Freight on Rail response to Delivering a Sustainable Transport SystemThank you for the opportunity to comment. The response starts with answers to the consultation questions followed by comments on the main report. DaSTS Consultation 3 The challenges The three most important themes are:- Theme 10 Quality of life theme 1 Incentivisation to achieve climate change outcomes 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. 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. 4 The networks We appreciate the Government funding for the SRN in CP4, which has given the industry the confidence to invest in rail freight so that third party funding has been forthcoming. We ask that the Government continues to support Strategic Rail Freight Network in CP5 from 2014 onwards. DaSTS and the new Planning Act offer an opportunity to integrate land use and transport planning. 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. 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. 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 powers2 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. We believe that local authorities and public inquiries should have to take NPSs, which will be statutory documents, into account. 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. 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. Quality of life and the importance of end to end journeys are not mentioned. Corridor planning should systematically map all the challenges on the corridors and gateways to ensure that options generated address all of them. The appraisal system gives priority to time savings, which can be minor, but infact reliability is more important to business. 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/cityregion and local level must be set out. We question whether the current regional structures are resourced to be able to lead on the development of solutions for city and regional networks. FoR and its members will be pleased to take part in the stakeholder involvement in the corridor studies. We believe that the potential for and benefits of mode shift are underplayed in the London-Manchester corridor .
Detailed comments on main report Rail freight, which delivers freight in a low carbon safe way, is well placed to help the Government meet its twin challenges of sustaining a prosperous and growing economy and achieving its challenging emissions and reductions 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. P8 item 8 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. For example, we believe that regional and local authorities should require that RDCs either be rail connected or capable of being connected in order to be given planning permission. Item 9 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:- a) that road does not pay for the external and congestion costs it imposes on society Planning for uncertainty Tackle Climate change 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 high5. 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. 1. 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.
For comparison, the HGV figures are better related to traffic, as shown below. 
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. P14 Safety comparison - 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. P50 2.37 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
Source: VOSA 20085[iii] 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 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 P15 item 1.17 Whilst 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. 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. This chart below shows relative safety on different types of roads Table 2: HGV traffic and fatal accidents by road type
Sources for Tables 2 & 3: TSGB 2007, Goods Vehicle Statistics 2007, Goods Vehicle Accidents and Casualties 2007, all DfT These figures show not only that existing sized HGVs have safety implications but also highlights that increasing lorry sizes to 25 metres would introduce even more risk to other road users, which is an example of safety implications of wider policy decisions. So we urge the Government to resist any attempts by the European Commission to try and force through policies which would mean that LHVs came to the UK by default from the continent. Chapter 2 Delivering on climate change and growth Were this to take place, more sustainable modes such as rail would increase their market share The Potential of Economic Incentives to Reduce CO2 Emissions from Goods Transport Paper prepared for the 1st International Transport Forum
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. P21Item 2.15 Item 2.17 Government support for the SFN and other enhancements projects is key in bringing in third party funding for upgrades of the rail network. Chapter 3 Planning for Uncertainty Rail is far more energy efficient than road and air and this is a key consideration with price variations and unreliability of oil sources which make rail an attractive option. P27 Chapter 4 The national Framework The large strategic rail freight interchanges (SRFIs), sized 60 hectares and above, will come under the Infrastructure Planning Commission. However, the difficulties of getting planning permission for medium sized and small terminals remain so the right land use planning policies nationally, regionally and locally are crucial. Councillors and inspectors at Public Inquiries need to be able to draw on supportive national policy, for example NPSs, and regional policies which show the wider regional and national benefits of rail freight, in order to justify permission for terminals, which are often opposed locally. Therefore we believe that it is crucial that local authorities and public inquiries should have to take NPSs into account when making local planning decisions. Without planning permission for interchanges more freight cannot be shifted to rail. The on-going importance of regional spatial planning must also be enshrined in the new integrated regional strategies, part of the Government’s Sub National Review. Planning Policy. P35 International gateways and freight 4.23Working with the industry today a) 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. b) The way NATA handles time savings does not give enough weight to journey time savings on longer journeys or reliability. Congestion relief of rail freight Detailed Rail Freight Planning Guidance
Philippa Edmunds Freight on Rail Campaigner February 2009 |
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