Reviewing the London Plan February 2006

Freight on Rail would like to thank the Mayor for the opportunity to comment at this stage before the formal consultation process. We would also like to state that we support many of the policies in the London Plan relating to transport and freight and are pleased to take part in enhancing the Plan.

Freight on Rail definition
Freight on Rail, a partnership between transport trades unions, the rail freight industry and Transport 2000, works to promote the economic, social and environmental benefits of rail freight both nationally and locally. In particular it works with regional and local authorities advocating policy changes that support the shift to rail and provides related information and help.

Comments on Statement of Intent

Introduction

Freight on Rail would like to highlight that rail freight, which produces 90 per cent less carbon dioxide than road transport tonne for tonne carriedi, has a crucial contribution to make in tackling climate change, identified in this revision as a key issue that London has to resolve.

Freight Transport: Average emissions in grams per tonne-kilometreii

Mode	PM10	CO	NOx	CO2	VOC
Rail	0.004	0.032	0.31	15	0.021
HGV	0.048	0.33	1.74	180	0.15

Key: PM10 particulate matter of less than 10 microns; CO carbon monoxide; Nox oxides of nitrogen; CO2 Carbon dioxide- the principal green house gas; VOC volatile organic compounds.

Freight on Rail supports the mayor’s intention in 4.i Page 1 to strengthen the GLA input to future government spending review on transport.

4.ii Part 2 In order to mitigate road congestion and air pollution it is important that key growth areas such as the Thames Gateway can be served by rail freight both in terms of construction and ongoing distribution needs. Planned expansion at Thames Gateway Port, formally known as Shellhaven, would benefit from enhanced rail freight capacity and capability.

4v Page 2 and part 1 – Progress and Implmentation12/13 Page 5 .Freight on Rail believes that spatial planning and transport planning need to be integrated in order for London to meet its aspirations.

Implementation Page 6 20

Freight on Rail believes that rail use should be specifically identified not left as other uses alongside protecting the strategically essential stock, including the need to retain industrial land for waste, recycling and other uses
Suitable sites for rail freight terminals both large and small are scarce and as such need to be protected alongside the railways.

44. Page 13

Thames Gateway port is important for this area. Rail freight is well placed to serve the port and thus reduce emissions and road congestion.

Environmental Imperative Climate change P16

See table in introduction which shows the environmental benefits of rail freight.

Spatial Implications page 20

It is crucial that spatial planning policies in the London Plan, the Sub Regional Development Frameworks (SRDF), Local Development Frameworks (LDF) and Local Implementation Plans (LIP) all support the shift to rail freight so that planning permission can be obtained at appropriate sites. There are considerable other pressures for land usage in London on brownfield sites, making it vital that suitable sites beside the railway are protected by Greater London policy and at local levels.

The London rail freight study

The London Rail Freight Study was commissioned by the London Sustainable Distribution Partnership (LSDP) to develop an action plan to move more freight by rail. The LSDP, of which Freight on Rail is an active member, was set up as part of the GLA Transport Strategy, to get more of the capital’s freight off its congested road network.

P25 89

This section mentions the importance of effective use of scarce resources, including transport infrastructure.

P25

Objective 2

Rail freight has an important role in making London a better city for people to live in.

To relieve road congestion

An average intermodal freight train can remove 80 HGVs from our roads – Freightliner

Rail freight, can reduce road congestion which according to the UK Government is set to grow by up to 37 per cent by 2010.

To offer an alternative to other issues facing road transport

Road congestion is causing extended and less predictable journey times.
Existing driver vacancies 47,000 with the average HGV driver age now 55.
Working Time Directive is estimated to require another 30,000 and to cost the road freight industry an extra £1 billion per annum.
Taxation by distance and tougher emissions regulations on the agenda.

“Rail will have to play a significant future role in moving cargo out of the British ports. … As an industry we need all the rail freight we can get.” Jens Holger Niesen MD Maersk Sealand 2004

“Rail to and from the UK’s major ports is proving more reliable than road. Dedicated K&N rail services from Southampton and Felixstowe are recording 95% reliability levels, compared with ‘low-mid 80%’ for comparable road haulage”. Peter Ulber, Chief Exec. Kuenhe & Nagel 2005

To reduce road maintenance costs

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 research suggests that certain local authorities, particularly where they have significant bulk, waste or port traffic in their regions, could reduce these costs on local roads by transferring to rail.

P27 Climate Change

No mention is made of the benefits of a shift to rail freight.

Page 28/29

Rail freight’s potential to transport construction materials to service London’s economy is not mentioned, nor are the benefits of transporting products by rail mentioned. Similarly the ability of rail to remove industrial waste.

Page 32 Transport

We support the proposal to strengthen measures to reduce CO2 emissions including modal shift. (see table in introduction illustrating rail freight’s strong record on reducing pollution).

We have already highlighted the environmental and economic benefits of rail freight including the possible savings on road maintenance that transfer to rail provides.

We would also like to highlight the acknowledged safety benefits of rail freight over road freight transportation.

650 pedestrians were killed or seriously injured by HGVs and LGVs in 2003 - Transport Statistics Great Britain, 2004 Edition, DfT 2005

There were 28,864 accidents involving HGVs and LGVs in 2003: 9,958 HGV and LGV drivers and passengers were injured in 2003: 2,474 pedestrians were hit by HGVs and LGVs in 2003: 1,194 HGV and LGV drivers and passengers were killed or seriously injured in 2003 – Road Accident Statistics Great Britain, 2004 Edition, DfT

Improve access in order to support London’s economy

Freight on Rail’s position is that we support Crossrail in principal. It is an exciting transport project which provides a great opportunity to improve trains services in a congested part of the national network. However the Crossrail Bill as currently drafted, could represent a significant threat to the existing passenger and freight services on the busy Great Eastern and Great Western main lines. As Freight on Rail has maintained all along there are workable solutions to resolve these issues. These include (i) the upgrading of alternative routes (where available for freight) ii) the provision of additional tracks on the surface lines of the proposed Crossrail route, iii) the adoption of a Crossrail timetable that allows all users to have their fair shares of capacity, (iv) appropriate protection or relocation of rail freight terminals affected by the scheme. We believe that the Crossrail project must be properly specified and funded in a way that it does not damage existing and forecasted traffic. The rail freight industry needs to feel that the Government is committed long-term to rail freight in order to make long- term investment decisions.

With regard to the Olympic Games Freight on Rail members are working with other stakeholders to ensure that rail freight interests in the build up to and during the Games are protected. Further, rail freight could play a significant role in delivering the construction materials required for such a large development.

It is likely that rail enhancements will be required to ensure freight requirements can be delivered alongside passenger requirements in such projects, and in TfLs corridor plans. There are likely to be synergies between the work required in the various projects and we would expect that these can be exploited.

Planning for the new housing developments, such as the Thames Gateway, will need to take account of freight distribution needs. This should allow for the provision of rail freight terminals and increased rail freight capacity on the rail network to maximise the benefits of sustainable distribution.

Heat generating transport uses

We need to ensure that as rails are replaced, bridges strengthened for freight, or roads resurfaced that they are built to withstand the temperatures they will experience during their design life. Likewise, rolling stock also needs to be able to withstand the temperatures it will experience.

As rails are replaced, bridges strengthened for freight etc. they enable the maximum capacity of freight train possible to run, considering gauge, length, route availability etc.

Further Strengthen public transport

In terms of both rail freight capacity/capability on the network and provision of suitable sites for rail freight terminals, the London Sustainable Distribution Partnership, set up by the Mayor, has commissioned research to address both aspects of increasing rail’s share of the freight market.

Freight on Rail supports the findings of the TfL Rail freight study which highlighted the following points in June 2003

TfL Rail Freight Study

TfL and GLA study of 2003 showed that the main prospects for rail freight growth in London are in the following sectors:-

Quarried aggregates
Freight through wharves, chiefly aggregates
Cement and building materials
Municipal waste,
Cross channel flows of consumer goods

The report also highlighted the main mechanisms for realising this move to rail are as follows:

Safeguard capacity on West London Line for freight subject to diversion of some trains via Kew Bridge if that route is upgraded/electrified;we note that the Channel Tunnel usage agreement protects a number of paths on this corridor

Upgrade key parts of the London rail network (the Tottenham and Hampstead line between Barking and Gospel Oak and the Clapham Junction – Kew Bridge – Wembley route) to take more freight, particularly intermodal;

Urgently promote at least one major rail intermodal terminal and safeguard sites for others;

promote waste strategies using rail to landfill or incinerator, particularly in South London;

Planning policy should encourage rail connected sites for distribution and industrial development;

Promote more rail connections to PLA terminals, particularly in the Thurrock area and along the north bank of the Thames between Barking and Tilbury;

Please note that the industry expects significant growth in intermodal traffic passing through London from the Haven ports and Shell Haven.

AEA Technology Rail carried out a report on the development of sites in and around London as rail freight terminals which highlighted important rail connected sites to be protected.

Freight on Rail would point out that there is significant demand for small terminals for bulk cargoes such as aggregates and other construction materials. This is reliably and credibly forecast to rise steadily and will increase by 20 per cent over ten year, giving rise to a need to more railheads. Rail is well-placed to move these materials (which are vital for the continued maintenance and reconstruction of London) and to keep them off the roads. The issue is that there is already a shortage of suitable sites and this will become more acute unless spatial planners act. The rail freight operators and its customers are confronted by this problem in London more than anywhere else and is probably their our top priority for action by TfL and the GLA

Freight on Rail would also stress the importance of land use planning policies at all levels supporting the shift to rail freight. This means that in addition to the London Plan supporting rail freight, all levels of policies including Sub Regional Development Frameworks, the Local Development Frameworks and Local Implementation Plans must support and where appropriate as in the case of Local Development Frameworks specify actual sites to be protected for rail use. PPG13 states that transport lands can be protected for future possible transport use, even if there is no known current transport use as long as the lands are identified in Local Plans and Local Development Frameworks as such.

This is crucial because of other pressures for scarce land in the Greater London Area.

Planning decisions are normally made at a local level and in order for members to support applications for rail freight terminals, where there is often local opposition, members need to be able to promote the wider regional and national benefits of such a facility making the case using policies such as the London Plan and pointing to designed protected transport land in the local plan.

We support measures to make more efficient use of capacity on the existing rail network. It is important to highlight also the importance of protecting existing and forecast freight paths on the network in and around London. In particular on the North London, the Gospel Oak to Barking and the West London lines, where there are conflicting pressures between freight and passenger services.

Freight on Rail supports the development of these routes to meet the requirements of both freight and passenger growth. (Such developments could include measures such as longer trains as well as infrastructure development.) Loss of freight capacity could force trainloads of freight back onto the congested road network, would have severe implications both for London and the nation.

With reference to the penultimate paragraph on P33,

A) Extensive research has been carried out by TfL on the capacity constraints on these lines in particular so now a commitment is needed to funding the enhancements needed.

b) There is a need for more single user and shared-user rail freight terminals in the region including bulk and intermodal terminals. Suitable locations are scarce and need to be protected. There is an urgent need to establish more construction materials railheads and these needs to be included in the policy. We support the SRA Strategic Rail Freight Interchange Policy findings that 3-4 strategic rail freight interchanges are needed in the London area.

Cricklewood represents possibly the only suitable strategic site for a shared user rail-served warehouse and a waste-transfer station in North London and is therefore of national strategic importance.

Research carried out for TfL by AEA Technology identified key sites for rail freight terminals which should be

P34 London’s Geography including the Sub regions and inter-regional issues

It is crucial that spatial planning policies in the London Plan, the Sub Regional Development Frameworks (SRDF), Local Development Frameworks (LDF) and Local Implementation Plans (LIP) all support the shift to rail freight so that planning permission can be obtained at appropriate sites. There are considerable other pressures for land usage in London on brownfield sites, making it vital that suitable sites beside the railway, which may or may not be existing rail land, are protected by Greater London policy and at local levels, because of their scarcity.

The large developments which the SRA Interchange policy encourages need to be included in the London Plan and also the TfL Freight strategy so that the London boroughs are able to give planning permission for facilities which are beneficial to the region and nation but may have local opposition. The London Plan and TfL Freight Strategy show the wider environmental benefits of such developments.

The final bullet point covering waste management should recognise rail freight potential to remove different kinds of waste, such as industrial and domestic. Rail is well placed to remove recycled domestic waste and currently removes large quantities of waste for West London and North London Waste Authorities.

P36

As previously mentioned rail freight’s economic environmental and social benefits are important factors when analysing the quality of life issues for Londoners

As our introduction on rail freight highlights rail freight can help reduce road traffic congestion, produces 90 per cent less carbon dioxide tonne for tonne carried than road transport and is a safer method of distribution and is a safer method of distribution.

Comments on the current London Plan

Under Freight Strategy

Policy 3C.24

Freight on Rail would like to state that we support the existing policy.

Policy 3C.25 Strategic Rail Intermodal Freight Facilities

We welcome the Mayor’s support for intermodal freight facilities and point out that this policy must also be stated in the Mayor’ Freight Strategy. We also believe that the Mayor should give directions to the boroughs where possible to support such facilities.

We also ask that the Mayor supports the need for additional smaller rail freight terminals both for bulk and intermodal traffic which can be both single user or shared facilities.

Page 37 Olympic Games

With regard to the Olympic Games Freight on Rail members are working with other stakeholders to ensure that rail freight interests in the build up to and during the Games are protected. Rail freight customers need to be confident now when they are making long-term investment decisions, that services will not suffer.

Philippa Edmunds
Freight on Rail Campaigner
Email philippa@freightonrail.org.uk
Tel 020 8241 9982

i. AEA Technology for SRA November 2004
ii. SRA February 2005