Response to draft guidance to regions Delivering a Sustainable Transport System (DaSTS)Freight on Rail is pleased to comment. Summary Thank you for the opportunity to comment. Unless there is clear DfT guidance and involvement there is a danger that short term political decisions could prevail over long term strategic assessments. If DaSTS is to build on RFA 2, it will be important to avoid some of the shortcomings of RFA 2 which include local authorities promoting their local priorities with little strategic, regional awareness, patchy CO2 impact assessments, and the tendency for road schemes to dominate. We welcome the fact that DfT want regions to pay more attention to rail and revenue measures – but regions will need more, firmer and more consistent guidance which makes it clear to regions that rail should be fully evaluated. DfT ambiguity in RFA 2 : encourage rail, then insist regions have to prove benefits from rail will “stay in the region” (no such requirement for roads) Regions must be told that they need to re-assess previous commitments in light of DaSTS otherwise legacy schemes from RFAs1+2 could leave little funding for rail schemes. Government must also however be open to proposals for national policy options from regions and local authorities and consider these seriously in its own corridor work. In terms of the ability of the regions to carry out the long term transport planning in terms of option generation and justification, envisaged in DaST, we believe there are resourcing issues. The sub national review has not fully clarified the new roles in the regions, nor the resources available for this. Close joint authority working will need active support and resource funding from central Government. Transport policy should seek to actively enhance the natural environment rather than simply minimise impacts. We believe that carbon reduction and moving towards a low carbon transport system are the key priorities as is quality of life and health. The importance of end to end journeys is not mentioned as a key challenge. Corridor/network planning and option generation, whether undertaken by central or local government, should systematically map all the challenges on the corridors and networks to ensure that options generated address all the challenges. Options considered in relation to the corridors should include national policy interventions, rather than purely ones relevant to the corridor. Examples include promotion of/funding for interchanges. Non transport interventions, such as land use planning policies should be considered in corridor planning. Under cross network/economic competitiveness any simplication of regulations should consider impacts on the wider community rather than just the benefits for users and providers. Safety requirements for road haulage are an example where stronger rather than weaker regulation is needed for the wider community. See section on implications of weak road safety regulation. The studies appear not to consider links between national networks and local and regional transport networks. If the mistakes from multi-modal studies are to be avoided, clear planning, delivery and funding arrangements at the regional, sub-regional/city region and local level must be set out. We question whether current regional structures are resourced to lead on the development of sustainable solutions for city and regional networks which will deliver on CO2 reductions; joint boards in the short term and in the longer term city-regions integrated transport authorities, complemented by well resourced rgional bodies with effective involvement of stakeholders, will be needed. A genuine partnership between central and regional/local government and good stakeholder involvement will be required to ensure that the linkage and interplay between national local policy options is developed and assessed properly and a full range of meaningful options generated. FoR and its members will be pleased to take part in the stakeholder involvement in the corridor studies. Detailed comments 1. Resource constraints in regions In order to reduce carbon emissions from freight, the Government needs to help regional and local authorities promote rail freight schemes where viable. Ref P.3-11. It will be vital that national government insists to regions/local authorities that options and packages of solutions to problems in their areas make progress on all the Government’s 5 goals and the challenges, and that this progress is measurable and effective. For example, sub-national government must contribute to meeting carbon reduction targets; it cannot opt out of this as some regions have during the current RFA2 round. We urge the Government to insist that regions/local authorities do give effective weight to a full range of options including modal shift and land use changes. The regions will need to be given clear directions from Central Government about the urgency of reducing carbon emissions so that rail schemes are fully evaluated. The allocation of funds to developing schemes will be important as many local authorities have dedicated staff to develop roads but not rail - DfT may have to moderate its insistence on early or easy deliverability to allow longer-term planning for sustainability. It is important that there is early collaboration between DfT, Network Rail and authorities with clear guidance from DfT on rail schemes. Rail schemes should be fairly treated. 2. Implications of weak road safety regulation Lack of compliance with road regulations by HGVs should be taken into account when accessing relative cost benefit analysis and safety implications of different modes because lack of compliance by HGVs with existing road regulations puts over road users at extra risk.The rail industry is highly regulated in safety terms whereas enforcement of road regulations is needed if improvement if road safety is to take place. Over 82% of HGVs exceeded their speed limit of 50 mph on dual carriageways and almost three-quarters exceeded the 40 mph limit on single carriageway non-built up roads in 2007. Source: DfT Transport Statistics Traffic Speeds Figure 3.5C for 2007 issued July 2008 VOSA spot checks in October 2008 found that half of UK registered HGVs stopped were breaking the law. IFW 21st October 2008 In terms of cities and regions where it is planned for regional and local authorities to take the lead we believe that it is crucial that safeguarding policies for rail corridors are upheld at national, regional and local levels. 3. Land Use Planning DaST is right to note the importance of spatial planning. All corridor and network studies should consider ways of reducing dependence on road transport in new and existing developments. The right land use planning policies to safeguard and protect rail freight lands are also key and we believe that the National Planning Statements offer the right mechanism a) to safeguard national rail corridors long term as part of the low carbon economy. b) give direction to local authorities and Public Inquiries which has to be taken into account when planning decisions are made at a local level. Planning Policy Guidance (PPG13) powers must be retained and strengthened at a local level in the ongoing planning statements revisions being carried out by CLG as these powers have been crucial in protecting strategic rail alignments and sites locally for possible rail use, even where there is no current rail plan during the period of the plan. Climate change considerations have shown that it is crucial that key transport lands are protected, otherwise once they are gone they are lost to the nation for ever1. The case of Mansard County Homes Ltd v Surrey Heath Council in 2002, showed councils countrywide that they can protect disused railway land for future potential railway use, even where there is no immediate evidence of future possible use without fear of litigation, as long as the lands were identified as such in the local plan. PPG13 clearly indicated that even where there was not a reasonable chance of future use of an old transport link, unnecessary severance was still to be avoided. The background to that policy presumed against unnecessary severance in order to preserve long term prospects of re-use. While we realise that Planning Policy statements are the primary responsibility of CLG, DfT will be consulted, so we hope that you agree that these long-term safeguarding powers need to be retained at this local level. 4. Need to reform appraisal in order to reduce carbon emissions from transport While we accept that road and rail modes complement each other, and that road will remain the dominant mode, it is important to acknowledge the factors which have lead to this situation, namely:-
5. Safety aspects of rail freight 1 rail passenger died during 2007. According to the Government’s own figures Road fatalities cost the Government £3bn per annum. Overall, road accidents cost around £18 billion per annum according to the Road Safety Foundation. The Transport Select Committee report – Ending the scandal of Complacency October 08 that there is a degree of underreporting of serious accidents and stated that Freight on Rail is concerned that this under reporting could mean that the inherent dangers of HGVs are underplayed. Lumping together deaths and serious injuries makes analysis more difficult and should be replaced with separate reporting and targets in 2010. By lumping together “killed and seriously injured” in the targets for 2010, there is an incentive for the authorities (including the police) to under-classify injuries. The Transport Select Committee report – Ending the scandal of Complacency October 08 While we support policies to reduce road accidents, we would point out that transferring freight to rail will reduce road accidents significantly because HGVs, because of their size and weight are disproportionately more likely to be involved in fatal accidents for example. On motorways, HGVs are over three times as likely as cars to be involved in fatalities from road accidents per billion kms travelled. DfT figures dispel the myth that lorries are safer on motorways than other roads. In terms of road safety of different types of vehicles, what really matters is how dangerous HGVs are on different types of roads in relationship to other vehicles. Lorries are in fact less safe on motorways than A roads, because of the forces involved, ie weight and speed implications of HGV traffic travelling faster on motorways. Sources for Tables 2 & 3: TSGB 2007, Goods Vehicle Statistics 2007, Goods Vehicle Accidents and Casualties 2007, all DfT 6. Tackle Climate change The Government’s own figures show that rail freight produces over three times less CO2 emissions per tonne carried, than the equivalent road journey- ref DaST Logistics Perspective Dec 2008. Industry figures indicate that CO2 emissions from rail are between three to five times less, per tonne carried than the equivalent cargo carried by road. The range related to different cargos. Energy efficiency is directly related to carbon dioxide emissions; rail is far more energy efficient than road and air transport which makes rail an attractive option with price variations and unreliability of oil sources. DfT needs to make it clear that tackling climate change is imperative and urgent. We recommend DfT guidance on carbon impact assessment as many councillors do not understand the urgency of addressing climate change and do not see it as their role. And therefore the DfT should not leave the method of achieving CO2 reductions entirely to the regions. CO2 emissions needs to be linked closely to soical inclusions and quality of life. If, as stated that the Government wants to ensure that people and businesses have choices about transport they use but that they want to ensure that they face the full costs of their choices, the costs of freight distribution will need to be internalised as supported by Freight on Rail. Were this to take place, more sustainable modes such as rail would increase their market share. a) Lorry user charging Research published using the freight model used by the Government, shows that a lorry road pricing scheme could improve the efficiency of road freight, almost double rail freight and also increase coastal shipping and the use of northern ports.
b) Shifting freight to rail can reduce road maintenance costs for authorities and reduce emissions and road congestion Research commissioned by Freight on Rail highlights that in counties with significant rail freight potential, the local transport authorities could save serious amounts on road repairs if suitable cargoes were to go by rail. The research shows that the case study county council, which spends a typical amount on its road maintenance, could be saving as much as £770,700 on road maintenance each year because certain goods in its area go by rail rather than road. The research makes a strong case for local authorities to be free to use their road maintenance budget to encourage more freight to go by rail, particularly where they have significant bulk, waste or port traffic in their regions, even without taking into account the significant additional environmental, social and congestion benefits of rail freight. HGVs are up to 160,000 times more damaging to road surfaces than the average car; some of the heaviest road repair costs are therefore almost exclusively attributable to the heaviest vehicles and the research suggests that transfer to rail can reduce these costs. 8. Rail freight has been a success story Rail freight has grown by 60 per cent over the last ten years.
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