Response to West Midlands Draft Regional Strategy Policy on Policy PA9

A We believe that when making provision for RLSs, they should be at least capable of being rail connected. That is new distribution parks, incapable of being connected to the rail network should not be planned or given planning permission, given the need to reduce carbon emissions from freight, unless they can be supported in the immediate vicinity by a rail connected terminal.

B We support the policy to identify existing or potential sites for rail connected interchanges with good road access. We would point out that it is often easier to expand existing rail connected interchanges than new ones so given the aim to increase freight carried by rail, it is important to encourage enlargement of existing sites as part of the policy.

i) Large SRFIs would be around 50 hectares or more, however there is a significant need for more medium sized and smaller terminals to be built if more freight is to be carried by rail. Therefore we do not believe that you should be prescriptive in your sizing policy.

ii) Agree that staff should be able to get to the site by public transport.
iii) Also sites should be capable of being rail connected to use rail freight, even if rail not used initially.
v) Environmental impact of sites can be minimized with proper design to reduce noise and light impacts as well as visual intrusion. Early consultation with local community is paramount too.

vi) Consult the rail freight industry to make sure that the specification is workable.

vii) Many terminals do need to operate 24/7.

C We believe that more than 150 hectares of land could be required in the WM where there is a significant shortage of rail connected interchanges. As well as large interchanges, there is a need for medium sized and small terminals.

D We believe that decisions about which terminals are brought forward for expansion or development should be market led and therefore we do not believe that a priority order suggested in the policy is advisable. We believe it is wrong for the RSS to be prioritizing one facility over another.

As previously mentioned, it is easier to expand existing rail freight terminals and we believe that this should be encouraged. Examples of successful expansion are Halls Hall and Daventry.
The viability of individual sites has to be evaluated by companies, location is key to their success.

7.46 We support promotion of rail connected sites which can support Government policy to reduce carbon emissions. Any redevelopment of sites such as the Drakelow Power Station must retain its ability to be rail connected.

The case for rail
1. Rail freight produces between three to five times less carbon emissions than road per tonne carried EWS 2007.

Emissions from HGVs are growing1
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 travelled2,

2. Congestion benefits of rail
An aggregates train can remove 120 HGVs from our roads

3. Safety benefits of rail

Safety comparison 1 rail passenger died during 2007.
2946 people died in road accidents during the same period - Transport Statistics 2007 & Office of Rail Regulation (rail figure excludes trespassers and suicides)

DfT research stated that because of their size and weight, when they are involved in accidents the level of injury tends to be higher; DfT statistics show that HGVS were twice as likely to be involved in fatal accidents as cars in 2007 – Road Statistics Traffic Speeds Chart 10 p 115 2007, issued July 2008

Philippa Edmunds 18th November 2008

1. HGVs traffic have grown 20% since 1990 resulting in a 14% rise in CO2 emissions - Carbon Pathways DfT 2008
2. Iain Knight Transport Research Laboratories Commercial Motor 17th July 2008