Freight on Rail Response to the DECC consultation into National Policy Statement for Energy (EN-1, 2, 3 and 6)

 
Thank you for the opportunity to contribute to the consultation on the overarching Energy NPS (EN-1).

Freight on Rail definition
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.

1. Executive Summary
The Planning System sets the spatial planning framework upon which transport and planning  decisions are made. It is therefore crucial that the economic, social and environmental benefits of rail freight, for transportation purposes, are full reflected in all the Energy NPS with a default for rail or water, where possible.

We urge that the points we make in EN-1 are fully taken into consideration in all the energy NPSs where appropriate.

Freight on Rail has long campaigned for national spatial planning to set the policy framework and to give guidance to regional and local spatial planning therefore we are supportive of National Policy Statements (NPSs) in principle. DfT has confirmed that local authorities will have to take material consideration of the DfT led NPSs in their planning and transport decisions and therefore this point should be made in all the NPSs. 

The NPS implies that many of the sites will be the same as existing ones and presumes that there will only be the existing transport links. Just because there are no rail connections currently at a site, it does not mean that rail should not be the preferred option in the future.

The case for stronger support for rail freight in all the Energy NPSs

Rail already has a significant market share in the movement of coal to power stations from ports and from domestic mining. It also has a significant market share in moving spent nuclear waste. Rail should be used for delivering biomass which this NPS recognises as increasingly important. In the construction phases rail should be used for transporting building materials to the sites for energy projects and for the removal of industrial waste. Rail or water should be used to remove gypsum from power stations, where appropriate.

Rail freight has a crucial role in helping the Government to achieve the low carbon economy and green jobs needed.

• Carbon reduction  - As DfT Department’s Logistics Perspective of December 20081 shows rail freight produces 70% less carbon dioxide emissions than the equivalent road journey.
• Road congestion relief - An average freight train can remove 50 long distance HGVs from our roads with the largest freight trains each now removing up to 160 long distance HGVs – Source Network Rail
• This means that moving more freight to rail can also have an economical impact; considering that the DfT estimate the cost of congestion being £1 per lorry miles on the most congested roads.

Safety - Rail freight is safer than long-distance road freight using motorway and A roads, as HGVs are over 3 times more likely to be involved in fatal accidents than cars due to a combination of size, lack of proper enforcement of drivers hours, vehicle overloading and differing foreign operating standards. Source: Road Statistics 2008, Tables 3.2 and 3.6, Road Freight Statistics 2008 Section 5, both DfT

Government Policies support the need to reduce carbon emissions

• Climate Change Act, which commits in statue to an 80% reduction in CO2 emissions by 2050

• The DECC commitment  -To contribute to sustainable development by seeking energy infrastructure development that helps reduce climate change while also minimising negative impacts on the local environment

• Coalition Programme for Government of May 2010 committed to reduce carbon dioxide emissions and promote green transport

• Rail Freight successes potential
  Rail carries 13% of freight in the UK
• Over 25% of the electricity consumed in the UK is generated by coal that has been moved by rail
• Rail moves aggregares and cements into major conurbations to enable developments that in turn enable our econmy to grow. In London over 40% of raw materials are delivered by rail.
• Consumer rail freight has grown by 21% in the last four years despite the recession
• Rail Freight Group/Freight Transport Association forecasts of June 2008, indicate that by 2030 rail freight volumes will have more than doubled.

All these factors are backed up by a report published by the Institution of Mechanical Engineers in early 2009, which states that: “ as an option for the reduction of carbon emissions, the rail freight sector is leagues ahead of all the other options available. The target should therefore be to deliver far greater levels of growth in the rail freight sector than are currently projected.”

In view of the NPSs acknowledgement of the need to reduce carbon emissions, we believe that the Energy NPSs should have stronger policy in favour of rail freight for transportation and should have a presumption of using rail and water modes, where possible.

Detailed comments on National Policy Statement

Consistency between Energy NPSs and Transport NPSs
We ask that there is consistency between the Energy and National Networks and Ports NPSs where feasible.

EN-1 Overall NPS

Traffic and Transport Implications
5.13
5.13.10
Water-borne or rail transport is preferred over road transport at all stages of the project, where cost-effective.

We fully support the preference for rail and water transport and believe that definition of cost-effective should take into account all the external costs of the various modes in determining what is cost effective to society the economy and the environment.

The IPC should also be able to make use of rail a mandatory planning condition both for the ongoing use and the construction phase.

5.14 Waste Management
Rail and water should be stated as preferred waste removal modes for industrial and energy waste.

EN 2 Fossil Fuels
We note that paragraph 2.2.5 is much weaker than 5.13 of EN – 1 and suggest that the former should be changed to make clear that rail or water modes are preferred. We do not agree that rail is unlikely to be economic in many cases as existing sites make considerable use of rail. 
EN-2 should give  stronger support for alternative modes to be consistent with EN-1

EN-3 Renewable Energy Statement
The use of rail or water for moving biomass should be mentioned in paragraph 2.5.22

EN-6 Nuclear Statement
There does not appear to be specific statement on transport on EN-6. In line with EN-1 there should be a preference for rail and water where feasible. Rail and water should be preferred modes for the movement of construction material to and from sites.

Philippa Edmunds Freight on Rail Manager January 2011