Scottish Consultation

Thank you for the opportunity to comment on this policy. Freight on Rail’s response consists of general comments followed by answering the consultation questions.

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.

General Comments on introduction and current market section

For rail freight to play its full role in servicing the economy in a sustainable way, it needs the ongoing support of the Scottish Government so that industry has the confidence to continue investing in the industry. RFG/FTA forecasts for rail freight growth show that rail freight could double its market share by 2020 so we welcome the Government writing this rail freight policy to provide the vision to help achieve these goals as part of the low carbon economy.

P7 Damage caused by road and rail to their respective infrastructure
Network Rail and ORR have already undertaken extensive research into rail freight impact on the rail infrastructure as part of the review of access charges for CP4. As a result of this review access charges paid by the freight operators are set at a level which covers the damage caused by those services. A detailed model allocated different charges to different wagon and locomotives depending on their specific attributes. Since April 2009, coal service also pay for the fixed cost of the freight only lines which they use. Overall therefore there is no evidence that rail freight traffic is not covering its costs for track damage.

Consultation questions

Question 1
The Scottish Government has a key role in promoting rail freight as part of the low carbon economy and green jobs needed by society. In order for industry to invest in rail freight it needs to have confidence that the Government supports rail freight.

Scottish Government support is needed in the following ways

Supportive rail freight policy at national and local authority level in transport and land use policy terms
Upgrading of the network
Grants which take into account rail’s benefits in terms of road congestion relief and reduction in other external costs to society as recognised in the Sensitive Lorry Mile calculations.

Question 2
Rail’s benefits to society and economy:-

Rail has a crucial role in reducing freight’s carbon dioxide emissions as it produces 70% less CO2 than the equivalent road journey. It is therefore more energy efficient than road.
Reducing road congestion

An average freight train can remove 50 HGVs from our roads1 with the largest freight trains on the network can each remove 160 HGVs.
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 UK Department for Transport

Question 3
Obstacles to moving freight by rail

Under infrastructure rail freight terminals
Without terminals/interchanges in the right locations, rail freight volumes cannot be increased therefore the following land use planning and transport planning policies are needed to provide the framework to protect, alignments and suitable sites for terminals

Local government shape the planning framework, within its borders, So it is vital that local spatial planning makes adequate provision for rail freight. It needs to identify and protect existing and disused sites, lines and sidings and suitable interchange locations. In particular, planning permission for rail interchanges, without which rail freight cannot increase, will not be secured unless the right policies are enshrined in the spatial planning framework

Planning permission for terminals
Without Scottish Government support, it is difficult for LAs to justify giving planning permission for terminals to take advantage of the wider regional and national benefits a terminal will provide, because there are often local disadvantages of terminals such as increased HGV movements.

Question 6
Grants are key to retention of existing rail freight flows and to expansion
Rail freight grants which take into account the economic, environmental and social benefits of rail to society are key to retaining existing flows and shifting more freight to the railways as part of building the low carbon economy and the green jobs needed.

Grants are designed to take into account the benefits to the economy, in terms of road congestion relief and reduction in emissions and other external costs to society avoided by using rail instead of road.

Rail freight grants budget not confirmed yet for year April 2010-April 2011
We support the mode shift grant schemes and urge the Scottish Government to confirm the budget beyond April 2010.

The grants regime in Scotland has been crucial in increasing rail freight volumes as part of reducing road congestion, emissions and exposure to accidents.
Scottish Government support has seen significant growth in key emerging markets such as the supermarket business. Examples of which are
Asda has been using rail in partnership with the Malcolm Group and Direct Rail Services since 2001. The annual road travel savings, allowing for movements from the rail terminals to the distribution centres is 9718,800 kms and a savings of 6376 CO2 emissions.

Rail services offered by the Malcolm Group in partnership with Direct Rail Services (DRS) now also include deliveries between Grangemouth and Linwood Grangemouth and Aberdeen Daventry (DIRFT) and Mossend.

The Grangemouth Aberdeen intermodal (containers) service run by DRS for WH Malcolms
Runs 6 days a week and the main customer is Asda and the service is further enhanced by ARR Craib and Malcolms joining forces with Asda by addition additional containers onto the service. This service has contributed towards a savings of almost 3000 tonnes of CO2 emissions per year and equates to removing 7200 lorry journeys off the congested roads.
The daily service between Daventry and Grangemouth which services its sites across the central belt of Scotland, is so environmentally efficient it alone makes fuel and CO2 savings equivalent to taking the entire Stobart fleet of over 1850 trucks off the road for around two weeks a year

Revenue and capital grant support has been key in achieving these goals.
Freight Facility grants are important in offsetting the initial start up costs of the shift to rail

Question 10
At a time when the urgent need to reduce carbon emissions and rail’s contribution is recognised, the Forth bridge road project should not divert crucial funding away from rail freight schemes.

Key rail enhancements needed

Upgrades to rail capacity and capability into Grangemouth
The WCML to Coatbridge is already clear for W10, therefore an enhancement to Grangemouth would be required from Coatbridge via the Scottish Central Route (Cumbernauld – Greenhill) then from Greenhill to Grangemouth.

One of the priorities for upgrade is improving the looping facilities in the Mossend area

W10/W12 from the East Coast Main line to Mossend either via Carstairs or Shotts is crucial. This would open up the Central belt of Scotland to increased East Coast traffic and also improve the flexibility of the network for diversions.

Improvement in capacity and capability (mainly improved loop lengths) between the Central Belt and Inverness

The majority of enhancements to the rail network benefit passenger and freight services.

Philippa Edmunds Freight on Rail December 16th 2009
philippa@freightonrail.org.uk

1. Network Rail 2009