redevelopment by reducing carbon emissions and road congestion. The Northern Way partnership has recognised the role rail freight plays in servicing the economy and regeneration.

Synergy of enhancing rail network for freight and passenger services
For example the enhancements to London Overground, known as the NLL and the Gospel Oak to Barking, will benefit both freight and passenger services.

We welcome the importance given to addressing climate change in the London Plan and highlight the role rail freight can play in alleviating green gas emissions and road congestion.

The mayor’s role
Importance of integrating planning and transport policy
Mayor does add value here, in a way that other regional authorities in England cannot do as they are not elected planning body.

EIP
Retention of rigorous EIP procedures is important as the existing procedures have been able to test the robustness of regional strategies.
Freight on Rail was pleased to take part in the EIP of the London Plan and gave evidence at the inquiry into important policy definition for strategic rail freight terminals.

SPG for Transport has been important in both promoting rail freight and protecting suitable sites for rail freight interchanges.

Development control powers over strategic important applications should be retained and used where necessary.

GLA and TfL also consulted in public inquiries which is important. GLA and TfL gave an important strategic lead at the Howbury Park inquiry which was taken into consideration in the decision to grant planning permission for Howbury Park.

Brownfield land needed for railways as well as housing
There is huge competition for development of brownfield sites, encouraged by Planning Policy Guidance note 3 which gives priority for housing on brownfield sites.  This makes a strategic lead by Government all the more important if suitable sites for freight terminals and railheads are to be retained.

Safeguarding sites for possible future terminals,
The majority of terminals ie medium and small terminals will not covered by Planning Commission which will only look at Strategic Rail Freight interchanges of 60 hectares or more so the role of the GLA is crucial if planning permissions is to be given for more terminals. It was estimated by the SRA and retained as policy by the DfT that the greater London area needed 3-4 SRFIs and an additional  18 medium sized and small terminals needed.

Example of Cricklewood and role GLA has in preserving rail freight facilities there.
Cricklewood is an example of a key rail freight site which needs to be protected for future rail use. It is probably the only available site in North London suitable therefore GLA and TfL have a key role in protecting and promoting the site both in land use planning terms and in business viability terms as without that support. Steps must be taken to ensure that the developer doesn’t just build the highly valuable shops and residential space and somehow overlook the rail freight need. The scheme has to be integrated and no one part should proceed without the whole being certain. However what is key to the viability of the facilities will be the terms of the lease negotiated. There is a danger that unless these sites are preserved exclusively for rail freight use, under equivalent  lease terms as prior to the redevelopment, this national strategic rail freight site could be lost if the developer were able to charge unviable rates to the rail freight operators. The ORR decision of July 2006 stated that existing rail freight facilities should only be released if equivalent or enhanced facilities and terms were provided on a new site. These facilities have huge potential to contribute to key borough and GLA objectives such as clean air, and less intrusion of heavy lorries.
  

We believe that it is important that the Mayor and GLA gives strong direction to the local authorities to protect and safeguard suitable rail freight sites and alignments and also gives direction to local authorities to reduce carbon emissions. Without direction from the GLA it can be difficult for councillors to support rail freight facilities which have regional and national benefits but encounter local opposition due to local disbenefits.

We support the London Rail Freight Strategy August 2007 which is a daughter document of the Freight Plan and urge the GLA to retain the policies enshrined in this strategy.  We endorse the three separate documents have been produced to accompany the Strategy and urge the GLA to promote this rail freight strategy and encourage the London boroughs to do so also.

• A Planning Policy Toolkit, aimed at assisting Borough planning officers in designating suitable sites for rail freight in Borough development plans
  
• A Development Control Toolkit, to assist Borough development control officers in reacting to rail freight planning applications
• A list of suitable sites for rail freight in London Boroughs

It is important to safeguard suitable sites for rail freight interchanges for possible rail use in London Plan and borough Local Development Frameworks. Important that boroughs are aware of their responsibilities in this regard.

FoR is pleased that the Rail Freight Strategy identifies the need to ensure that adequate network capacity exists for both passenger and freight needs.
 

Improving the Environment
Tonne for tonne moved, rail produces between three to five times less carbon dioixide5 than road freight (depending on cargo).

Remember an average freight train can remove 50 HGVS from our roads and an aggregates train can remove 120 HGVs from our roads6”  

Rail is a safe mode of freight distribution.
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)

Economic regeneration of rail freight
Rail freight can play a key role in economic regeneration
Value of freight to economy is often underestimated
As figures below indicate.

1. How valuable are logistics jobs?

Dispatch clerks, warehouse pickers           £300 pw
HGV/truck operatives                             £350 pw
Supervisory                                          £400 pw
Call centre operators                              £278 pw
Main logistics positions needs skills including IT
Source Midlands Logistics Study MDS Transmodal Regeneris 2005

Keeping London moving

Need same policy towards rail freight as water, such as SPG additional guidance and protection of rail lands and sites for terminals. Given the imperative to reduce carbon emissions form freight we suggest that a SPG on rail freight should be published as well as one for waterways. As previously stated, it is difficult for both rail and water to compete with road freight while it does not pay its external costs, nor has the rigorous safety regime which rail has.

Planning Issues – There is a need for clear national planning guidance which informs regional and local strategies. It is important that boroughs know that they can protect suitable sites for possible future rail use without fear of litigation using PPG13 and precedent of Mansard Homes v Surrey Heath. Once strategic sites are lost to the railways they are gone for ever.

Thames Gateway
Increased rail freight capacity will be crucial if rail is to play its role in the Thames Gateway redevelopment.

Changes to the London Plan
In addition to the SPG on waterways, we believe that there should be a SPG on rail freight. Rail and water 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 road congestion.

FoR keen to take part and be consulted in further consultations and studies and can draw upon its members’ expertise.

 
Philippa Edmunds  November 5th 2008

 

1. Carbon Pathways DfT 2008
2. EWS 2007
3. Network Rail 2008
4. Source Heavy Lorries do they pay for the damage they cause by MTRU and peer reviewed by Institute for Transport Studies Leeds   April 2008
5. EWS 2007
6. Network Rail 2008