London Plan Further Alterations December 2006

The members are as follows: - Rail Freight Group, EWS, Freightliner, RMT, ASLEF, TSSA, AMICUS, Network Rail and Transport 2000

 
Chapter 3C
Policy 3C.4 Land for transport

Freight on Rail believes that the London Plan should state that rail lands should be protected even where there is no evidence of future possible use because, as shown with the disposal of avoiding lines, economic factors change so it is critical to safeguard rail lands for future possible use. Once rail lands are gone, they are gone for ever to the railways and society. The judgment in the case of  Mansard County Homes Ltd v Surrey Heath Council 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 as long as the sites are protected in their Local Development Frameworks.

One of the factors is that there are a limited number of sites which have the right criteria to be viable for rail freight facilitities making it all the more crucial that the ones that are suitable are safeguarded. 

 
PPG13 states that

Identify and, where appropriate, protect sites and routes, both existing and potential, which could be critical in developing infrastructure for the movement of freight (such as major freight interchanges including facilities allowing road to rail transfer or for water transport) and ensure that any such disused transport sites and routes are not unnecessarily severed by new development or transport infrastructure. In relation to rail use, this should be done in liaison with the SRA which is best placed to advise on the sites and routes that are important to delivering wider transport objectives;

It is vital that the GLA guidance to the London boroughs directs them to protect such sites.

 
Policy 3.168 does recognize the need to protect land for transport purposes. Neither passenger or freight rail is mentioned in this context which we believe is unhelpful.

 
Policy 3.168i Freight on Rail believes that before any transport land is released it is crucial, in the absence of a rail agency, that the following organizations are contacted for their views:-

Dft Rail Directorate rail freight section

Rail Freight Group

All the rail freight operators

Network Rail

Freight on Rail

It is hard to comment further as the Supplementary Planning Guidance on Land for Transport functions has not formally been issued since the consultation in May 2006.

 
Policy 3.183i While we support improved passenger services on London Overground, increased passenger services must not adversely effect rail freight services. We support the commitment made in TfL Rail2025 that plans for enhanced services ‘should have no adverse impacts on freight’. Future rail freight forecasts for growth as well as existing traffic will have to be factored in to all calculations and proposals if existing and potential rail freight services are to be protected. We recognise that rail infrastructure enhancements benefit both passenger and freight services.

Capacity and capability improvements to the Gospel Oak to Barking line will provide diversionary routes for freight to relieve pressure on routes such as the North London Line via Stratford.

 
Policy 3C11 in principle we support the Crossrail project and its aims to provide additional capacity and short journey times on London’s rail network. However we cannot support the project if it reduces rail freight paths on the GE and GW as this would do great harm to the rail freight industry, to those businesses that rely on rail to move their freight and to the wider community. It will force trainloads of freight off the railways onto the congested road network with all the adverse economic1 and environmental2 consequences.

 
Policy 3C.24

We support the policy to ensure that suitable sites and facilities are made available to enable the transfer of freight to rail through the protection of existing sites and the provision of new sites.
We would ask that the GLA gives guidance to the London boroughs that they should protect suitable sites in their Local Development Frameworks (LDFs) otherwise the sites will be used for non rail purposes. It is the planning system at the GLA level and local levels via LDFs  which protect rail lands including sites for rail freight sidings and rail alignments.

 
Policy 3.215

It is vital that the development of national rail routes which can relieve London of some rail freight traffic include capacity upgrades as well as capability enhancements otherwise the rail freight operators will not be able to offer customers the service they require.

 
Policy 3C25 Strategic Rail Intermodal Freight Facilities

We support this policy

Policy 3.218 We support this policy and would add that PPG13 is important to allow local authorities to protect sites through their LDFs even where there is no future potential rail use identified. Please refer to my comments under policy 3C.4 for details on PPG13 relating to site protection.
 

Philippa Edmunds   Freight on Rail Campaigner
15th December 2006
Email Philippa@freightonrail.org.uk;
Telephone 020 8241 9982
 
joined Freight on Rail in July 2006