Planning White Paper consultation July 27th 2007

Freight on Rail is pleased to respond to the Planning White Paper consultation.

Definition of Freight on Rail
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.

The members are as follows: - Rail Freight Group, EWS, Freightliner, RMT, ASLEF, TSSA, UNITE - AMICUS, Network Rail and Transport 2000

When considering rail freight it is important to take into consideration that rail freight crosses local and regional authority boundaries and take account of regional and national benefits of rail freight interchanges as well as the local effects. In this context, we believe the following needs to be incorporated in the final Planning policy adopted.

In summary 

1. National Policy statement needed for freight applicable for schemes under IPC and existing Town and Country Planning Act
   
 
2. Difficulty getting planning permission under present system
   
 
3. Need for detailed rail freight planning guidance
   
 
4. Need for regional tier of planning
   
 
5. PPG13 Protection policies need to be retained
   
 
6. Demand for rail freight exists as does enthusiasm to build interchanges
   
 
7. Why we need rail freight
 

Rail Strategy July 24th 2007

We support the statement that ‘the development of the rail network must be aligned with national and regional spatial and economic planning’ and believe that  is important to ensure that rail is properly treated in planning reform. 
 

1. National Policy statement needed for freight.

We believe the key reason for delay in existing planning system is lack of national strategic policy. National policy is needed to support rail freight so that regional and local authorities will make policies which protect and promote rail freight. That is why a national policy statement for freight is needed which should be taken into account for both schemes under IPC and existing Town and Country Planning Act.

This would be a cross modal statement addressing the movement of freight rather than rail. NPS should be regionally specific in the need for rail freight terminals while recognising it cannot be site specific.

Planning permissions for terminals is vital if rail freight is to grow and fulfil its role in reducing carbon emissions from transport. This issue is fundamental as we cannot increase the amount of freight carried by rail without more interchanges so fair and democratic ways of getting planning permission are needed.
 

2. Difficulty obtaining Planning Permission for rail freight terminals under Town and Country Planning Act

Maintaining the status quo for schemes not covered by Major Infrastructure Plans (MIPs) which would be devolved to local authorities will make it difficult to get planning permission for rail freight interchanges, as it has proved in the past. The chief obstacle is that the strategic national and regional importance of such facilities is often subsumed in debate on local issues. So it is difficult for the regional and national wider benefits to society of a rail freight terminal to be taken into account where local impacts may mean more lorry movements.

Difficulty in getting planning permission for interchanges is further complicated by the difficulty in finding suitable locations for SRFIs which have the right rail route criteria, road connections and space to develop an interchange. Location of sites is key to their success.

Where decisions are made at local level by local authority planning committees, it is difficult for councillors to support a rail freight scheme when there is local opposition unless there is strong national and regional policies which direct them to support rail freight. It represents a local decision for a project which normally has regional and national importance and as such needs strong national and regional guidance to justify consent.

Example of difficulty getting planning permission for Strategic Rail Freight interchanges
In the case of large interchanges know as Strategic Rail freight interchanges (SRFI) it has proved extremely difficult to get planning permission in recent years.

The LIFE project was refused because of a lack of national and regional strategic direction in 2002. It was rejected

1. on green belt
   
2. impact of local lorry movements

Green Belt - Special Circumstances
Difficulty in finding suitable locations for SRFIs which have the right rail route criteria, road connections and space to develop an interchange.
In the case of London, SRA identified need for 3-4 SRFIs, a policy which has been supported by the GLA. However the majority of the suitable sites, of which there are few, are on green belt.

For example a public inquiry has just finished at Howbury Park, Slade Green for a SRFIs on a former quarry which is green belt. There is a strong case for special circumstances warranted approval on green belt because of the wider environmental and social benefits of the shift to rail.
Therefore we believe that very special circumstances do justify the development of SRFIs within green belt in certain circumstances
There is a significant need for new interchanges, particularly in the south east.  These are of national importance, since, without them, the Government policy of encouraging freight on rail will be constrained.  The current planning process for new rail freight terminals is a major deterrent to development.  While an individual SRFI may not be deemed to be of national significance having a network of these interchanges is of national significance if we are to reduce carbon emissions.

A national policy statement on freight which would have to be taken into account for both major infrastructure projects and those under the Town and Country Planning act would provide policy direction for public inquiries and local planning authorities.
 

3. Need for detailed rail freight planning guidance

FoR has called for detailed rail freight planning guidance because there is no rail agency to support public inquiries or local authorities deciding on rail freight interchange applications. Previously the SRA gave written and or oral evidence both at a local level or at public inquiries. DfT Rail does not do this.
The DfT had in principle agreed to produce this document which has ministerial support, but the review of planning policy with the white paper have forced it to be  delayed. However, Freight on Rail still believes the manual is still needed to assist land use and transport planners and Public Inquiries evaluate rail freight schemes.
 

4. Need for regional tier of planning to make decisions of regional importance

The GLA, as an elected body has this decision making tier of land use planning policy. A regional planning body is needed across the eight English regions and should be part of the Planning White Paper policy. The review issued by H M Treasury Sub-National economic development and regeneration review 17th July 2007 should also include regional tier of planning to make decisions of regional importance.

This is becoming more of an issue with the larger Strategic Rail Freight Interchanges (SRFIs) if there is to be more devolution it means that the majority of large SRFI schemes go to public inquiry in any case.

Rail freight crosses local and regional authority boundaries, the Planning White Paper does not adequately cover the regional element. It raises questions about the robustness of existing policy to handle cross boundary co-operation between local authorities. For example in cases where there are conflicting views between  authorities about a proposed rail route.   
 

5. Rail freight needs PPG13 protection
Freight paragraph 45 should be retained

PPG13 Protection of transport lands identified in Local Plans
Freight on Rail is writing to give our comments and support for the freight section of the current version of PPG13 which we believe lays a strong foundation for planning protecting and promoting rail freight. We believe that the existing version of PPG13 has provided excellent support for rail freight and would oppose any dilution of the existing version.

PPG13 states - The Government has set out its policy framework on freight in its 'Sustainable Distribution Strategy' (March 1999). While road transport is likely to remain the main mode for many freight movements, land use planning can help to promote sustainable distribution, including where feasible, the movement of freight by rail and water.

Unlike passenger services which are specified by the Government, freight has no franchise agreements: this makes PPG13 all the more key to set the parameters for rail freight.

The Government can assist the rail freight industry by safeguarding planning through PPG13 combined with the land use planning framework so that rail freight can service the UK economy. The industry can fund terminal schemes as long as the planning framework secures the planning permission for such developments.

PPG13 is important in the context of protecting rail lands at a local level. This ability to protect sites at a local level is dependent on national and regional policy which enables authorities to justify protecting transport lands.

The judgment in the case of Mansard County Homes Ltd v Surrey Heath Council (Feb 2002 see our web site for full details) shows 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. This ruling means that authorities can protect railway sites and routes.
 

6. Demand for rail freight exists as does enthusiasm to build interchanges

More rail connected warehousing needed which property developers are willing to fund but the planning system is holding things back.
 
As an industry we need all the rail freight we can get                 
MD Maersk Sealand Feb 04

• “Having a rail alternative is more economic, cuts delivery times and is more reliable”-  Arthur Koutstall ECS European containers
• "We are also investing in alternatives to distribution by road. We have switched to rail for transporting goods from our Daventry depot to Scotland. We want to do more of this, and I urge the Government to build on its commitment to rail as an alternative to road for moving goods around the country" CEO of Tesco
• “Having a rail alternative is more economic, cuts delivery times and is more reliable”-  Arthur Koutstall ECS European containers
   

7. Why we need rail freight?

To protect the environment

Rail freight makes a vital contribution to protecting the environment and helping the Government to meet its commitments to improving air quality and tackling climate change. Overall rail produces less than one per cent of the total U.K. emissions of carbon dioxide, the principle greenhouse gas, compared with 21 per cent from road transport i.

Recent research by Herriot Watt University for EWS shows that a tonne of freight moved by rail creates five times less Carbon Dioxide than the same tonne being moved on the roads. Rail freight is also up to fifteen times better than road in terms of other noxious emissions.

To relieve road congestion

An average freight train can remove 50 HGVs from our roads – Network Rail

An aggregates train can remove 120 HGVs from our roads – Network Rail

Rail freight is able to act as a freight by-pass, by offering a more reliable alternative to road – something that will be more attractive as road congestion continues to worsen. The Government’s own forecasts show that it is set to grow by up to 37 per cent over the ten year period to 2010.

To offer an alternative to other issues facing road transport

Road congestion is causing extended and less predictable journey times.

Transport Select Committee Ports March 2007 report stated that
Inland infrastructure is the key to ensuring that freight can move around the UK and that the UK economy can therefore function.

The government has a fundamental responsibility to the transport infrastructure of the Uk, its major roads railways and rivers and canals. Its responsibility lies not only in ensuring the freight that moves on it can do so easily, quickley and sustainably.

Much of our future freight growth will have to be focused on rail, inland water and coastal shipping, the burden of this will fall on rail, particularly as the preferred mode of inland transport for shipping lines and generally their customers. 

 
Philippa Edmunds Campaigner    Freight on Rail   27th July 2007

i. The Railway Forum 2005