Response to the Select Committee Inquiry
Freight on Rail welcomes the opportunity to contribute to the inquiry on the draft National Planning Policy Framework.
Freight on Rail, a partnership of the rail freight industry, the transport trade unions and Campaign for Better Transport, works with local and central Government to promote rail freight, the low carbon 1, energy-efficient safe alternative to long distance road freight which reduces road congestion.
We welcome the National Planning Policy Framework’s (NPPF) recognition of the need to support sustainable transport modes for the movements of goods or people (paragraph 89) and the imperative to avert climate change by reducing carbon dioxide emissions and the need to reduce road congestion (p88). However, some of the caveats such as where practical and where reasonable (p83) risk weakening the framework’s ability to meet the stated objectives to avoid climate change and reduce road congestion.
We warmly welcome the draft NPPF recognising the role of rail freight
a) in facilitating economic growth, reducing road congestion and reducing carbon dioxide emissions.
b) the resulting need to build rail freight terminals to achieve these aims through modal shift.
c) the recognition of the need to develop large scale facilities such as rail freight interchanges (p84)
We are pleased to see that the local authorities retain the ability to safeguard sites but fear that the weakening of safeguarding policy will make it difficult in practice for local authorities to safeguard sites for long term possible use.
We are also concerned about transitional arrangements during the period when local plans are not NPPF compliant.
1. Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?
Areas of concern over ability to meet environmental aims
The draft NPPF recognises that some policies and proposals will not „maximise sustainable transport solutions. (82). the commitment to sustainable development is heavily qualified: the NPPF supports a pattern of development which facilitates the use of sustainable transport but only „where practical. or „where reasonable to do so. (83).
We support paragraph 10 recognising that sufficient land of the right type and in the right places is needed
Lack of sub-national strategies could make if difficult for local authorities to support strategic projects locally which have wider social, environmental and economic benefits but have local disadvantages. (See question on strategic planning). For example, P5 paragraph 18 states developments should be appropriately located. Without sub-national strategies it is more difficult for local authorities to protect sites for future rail use in local plans.
Transport safeguarding needs to be strengthened
Rail freight infrastructure needs to be located in the right places, therefore the ability of local authorities to safeguard key sites is crucial. So we welcome the retention of the principle of local authority safeguarding (p94) of key strategic rail corridors and sites in their local plans. While the principle of land safeguarding remains, we envisages safeguarding problems, especially during the transition period, because many existing local plans will either not conform with the NPPF or have not been adopted and the proposed text in the NPPF, will not protect sites, in its own right. In practice, it may therefore be difficult to safeguard strategic sites for long-term potential transport use from other less environmentally sustainable demands for the land.
The NPPF is not likely to allow local authorities to have the same control on getting freight related locations right in local plans in terms of supporting freight without the specific references which were in PPG13 paragraph 45
Paragraph 45 PPG13
The Government has set out is 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. 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 the SRA which is 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;
- 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, waterways or coastal/estuarial ports; and
- On disused transport sites consider uses related to sustainable transport first, before other uses
PPG13 paragraph 73 stated - In preparing their development plans and determining planning applications, local authorities, in conjunction with work on the local transport plan, should:
3.explore the potential, and identify any proposals, for improving rail travel, in liaison with the Strategic Rail Authority, including the reopening of rail lines, or creation of new stations on existing rail lines, light rail or guided bus routes (giving due consideration to the funding and value for money of proposals
Paragraph 43 of the NPPF, could also make it difficult to safeguard key sites for future possible rail use, if infrastructure has to be deliverable in a timely fashion.
We support the safeguarding in the minerals section. (p102) safeguard existing, planned an potential rail heads, rail links to quarries wharfage and associated storage, handling and processing.
We would like to see prioritisation of the use of low carbon modes such as rail and water, for transportation of minerals to lessen the impact on society in terms of emissions, road congestion, road maintence costs and adverse impacts from transportation of bulk products. It should be noted that NR pointed out in its Value of Freight publication that an average aggregates train can remove up to 160 HGVs from our roads.
We support the fact that local plans should include strategic policies to deliver the provision of infrastructure for transport minerals and waste and work with other authorities and providers to assess the demands and meet forecasted demands para31
Green belt policy
We support current policy which we understand the NPPF does not changes. This allows for some development where in very special circumstances if the social, economic and environmental is compelling.
Planning conditions and obligations
NPPF weakens the ability of local authorities to impose or enforce planning conditions and obligations (p67-70). NPPF discourages the use of conditions and obligations. However we believe that conditions and obligations can be important to promote sustainable modes and that local authorities should have to power to make these conditions. For example planning permission for Terminal 5 was given on condition that construction materials were delivered by rail. Local authorities can stipulate that facilities get planning permission on the basis of a certain percentage of freight being carried by rail. Even with the current system it can be difficult for authorities to enforce conditions as developers do ask for rail quotas to be reduced, once planning permission has been secured, sometimes even before the facility is operational. See PPG13 paragraph 81/82/83/84
There is a lack of clarity about what Ministers expect to happen with this process and the extent to which they expect existing local plan documents to be rewritten. There is also the danger of local planning authorities rushing through local plans which are inadequate. Local plans are required to have a certificate of conformity with the NPPF. In its absence, or the absence of an „up-to-date and consistent. local plan (p14), planning applications will be determined in accordance with the NPPF. In those circumstances, the NPPF will take precedence over local development plans, where full consultation has occurred (p26). A recent estimate by a planning lawyer was that only 5% of areas would be covered by a valid plan in conformity with the NPPF when it comes into force.
2. Is the definition of 'sustainable development' contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?
The emphasis on sustainable development reads too much like being in favour of short-term economic development which could impose costs on both the economy in terms of road congestion and the environment which will have to picked up over the long-term.
3. Are the 'core planning principles' clearly and appropriately expressed?
While the summary chapter Delivering sustainable development states the environmental role planning for places plays and the need to mitigate and adapt to climate change including moving to a low-carbon economy, and (p71) enforces this to meet the twin challenges of global competition and of a low carbon future, the section on transport waters this down with qualifying statements such as where practical and where reasonable (p 83).
In the same way, what does undertaking development responsibly mean in planning terms?
4. Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?
Paragraph 31 states that local planning authorities need to take account of the need for nationally significant infrastructure within their areas. The definition of areas should not be limited to local authority boundaries and should include the wider sub-national and regional context.
Paragraph 87 take account of the principles set out in the relevant national policy statement.
National Policy statements for national networks does not exist yet so currently there is a planning vacuum for major infrastructure projects which is undermining economic recovery by stopping developers submitting planning applications for SRFIs
Rail facilities, especially the large SRFIs, with warehousing and associated ancillary services provide both direct and indirect employment, as illustrated by the chart below.
5. Does the NPPF, together with the 'duty to cooperate', provide a sufficient basis for larger-than-local strategic planning?
Key economic need for strategic planning if sustainable regeneration is to take place. Lack of sub-national policy will make strategic plan=ning difficult. LEPs, which do not have statutory status, cannot fill this gap so the final wording in the clauses of the duty to co-operate in the Localism Bill will dictate how effective the new regime can be in supporting strategic planning. Projects like rail freight terminals which have wider economic, social and environmental benefits, but can have local disadvantages, such as extra local HGV movements, and are consequently opposed locally, can be difficult to justify without strategic planning policy.
While the draft NPPF ensures that local authorities demonstrate that they have worked together, there is no overriding sub-national policy objective which has to be achieved, now that regional spatial strategies are being abolished, which means that there is a danger that some local authorities could go through the motions of co-operating.
Suggested clauses for modification of duty to co-operate submitted to DCLG by Freight on Rail in February.
- Planning authorities should be required to consider fully the economic, social and environmental impacts [not benefits] outside their boundaries of schemes
- Planning authorities should be required to consider and show that they have had regard to representations about such impacts from people and organisations outside their area, including neighbouring authorities, statutory bodies, and civil society groups
6 Rail freight potential
Rail freight volumes have grown despite the recession, with a 16% growth in the first quarter of 2011 over the previous year, especially in the consumer market with quarter of products coming out of South Eastern container ports being carried by rail. Rail freight volumes can double in the next 20 years, especially in the consumer sector, as long as Government continues to support rail freight through spatial planning and transport policy; in fact if rail does not grow there will be increases in long-distance road congestion.
The growth is forecast particularly in the emerging supermarket rail traffic, this sector has the highest growth potential of up to 12 times in a 25 year period 2 as long as terminals can be built and existing market conditions are maintained.
The case for rail freight
a) Road congestion alleviation
An average freight train can remove 50 long distance HGVs and an aggregates train can remove up to 160 long distance HGVs 3
Road congestion is claimed to cost businesses £17 billion per annum. 4
DfT estimate the cost of congestion being £1 per lorry miles on the most congested roads.
b) Tackling climate change
Rail produces 70% less CO2 per tone-km than road transport 5 and can help the UK meet the 80% carbon reduction target. Network Rail has calculated that a tonne of goods can travel 246 miles by rail compared to 88 miles by road on a gallon of fuel. Shrinking oil supplies and costs mean that rail’s efficiency is even more important.
c) Rail freight is a safe mode
British railways the safest in European Union after Sweden
Existing HGVs are over 3 times more likely to be involved in fatal accidents than cars on major roads due to a combination of size, lack of proper enforcement of drivers hours, vehicle overloading and differing foreign operating standards 6
1. Rail freight produces 70% less CO2 emissions than the equivalent long distance road journey DfT Logistics Perspective Dec 08
2. Network Rail The Value of Rail Freight July 2010 Domestic intermodal growth highest forecast 1200% in tonne km between 2006/07 and 2031
3. Network Rail 2011
4. FTA The Importance of Rail Freight 2008
5. DfT Logistics Perspective Dec 2008 P8 item 10
Source: Road Statistics 2008, Tables 3.2 and 3.6, Road Freight Statistics 2008 Section 5, both UK Department for Transport)