Delivering a Sustainable Transport  System - The Logistics Perspective

Freight on Rail is pleased to give the following feedback

Summary

We welcome the Government’s commitment to reducing carbon emissions and its funding to enhance the rail freight network and urge it to stand firm on its forthcoming commitments to the Strategic Rail Freight Network (SFN) as part of the low carbon economy. Rail freight has a key role in the top twin challenges of emissions reductions and growing the economy and providing green jobs.

We are pleased to see that rail freight is integrated into the solutions for the logistics industry in the report but given the economic as well as environmental imperative, highlighted by the Stern report for the Government in December 2006, we believe the Logistics report could be stronger in highlighting  the advantages of rail freight in economic, environmental and safety terms. Rail has a key role to play in helping the Government to meet its commitments to carbon emissions reductions of 80% by 2050 set in the Climate Change Act.

It is vital that the report gives a balanced view of the relative advantages of each mode so that each mode can be fairly assessed. Therefore the decimal point error on Page 8 item 10 is unfortunate as it masks an important benefit of rail which produces around 4 times less CO2 than road freight. The industry calculates that on certain cargoes, rail can produce up to five times less carbon dioxide than road.

It will be vital for society that options and packages of solutions to problems make progress on all the Government’s 5 goals and the challenges, and that this progress is measurable and effective. It is important that there is early collaboration between DfT, Network Rail and authorities with clear guidance from DfT on rail schemes which come under city and regions.

Rail freight has been a success story and grown by 60 per cent over the last ten years. 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:-   

1. that road does not pay for the external and congestion costs it imposes on society therefore there is not a level playing field between modes which makes it difficult for rail to compete
   
2. the Appraisal system continues to treat the loss of tax revenues from fuel and VED as a disbenefit in cost benefit analysis of rail schemes, which makes it  difficult to justify rail projects
   
3. journey reliability and predictability is given priority in the DaSTS challenges, whereas in appraisal priority is given to time savings. These are not identical and will not produce the same options.

It remains the case that existing sized lorries are still 40 times heavier, 4 times longer, three times more likely to be involved in road fatalities, twice as noisy, and thousands of times more damaging to the road surface than cars and produce at least three times more carbon dioxide, per tonne carried, than rail.

As well as emphasising improvements in road emissions and safety it is crucial to spell out clearly the inherent environmental and safety advantages of rail.

Lack of compliance with road regulations P50 2.37
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

Table 1
HGV MOT tests and failure rates

	Number of tests	Failures		Failures as %
		Initial	Final	Initial	Final
2004/5	465,258	181,117	116,155	38.9	25.0
2005/6	467,698	172,478	104,216	36.9	22.3
2006/7	466,215	184,248	103,127	39.5	22.1
2007/8	462,820	168,837	93,397	36.5	20.2

Source: VOSA 20081

Vehicles which have relatively minor defects, such as failed or wrongly adjusted lights, are permitted to be corrected on the spot.  This explains the difference between the two failure rates.  It remains the case that, even after minor faults have been corrected, a fifth of the HGV fleet fails the MOT test, even though MOTs are planned unlike spot checks.

Safety
The Transport Select Committee report – Ending the scandal of Complacency October 08  stated that there is a degree of underreporting of serious accidents and that these are startling conclusions. If the degree of under reporting is as great as that suggested then the Government’s apparent success in reducing serious accidents and possibly deaths on the roads largely evaporates away.

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 according to the Transport Select Committee report – Ending the scandal of Complacency October 08. 

Overall, road accidents cost society around £18 billion per annum according to the Road Safety Foundation. Transferring freight to rail can 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 travelled2. 

On Page 8 item 10 congestion across modes is mentioned without reference to the significant amelioration of road congestion by shifting to rail. This document states that road congestion is highlighted as a key issue (ref P64) so it is important to spell out this benefit of rail freight as an average freight train can remove 50HGVs from our roads and an aggregates train can remove 120 HGVs.

Working with the industry today
Even though rail freight is privatized, supportive Government policy which demonstrates that the Government has confidence in the industry is vital if  industry is to have the confidence to invest in rail freight. Similarity, land use planning policy, which is the gift of Government, which allows rail freight terminals to gain permission and protects key rail corridors is key to increasing volumes being carried by rail. Therefore, we are pleased to see recognition of this in P9.item 14.

It is relevant to mention the energy efficiency of rail given the cost variations and scarcity of energy sources. Ref P9 item16

Climate change
Until all costs associated with each mode are internalised, it will remain difficult for the sustainable modes to compete with road and air freight. Ref P11

Research in May 2008 by Campaign for Better Transport stated that HGVs are only paying between one to two thirds of the costs they impose on society3. 

The latest research of January 2009 by Dutch consultants CE Delft on behalf of Transport& Environment on road freight  showed that:-
- CO2 emissions to grow 50% by 2030
- responsible for 20% of congestion
- twice as lethal as cars
- Lorries cause far more environmental damage and congestion than previously thought, and are twice as likely to kill than cars
- Carbon dioxide (CO2) emissions from European road freight are predicted to increase 54% by 2030
- found that lorries are responsible for 20% of road congestion in the EU, despite representing just 3% of road vehicles. 
 - Per kilometre driven, trucks were found to be responsible for twice the number of deaths caused by passenger cars.

The study undermines the road haulage industry's claim that lorries pay their full costs through existing taxes and charges.  It found that existing charges of around EUR 50bn only cover infrastructure costs. So-called 'external costs' such as pollution, congestion, noise and accidents are not covered.   

Safety P12
In recent years fatalities and serious casualties from road accidents have fallen significantly, including those involving HGVs.  However, TRL calculate that HGVs are involved in 18.3% of road accident fatalities while accounting for only 5.8% of vehicle traffic (2006). 

This overall average does not, however, take into account variations in the roads used by HGVs.  What matters is how dangerous HGVs really are compared to other road users on the same type of road.  Statistics do allow some analysis of this and the results are set out in table 2 on Page 8 of this report.

Because of this, it should be noted that the simple DfT leaflet4 describing some goods vehicle accident figures is misleading in this regard, giving an overall figure comparing HGVs with cars which does not allow for the lower level of accidents on motorways.  The true position is given in the full version of the statistics5 and the relative danger in terms of fatalities is given in Table 2 below, with other casualties set out in Table 3. HGVs are more than three times more likely to be involved in fatal accidents than cars on motorways.
See more detail on safety your ref P48

Freight on Rail fully supports the Sustainable Distribution Fund which represents an important mechanism for encouraging and supporting the shift to rail with all the economic, environmental and social benefits this brings. It also helps to compensate for the fact that road and air freight transport do not pay for all the external and congestion costs they impose on society. P13 item 24

National Policy Statements, which will create the over-arching national spatial planning framework, upon which the Independent Planning Commission will have to base their decisions, represent an opportunity to integrate land-use planning and transport policy. Freight on Rail believes that national policy statements offer a crucial opportunity to provide a national spatial planning framework to safeguard key rail routes and sites now, to avoid greater cost and inconvenience in the future. This debate is not just about disused rail lands, it also involves safeguarding transport corridors long term for rail and sites for rail freight terminals.Given that DaST has reducing carbon emissions while expanding the economy at its central themes, protection of rail corridors is key to delivering a low carbon economy in line with the Climate Change Act and its targets. The issue is about safeguarding where work by the industry and others as part of DaSTS or RUSs for example has identified potential need and options may be developed at some point in the future.  Ref P13 item 25
 
Limited changes to the dimensions of vehicles
Freight on Rail is disappointed with the Government decision to consider longer HGV trailers as any relative shift in favour of road transport runs contrary to development of the low carbon economy. While road and rail complement each other, larger trunk movements of freight can be more sustainably carried by rail than in larger lorries. Ref P14. Item 28

Chapter 2 Impacts of Freight and logistics
Congestion
Increasing speed limits for HGVs on single carriage way roads would have significant safety implications because of the forces involved, ie weight and speed implications of HGV traffic travelling faster. Ref P38 item 22 see chart 2 P 8 of this report which indicates that there are less fatalities from HGVs on A roads than motorways because of lower speeds.

Air Quality - Particulates
On the issue of tyres, it is clear that particulates caused by tyre wear and brake wear are a growing area of concern.  They are already significant, and will cause a rising proportion of particulates from road traffic as the Euro standards clean up engine exhausts.  In terms of Euro IV vehicles, tyre and brake particulates are greater in number than those produced by the engine. 

These, and other particulates, are then distributed into the local environment many times over through the action of the large moving wheels (this is sometimes referred to as re-suspension or re-entrainment).  The significance of this effect is only now becoming more widely understood.

Carbon dioxide emissions
Rail produces around 4 times less CO2 than road freight. Ref figure 2.4 P43

Transport is responsible for 28% of carbon dioxide emissions in UK6
HGV traffic has grown by 20% since 1990 with a the 14% rise in CO2 emissions7
HGVs are responsible for 20% of carbon dioixide emissions from all domestic transport.
92% of domestic transport emissions are from road modes, over 50% of which is from domestic cars, and road freight accounts for 8% of UK carbon dioxide emissions. Ref Freight Statistics ref P40

Freight on Rail research shows that official figures used in this report  underestimate the impact of HGVs. These lorries actually contribute almost a quarter of UK domestic transport emissions, (not 20% as preciously calculated), even though HGVs only represent 6% of miles travelled8, The accurate carbon footprint of HGVs could have significant policy implications making the case for rail - a low emissions, energy efficient, safer alternative to HGVs - even stronger. We believe that these figures also overestimate the impact of vans which should represent 13% not 15% of domestic transport emissions. The errors exist in the way emissions proportions are calculated and is explained below:-
The UK National Atmospheric Emissions Inventory (NAEI) is based on the total amount of fuel (petrol and diesel) used by transport.  This figure is fairly robust and provides a “top down” total. 

NAEI then produce another estimate, using a “bottom up” approach.  This calculates the fuel used by different vehicle types using traffic counts and fuel consumption figures.  For HGVs consumption is based on a survey, while for light goods vehicles, buses and coaches, this is based on manufacturers’ averages. The above process results in a figure which is often not the same as the top down total.  To adjust the figures so that they meet the correct national total, the amounts for the categories are factored up or down.

However, the factoring for non-car diesel use is only applied to the LDV and bus/coach categories, because the HGV estimate is held to be fixed.  This magnifies the impact of the adjustment factor and appears to have resulted in an underestimate of HGV carbon emissions, and an overestimate of LDV, bus and coach emissions.  This is important in the design of transport policies which seek to reduce carbon emissions.  For example, in 2006 this means that HGV emissions could be shown as 12% lower than they should be, with LDVs 16% too highA.  To illustrate the effect, graphs have been produced for LDVs and buses which show how the carbon emissions vary significantly and not in line with traffic.  This is particularly strong between 2004 and 2006.

For comparison, the HGV figures are better related to traffic, as shown below.

A. This is calculated by comparing the original 2005 figures (old method) which did not take the new HGV consumption figures into account, with the new method figures in the current NAEI spreadsheet.

Source for all the above charts: National Atmospheric Emissions Inventory 2006 website Databank

Further work should be undertaken to identify the precise extent of the variations, and, for example, figures produced which simply factored up all categories equally to meet the desired total on a consistent basis.

Safety
While we are pleased to see the improvement in casualty figures we would draw your attention to the fact that there is increasing evidence that that reporting and recording has changed recently and that the STATS19 data may not be giving a reliable picture, particulary of the trends in serious injuries. The Transport Select Committee report – Ending the scandal of Complacency October 08 highlighted that  there are a number of reasons to believe that the actual decline in serious injuries is not as great as that recorded in STATS19 statistics: Hospital data suggest that serious injuries are not falling. Studies have shown that there are about as twice as many casualties in road
accidents as there are reported to and by the police, and under-reporting for some types of vulnerable road users is very much higher. Ref P48

Comments from TWC’s inquiry
These are startling conclusions. If the degree of under reporting is as great as that suggested then the Government’s apparent success in reducing serious accidents and possibly deaths on the roads largely evaporates away.

What this means is that it should be recognised that the only really reliable road casualty statistic is the number of people killed. This is due to under-reporting and under-classification of injuries, as recognised on the Department for Transport website. 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 

Safety record of current sized HGVs
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.

Table 2: HGV traffic and fatal accidents by road type

Traffic in billion veh kms	HGV traffic	All motorised traffic	HGV %	% fatalities involving at least 1 HGV	Ratio of HGV to all motor vehicles
Motorway	12.1	99.2	12.2%	41.0%	336.0%
A	13.3	226	5.9%	17.2%	292.2%
B	3.7	181.1	2.0%	7.2%	352.6%

Sources for Tables 2 & 3: TSGB 2007, Goods Vehicle Statistics 2007, Goods Vehicle Accidents and Casualties 2007, all DfT

Chapter 3 Working with the industry today
P52 item 3.2 We welcome the fact that the DfT recognises certain modes do not pay for their external costs and appreciates measures such as grants taken to counter-act this imbalance. However, we believe that the fact that road and air do not pay for the full external costs imposed on society should be spelt out in this and other DfT reports. This transparent analysis  would make it easier to resolve these inequalities  as those involved would have to recognise these facts.

Impacts of road charging
a) 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.
The research, carried out by consultants MDS Transmodal in June 20079, assumed that road haulage would pay its full environmental and social costs through a distance charge scheme on all roads, with different charges for different types of road and different levels of congestion. The lowest charges would be on motorways, to encourage lorries to use these rather than local roads. The research found that:

• Some international freight would switch from South East England ports to those in Yorkshire & the Humber and the North East
• Rail freight would more than double and would grow to nearly a fifth of total freight (currently it's about 10%)
• The environmental costs of road freight would be tablilised

b) The Potential of Economic Incentives to Reduce CO2 Emissions from Goods Transport Paper prepared for the 1st International Transport Forum
on ‘Transport and Energy: the Challenge of Climate Change’
Leipzig, 28-30 May 2008 Professor Alan McKinnon shows how internalisation of costs would significantly increase sustainable mode share and reduce carbon emissions
Full application of the ‘polluter pays’ principle would raise the total tax burden on freight transport while radically redistributing it among the various transport modes. Several studies have estimated the extent to which the tax on each mode would have to rise to fully recover the marginal social costs (e.g. Maddison et al, 1996; Beuthe et al, 2002; INFRAS, 2004). The resulting increases in freight costs would be likely to dampen overall demand for freight transport and promote a shift to cleaner modes. It has been estimated, for example, that the internalisation of marginal social costs in the Belgian inter-urban freight sector would reduce total tonne-kms by around 4%, cut road’s share from 71% to 54% and raise the shares held by rail and waterways from, respectively, 16% to 21% and 13% to 24%. Total consumption of energy by all three modes would decline by a fifth (Beuthe et al. 2002).

Please can we emphasize that because road freight do not pay for all the external and congestion costs it imposes on society it is  difficult for rail to compete and justify long term investment unless there are supportive Government land-use and transport policies.

While the Appraisal system continues to treat the loss of tax revenues from fuel and VED as a disbenefit in cost benefit analysis of rail schemes, it makes it  difficult to justify rail projects ref P52 item 33. See also this report Page 1 items b)+c)

Providing a longer term planning framework
Land use planning policy, which is the gift of Government, which allows rail freight terminals to gain permission and protects key rail corridors is key to increasing volumes being carried by rail and thus meeting Government carbon dioxide emissions targets. That is why an overarching national spatial plan which provides the framework in which rail freight can prosper is crucial. This is turn will direct both regional and local spatial policy so that rail lands are safeguarded for future possible rail use and planning permission can be gained for interchanges.

We believe that the National Policy Statement (NPS) on national rail and road networks, one of twelve statutory NPSs, is capable of providing this vision, underpinned by data from the Government’s Delivering a Sustainable Transport System reports and Network Rail’s strategies. The issue is not hard safeguarding where need has been identified in principle and there is a firm option for a scheme – but safeguarding where work by the industry and others, as part of DaSTS and RUSs for example, has identified potential need and options may be developed at some point in the future.

Planning Policy Guidance (PPG13) powers must be retained 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 ever10. 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.

What is missing is the ability to safeguard corridors at a national level. The DfT stated that it was keeping an open mind on whether more specific use of these national safeguarding powers11 is desirable as its long term transport planning advances. DaST makes the point about the need for strategic long-term national planning but does not state what the mechanism for this might be. Freight on Rail urges the Government to have a framework allowing for strategic safeguarding of land for future rail use within its land use planning system. The rail White Paper rejected a ‘blanket approach’ to safeguarding railway lines and stations for the future; we are not suggesting a blanket approach, but a targeted one based on likely demand as seen by the various players in the rail industry and by local and regional authorities which would need to be underpinned by data from NR’s Route Utilisation Strategies and Route Enhancement Strategies. Ref P53  item 3.5

Detailed Rail Freight Planning Guidance
Freight on Rail and DfT have had extensive discussions about the need for detailed planning guidance for regional and local authorities leading to rail ministerial support from both Dereck Twigg MP and Tom Harris MP for such a document. However, due to changes in  Planning, this project was put on hold. Now, that the Planning Act has been passed, we ask that this important work is carried out. Freight on Rail would be pleased to assist in this process. We believe that detailed and clear guidance to regional and local authorities is necessary  The model of ‘Planning for freight on the inland Waterways’, written by the DfT in 2004 is an example of the type of document needed. With all the changes as a result of the Planning Act, detailed guidance is all the more needed by authorities.This will enable authorities to represent strategic rail interests locally and at Public Inquiries and Examinations in Public for schemes which do not fall within the IPC.
 
Rail Freight investments
Freight on Rail warmly welcomes the investments for the Joint Line and Shaftholme junction which are important enhancements to build a robust network. P55.

FFGs are an important mechanism for promoting rail freight and compensating for the lack of internalisation of road freight costs. FFGs are particularily important in offsetting the initial start up costs of the transfer to rail.

SFN
We thank the Government for its funding for the SRN which we fully support and ask that the Government carries on this funding in CP5 from 2014 onwards so that industry has the confidence to invest long term in rail freight.

The SFN priorities have been agreed by the rail freight industry.

Consideration of longer trailers
Freight on Rail is disappointed with the Government decision to consider longer HGV trailers as any relative shift in favour of road transport runs contrary to development of the low carbon economy. While road and rail complement each other, larger trunk movements of freight can be more sustainably carried by rail than in larger lorries. Ref P57.

Benefits of modal shift funding ref P59
Modal shift funding is crucial in compensating for the fact that road transport does not pay its full external and congestion costs.

Freight Facilities Grant
We welcome the government’s commitment to increase the budget of the Sustainable Distribution Fund; the budget for revenue grants is planned to increase from £20 million in 2007.8 to £24 million in 2010/11; the budget for capital grants will also increase from £4m to £14million over the same period and continue to grow subsequently if worthwhile schemes emerge.

The impact of MSB rates on FFG will need to be determined as examples are progressed.  Overall we would expect a positive outcome although individual cases may suffer particularly in city centres.

Given the current downturn, DfT needs to encourage companies to apply for FFG if budgets are to be used effectively. The RFG has suggested that a short term increase in the percentage of award could be announced (with an associated environmental benefits hurdle if required) to stimulate demand.   Rules relating to wagon / container etc purchase etc could be similarly relaxed. A response from DfT is awaited.

In the medium term FFG could be targeted at schemes with strategic importance, alongside the existing programme.  For example, terminals could be assisted in equipping for longer trains, particularly tied to the strategic freight network.   FFG could be used to assist in developing the rail elements of new terminals for domestic traffic – although there would need to be some modification to the scheme guidance in some cases.

Mode Shift Benefit Rates

Overall the new proposed MSB rates appear to be generally sound, and are likely to increase the assessed environment benefits associated with modal shift to rail.

The simplification of the road types appears sensible.  However there are a number of sections of motorway which appear anomalous – in particular, the M1 between junction 17 (M45 exit) and junction 19 (M6 exit) which is classed as low (although it is high congestion from 15 to 17), and M6 between 10a (where toll joins) and 15 which is again low.

The treatment of tax within NATA continues to be an issue and is clearly demonstrated here with a significant deduction on the MSB rates for tax effects (around 34p per mile).  Clearly this is not a matter to be resolved entirely within this assessment but across DfT.  It has been indicated that the NATA document which is due to be published shortly will indicate no change to the treatment of taxation which is disappointing if true. See separate references to this on P1.

There are a number of smaller issues which are unlikely to make any significant changes to the headline numbers but are worthy of note;

• The rates for climate change, and taxation are relatively flat by road type.  We understand that this is because the modelling cannot distinguish different levels of fuel use by congestion band, so a single band is used.  This is slightly anomalous as you would expect fuel consumption to worsen in congestion.
  
• The contribution for climate change is small – around 4p-5p per mile.  This is based on DEFRA values but we would have expected it to be more significant.
  
• The value of other effects is assessed at 10% of the weighted average of other factors for road, and 20% for rail. It is unclear why the percentage is greater for rail. 

Mode Shift Revenue Support

Overall the new draft MSRS rates are broadly encouraging.  The revised mode shift benefit rates make a good impact particularly on the domestic rates.

DfT are committed to revisiting a few assumptions on the basis of evidence provided – this will be undertaken quickly to enable submission to Brussels.  This is likely to include;

• Revisiting the productivity assumptions for high utilisation routes, as they appear to be too stringent particularly in the current climate.  A sliding scale over the 5 year period may be considered.
• Further evidence on specific items including road haulage figures, wagon leasing rates etc.

Once new rates are cleared, we will need to consider the impact on budget, hurdle rates etc.  There is no indication at this stage that there will be new specific issues arising.

The presentation of environmental benefits should show a value for each flow even if the rate is zero.  It is important to distinguish between flows where there is no benefit in modal switch, and those where there is a sizeable benefit but no grant is required.

The role of local government ref P60   
Freight on Rail was set up expressly to work with regional and local authorities to help them set the right planning framework because getting the right spatial planning structures, is crucial in order to get more freight onto rail.

Local and regional government shape the planning framework, within their borders, through Regional spatial strategies and Local Development frameworks (LDFs). So it is vital that regional and 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. The case of Mansard County Homes v Surrey Heath in 2002 shows councils countrywide that, with the strengthening of Planning Policy Guidance PPG13, they can protect disused railway land for future potential railway use, without fear of litigation if this land is identified in local transport plans even where there is no immediate evidence of future possible use.

We seek to encourage and help members and officers engage with terminal operators, local business and the logistics industry as well as existing rail freight customers and Network Rail. In addition to identifying what the major freight flows are, who the players are and what the rail infrastructure is, local authorities can push for industrial development to be sited near railways, promote expansion in existing rail-connected sites, and avoid factories not being rail connected, so that new and existing markets can be secured. We want it to be much easier for local authorities to be able to enter into partnerships with the rail freight industry to allow the commercial development of rail freight projects – for example, to part-fund connections, upgrades, terminals.

Freight on Rail does not underestimate the barriers to making a shift to rail, but believes by acting as a facilitator within the industry it can promote dialogue and help local authorities get hold of the information they need from Network Rail and the rail freight operators, such as detailed site information and flow forecasts, to help identify freight traffic which could be transferred to rail. 

If rail is to play its full role in building the low carbon economy, regions need to re-assess previous commitments in light of DaSTS otherwise legacy schemes from RFAs1+2 could leave little funding for rail schemes. DfT needs to define clearly methods of achieving CO2 reductions making it clear that tackling climate change is imperative and urgent and needs to be linked closely to social inclusions and quality of life. We urge the DfT to make sure that regions/local authorities give effective weight to a full range of options including modal shift and land use changes because of the urgency of reducing carbon emissions. Examples include promotion of/funding for interchanges. We welcome the fact that the (DfT) want regions to pay more attention to rail but highlight that the allocation of funds and resources to developing schemes will be important as many local authorities have dedicated staff to develop roads but not rail. It is important that there is early collaboration between DfT, Network Rail and authorities with clear guidance from DfT on rail schemes. 

RDC should be capable of being rail connected
DfT should direct that local authorities should only give planning permission to distribution parks which are rail connected or capable of being rail connected, given the need to reduce carbon dioxide emissions from freight.

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, particularly where they have significant bulk, waste or port traffic in their regions. This 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, as this is  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.

Meeting future challenges
In terms of options generation, Freight on Rail members are keen to  work closely with the Government to ensure that the right decisions are made for developing and extending the Strategic Freight Network and other enhancement projects. Ref P66 item 4.4

Climate change policy goal
4.6 As highlighted by the Stern report of 2006, it is an economic as well as environmental imperative to reduce carbon emissions so the policy to move more goods by modes with the lowest carbon dioxide emissions per tonne carried is crucial if the effects of climate change are to be avoided.

Important to highlight that rail produces between three to five less carbon dioxide per tonne carried than the equilavent road cargo, the actual figure is dependent on cargo. 
  
While the appraisal system continues to treat the loss of tax revenues from fuel and VED as a disbenefit in cost benefit analysis of rail schemes, it  is very difficult to justify rail projects. If the aims of DasT are to be met, a fairer appraisal system needs to be introduced. Ref P66 4.4

The targets adopted in the Climate Change Act show the importance of reducing carbon dioxide emissions. 

In the same way, it remains very difficult for sustainable modes to compete while road transport does not pay for the external and congestion costs it imposes on society. In fact, research by Campaign for Better Transport last May, showed that HGVs are only paying between one to two thirds of the costs they impose on society12.

See Page 9 item b of this report The Potential of Economic Incentives to Reduce CO2 Emissions from Goods Transport Paper prepared for the 1st International Transport Forum on ‘Transport and Energy: the Challenge of Climate Change’ Leipzig, 28-30 May 2008 Professor Alan McKinnon

Government has a key role in  making rail freight more accessible as well as the rail freight industry because, as mentioned before in detail on Page 1 a-c of this report, because road and air freight costs are not fully internalised ref P77 4.33

Because of these disadvantages to rail, and the consequent need to compensate sustainable modes in order to achieve a low carbon economy, it is crucial that the Government provides the right planning spatial framework at national, regional and local levels which safeguards key routes and sites for rail. Upgrades needed to the rail network to allow rail freight to play its full role in servicing the economy in a low carbon mode.

We welcome the Government’s commitment to the Strategic Rail Freight network SFN in CP4 and ask that the Government continues this vital support in CP5 from 2014 onwards which will be crucial in enabling third party funding to be forthcoming during CP5.

The rail freight industry has agreed its priorities with Network Rail which is supported by Freight on Rail.  

Reference are to the DfT Logistics Perspective unless stated as this report

 

Philippa Edmunds Freight on Rail  March 10th 2009
Email philippa@freightonrail.org.uk Tel 020 82419982

 

1. VOSA Effectiveness Report, 2007/8, Annex 1 http://www.vosa.gov.uk/vosacorp/repository/VOSA%202007-08%20Effectiveness%20report%20with%20links.pdf
2. Sources for Tables 2 & 3: TSGB 2007, Goods Vehicle Statistics 2007, Goods Vehicle Accidents and Casualties 2007, all DfT
3. Source Heavy Lorries do they pay for the damage they cause by MTRU and peer reviewed by Institute for Transport Studies LeedsApril 2008
4. Road Accident & Road Freight Statistics Factsheet No. 1 – 2008, DfT, September 2008
5. Road Freight Statistics 2007, Section 5, DfT 2008, + accompanying spreadsheets
6. When the emissions from refining petrol included
7. Carbon Pathways DfT 2008
8. Iain Knight Transport Research Laboratories Commercial Motor 17th July 2008
9. MDS Transmodal road pricing freight June 2007
10. Revised Planning Policy Guidance 13 of March 2001 Freight paragraph 45
11. DfT answers to TSC questions October 2008
12. Source Heavy Lorries do they pay for the damage they cause by MTRU and peer reviewed by Institute for Transport Studies Leeds   April 2008

 

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