Response to Consultation on Scottish Planning Policy

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.

Freight on Rail is a partnership between transport trades unions, freight operating companies, the Rail Freight Group and Campaign for Better Transport. It 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 to central, regional and local government.

Benefits of rail freight
Economic
Road congestion is claimed to cost businesses £17 billion per annum. FTA The Importance of Rail Freight 2008

An average freight train can remove 50 HGVS from our roads and an aggregates train can remove 120 HGVs from our roads. Source Network Rail 2009

Environmental
DfT figures show that per tonne carried rail freight produces at least three and a half times less carbon dioxide than the equivalent cargo carried by road – Source DfT Logistics Perspective Dec 08 P8. Rail produces 0.05Kg rail produces

Safety
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)

HGVs are over 3 times more likely than cars per miles driven to be involved in fatal accidents. DfT Transport Statistics Traffic Speeds Figure 3.5C for 2007 issued July 2008

Specific comments on consultation

Economic Development
Paragraph 40 P. 10
Planning authorities should promote opportunities for sustainable freight distribution and transport in general in economic development.

Paragraph 41 P10/11
Given the need to reduce carbon emissions, identified as a key overriding policy in this document and now subject to legal targets since the Climate Change Bill of 2008, suitable sites or rail alignments for potential rail use should be protected even where there is no existing rail use and therefore should not be reallocated for another use. Rail alignments and sites suitable for interchanges beside the railway are limited and should therefore be protected, given the need to develop a low carbon economy. Once sites such as this with rail access are lost, they are gone for ever to the nation.

High Court ruling in England stated that as long as sites and rail alignments are identified in local plans, councils could safeguard sites for future rail use even where no rail use identified during the life of the plan. Mansard County Homes v Surrey Heath Council. Is this judgement relevant in Scotland,

Local authorities should state that regional distribution depots etc should be located beside good rail and road connections. Local authorities should stipulate that factories and assembly plants, should be capable of being rail connected

Paragraph 43 P11
As above rail sites and alignments should be protected.

Question 7
Planning system has a key role in promoting the use of low carbon freight transport so setting the framework which requires factories distribution depots etc to be capable of being rail connected.

Paragraph 121 P28 Green belt
Special circumstances where strategic rail freight interchanges could be sited in green belt if there are no alternative sites outside green belt because of the low carbon benefits of rail.

Transport
Para 123
FoR strongly supports policy to promote rail freight as a low carbon energy efficient, safer alternative to road and air freight.

Freight Paragraph 134 P31

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. In preparing their development plans and in determining planning applications, local authorities should:

Identify and, where appropriate, protect sites and routes, both existing and potential, which could be critical in developing infrastructure for the movement of freight (such as major freight interchanges including facilities allowing road to rail transfer or for water transport) and ensure that any such disused transport sites and routes are not unnecessarily severed by new development or transport infrastructure. In relation to rail use, this should be done in liaison with Transport Scotland, Network Rail and the rail freight industry which are best placed to advise on the sites and routes that are important to delivering wider transport objectives;
Where possible, locate developments generating substantial freight movements, such as distribution and warehousing, particularly of bulk goods, away from congested central areas and residential areas, and ensure adequate access to trunk roads and the rail network
Promote opportunities for freight generating development to be served by rail or waterways by influencing the location of development and by identifying and where appropriate protecting realistic opportunities for rail or waterway connections to existing manufacturing, distribution and warehousing sites adjacent or close to the rail network,

Development plans should require manufacturing processing distribution or warehousing to be capable of being rail connected as well as having adequate links to the road network.

Paragraph 135 .
Freight on Rail strongly agrees that local and regional authorities have a key role in setting the framework for rail freight by having policies:-
a) To promote mode shift to rail by defining this as a stated policy
b) By protecting suitable locations for additional rail interchanges
c) Protecting disused rail alignments.
d) Protecting transport corridors for future rail use in line with Government policy to reduce carbon emissions and promote the low carbon economy.

As well as suitable access to the rail network, exact criteria needed will depend on the size and type of terminal envisaged, good road access capable of handling HGVs with proximity to major road trunk network is needed for interchanges.

Question 20
If the UK is to meet its legal emission reduction targets, national policy needs to direct local authorities to promote sustainable freight distribution by requiring authorities to state that factories, interchanges etc should be capable of being rail connected.

Minerals
Paragraph 173
We strongly support the policy that states that where possible transportation of minerals should be by sustainable distribution methods. Research for Freight on Rail showed that by using rail instead of road in areas with significant bulk waste aggregates and minerals cargoes could reduce road maintenance costs as well as the additional safety, environmental and congestion benefits of rail freight

See Rail freight saves sample County Council over £750,000 in road repairs - 26th March 2006

Open cast coal
Question 26
Transportation impacts of coal have not been taken fully into account.
Policy should state that rail should be used instead of road where feasible.

Philippa Edmunds
Freight on Rail Campaigner June 2009