Freight on Rail is pleased to respond to the Revised draft of PPS4 Planning for Sustainable Economic Development

Reference to distribution networks in paragraph 18 (page 8) current wording below-

Identify, protect and promote key distribution networks, and locate or co-locate developments which generate substantial freight movements in such a way as to minimise carbon emissions. Such networks and development should be in sustainably sited locations, so as to avoid congestion and to preserve local amenity interests as far as possible whilst ensuring accessibility (including to rail and water transport where feasible);

Freight on Rail would like to make the following comments regarding the second sentence starting Such networks in the above paragraph and ask you to consider our suggested amendments.
 
We would like to see a stronger emphasis on planning and locating distribution interchanges where rail and water can play their part, in line with Government policy to reduce carbon emissions.  As you are aware tonne for tonne carried rail freight produces five times less carbon dioxide than road. More and more businesses are recognising that rail offers a reliable flexible low carbon alternative which avoids the uncertainty and unreliability of road congestion. Gary Anderson, President of Prologis, a leading Logisitics Developer, was quoted in Freight magazine March 2008 “There is a big shift going on across Europe from road to rail transport”.

Therefore if PPS4 can give guidance on the need to plan holistically looking for intermodal solutions with the benefits of co-modality being fully recognised, which would allow rail and water to play their parts in providing energy efficient low carbon alternative freight services in the context of uncertainty about fuel prices and sources.

We would therefore ask that the second sentence integrates sustainable freight rather than the current wording which makes rail and water seem like an add-on. In the context of rail, distribution interchanges should be located, where feasible, where there are rail connections and suitable road connections. Additionally there is a need to recognise the wider regional and national benefits of rail freight interchanges while balancing local interests.

We would like to ask you to consider the following wording for this second sentence. 

Such networks and development should be in sustainably sited locations with access to rail and or water facilities/network, where feasible, so as to ameliorate road congestion recognising the wider benefits to society of such facilities, while preserving local amenity interests as far as possible.