Sub National Review June 20th 2008

Freight on Rail is pleased to take part in this consultation.

1. Summary
It is important that sustainability and environmental duties are given priority for sustainable development. Economic growth should not come at the expense of the environment. Climate change and resource efficiency, which are significant drivers of change, need to be included.

We support the policy to make further progress on promoting sustainable growth as the Stern report made the point that it is an economic as well as environmental imperative that the effects of climate change are averted. If we wish to reduce the size of freight’s carbon footprint, the fast route to this is increasing rail freight.

The broader environmental benefits of rail freight need to be taken into account so that the framework does not simply look at economic development which means that SIRS must take into consideration the wider impacts of freight transport and the economic, environmental and social benefits of rail freight. It is important that a longer term view is taken of economic development which takes into account peak oil prices. Rail’s energy efficiency is becoming more important in the context of scarce and expensive energy as well as the security of supply issues. 

The IRS has a crucial role in giving clarity at regional level so that the private sector has the confidence to invest in rail freight.

It is planned that RDAs will have a more strategic role, working closely with the public and private sectors to prepare and implement an integrated single strategy for regions. In order to achieve this the new IRS needs to ensure that spatial planning is integrated with transport. The purpose of planning, apart from acting as arbiter between competing interests, is to promote sustainable forms of development (PPS1).

2. RDAs support for rail freight projects
We welcome the crucial role that the RDAs have played in promoting rail freight’s role in sustainable economic regeneration over recent years, in particular in promoting rail links to the ports, in line with the Eddington report recommendations.
Examples of which have been
The Northern Way and Yorkshire Forward contributions to key capacity and gauge projects in the north of England.
SEEDA has contributed to key gauge and capacity enhancements across the SE and links to other regions.
AWN has contributed towards enhancements from Southampton to West Midlands as well as SEEDA
AWN, EEDA and EMDA have supported gauge enhancements from Felixstowe.

EEDA is supporting further gauge work for improved links to and across the North of England.

3. Strategic Freight Network
We look forward to the RDAs paying a full role in enabling the Strategic Rail Freight Network to develop in order to provide a robust rail freight network with diversionary routes.

4. Rail freight offers a win/win distribution solution for the economy and the environment and has been a success story in recent years.

• 60% growth in tonne kms in past 10 years
• Surface market share now 12%

Environmental benefits of rail
Latest research from the rail freight operators, which will be issued officially shortly, shows that tonne for tonne carried, rail freight produces between three to five times less carbon dioxide, depending on the cargo, than road freight. Rail freight is also up to fifteen times better than road in terms of other noxious emissions.

Road congestion relief
An average freight train can remove 50 HGVs from our roads
An aggregates train can remove 120 HGVs from our roads – Network Rail

The value of rail freight to the economy needs to be fully taken into account in economic regeneration terms

Value of freight to the economy

How valuable are logistics jobs?
Dispatch clerks, warehouse pickers	£300 pw
HGV/truck operatives	£350 pw
Supervisory	£400 pw
Call centre operators	£278 pw
Main logistics positions needs skills including IT

Source Midlands Logistics Study MDS Transmodal Regeneris 2005

Economic Regeneration opportunities from rail freight

		Direct	Indirect	Size (HA)
•	DIRFT existing	2595		180
•	Howbury Park proposed	2670	2668	67
•	Port Salford proposed	1950	195	116
•	Trafford proposed	4981	2105	136
•	Parkside proposed	7000	1000	147
•	Radlett    proposed	3257		100
•	Teesport	2000	3000

5. The role of Local Authorities
The challenge will be for local government to ensure that it is well-positioned to take on the role and provide the necessary resources, skills and capacity to implement the new agenda in an environment where councils will be the only local democratically accountable body.  However, these additional responsibilities at sub regional and local authority levels will require extra funding from central government.

P9 Therefore we question the comment which states that the new arrangements should not include any additional council tax precept and not impose additional net costs on local authorities. Local authorities must decide on the details of the forums which must be representative of local government across the regions.

We understand that the assembly scrutiny responsibilities pass to local government in each region. The RDAs are expected to become more strategic, programme management bodies devolving the delivery of economic development to local authorities. There is a question about objectivity of a local authority in its scrutiny role, when it may be trying to get funding from the RDA. Therefore, there needs to be safeguards.       

As well as the statutory duty to promote economic development, local authorities should have a duty to bring forward policies which reduce carbon emissions. Any specification of board membership should include the environment as a core competency.

6. Stakeholder Engagement
The executive summary states that RDAs place a premium on effective stakeholder engagement. The Regional Assemblies have been accessible to Freight on Rail and its members and we look forward to working with the RDAs. We believe that this is important so the rail freight industry can input into regional strategies so that the right policies are enshrined in IRS to ensure that rail freight can play its full role in the Government’s policies of reducing carbon dioxide emissions from freight and reducing road congestion.  

Freight on Rail believes that by consulting rail freight interests from the start of IRS process its members will be able to advise on rail freight matters. We believe that involving partners from the trade union movement, environmental NGOs, local community groups, as well as the rail freight industry, from the start is crucial. Therefore, RDAs must be accessible like the Regional Assemblies have been to stakeholders including environmentalists, TUC and local community groups.

It is intended that SIRS will be owned by the region, rather than by RDAs which will undertake the role of Executive Coordination, and that this can be achieved by using the expertise within partner organisations during developing the strategy and implementation plan.

Partners need to be involved in decision making process from the start of process therefore local authorities need to be involved in writing IRS from the beginning rather than just having scrutiny powers.

7.  Forum of leaders
The model of the regional transport boards has proved to be effective with partnerships comprising representatives from the assembly, RDAs, NGOs and trade unions, and other regional organisations. A joint delivery plan as part of the IRS is needed to provide the certainty and clarity about investment that are critical to creating confidence among private sector infrastructure investors.

Transport partnership worked best where stakeholders add weight and partners were involved in decision making process. Any basis for sub-regional arrangements should include sustainable economic development not simply economic development and as such we understand that MAAs will be an important part of this process

We believe that it is important that local authorities choose reducing carbon emissions as one of their LAA indictors, given that rail freight produces between three and five times less carbon dioxide emissions than road per tonne carried.

 
8. Collaboration across sub-regions
We believe that this area could present serious challenges and would like to see more detailed plans of how working across local authorities to create sub regional partnerships, is envisaged and what the mechanisms would be.

 
9. Regional Funding Allocations
We support this method of funding

10. Transition
We welcome the announcement that existing RSSs will be adopted by the Secretary of State with further reviews where necessary to re-examine planned housing provision. In general terms, the RSSs have given strong strategic policy guidance to promote rail freight which enables local authorities in turn to safeguard sites for terminals and rail alignments in LDFs. Without strong regional policies supporting rail freight, rail freight terminals cannot get planning permission which means that freight cannot be transferred to rail, nor can rail alignments and transport corridors be protected in Local Development Frameworks.

11.The importance of Long Term Spatial Planning at national, regional and local levels

National policy is important as it provides over arching policy framework for regional and local strategies.

In order for there to be sustainable economic growth the right policies need to be in place at all levels to set the framework, ie at national, regional, sub regional and local levels. The right national policies are paramount so that these policies can cascade down and inform regional and local policies. This is crucial in the context of planning as planning permission for land usage is predominantly given at a local level by local authorities.    Large scale projects will be handled by the Planning Commission but for medium and small rail freight terminals planning permission will be granted by local authorities unless they go to public inquiries. This means that unless there is strong national and regional and possibly sub-region policy, it can be difficult for councillors to give planning permission for terminals. We believe that local authorities should have a duty to take into account the National Policy statements for National Networks and Ports when making planning decisions at a local level.

Regional spatial planning needs to direct local authorities to protect key sites, rail alignments and transport corridors for both existing and disused rail lands.

The importance of spatial planning must be recognised with the new integrated strategy which must fully integrate transport and land use planning in order to set the right spatial planning framework which reflects Government policies on sustainable economic growth. Therefore the RDAs need to be resourced to provide this planning expertise.

RDAs should have powers to safeguard strategic land for terminals and for transport corridors at a regional level for future rail use in a similar way to the PPG13 safeguarding powers at the local level.

We would like to point out that we believe that national government has an important role in protecting strategic land for terminals and for transport corridors.

The wider issues of the need to safeguard land for future rail use which has previously not been rail land
This is not just about disused alignments: it also involves sites (that is, sites not already owned by Network Rail or BRB’s residuary body, which would be automatically covered by permitted development rights) for rail freight terminals or possible new stations to serve new developments. At present, safeguarding is left entirely to local authorities through planning guidance note PPG13, but this only covers disused alignments, not other land for rail use, and there is no framework whereby Government can give guidance to local planning authorities about likely future rail needs. For example, new housing development and projects such as eco-towns may justify or indeed require new rail facilities in the future as the best value in terms of achieving access to those developments and avoid them generating significant local traffic congestion or increased CO2 emissions from them.

There are also issues of long term capacity – if the Government is serious about doubling the capacity of the network over 30 years, this will require new/reopened lines and stations, as Ministers have recognised.  

We think it therefore makes sense to provide a planning framework to allow for safeguard of key routes and sites now, to avoid greater cost and inconvenience in the future.

We understand that the Department for Transport (DfT) is examining the merits of protecting strategic transport routes for rail at a national level.  Currently the Highways Agency has powers for this type of protection but we believe that it is vital that there are similar powers for rail corridor protection both at national and regional levels, if rail is to play its full role in reducing carbon dioxide emissions from transport. An recent example of where protecting key strategic rail routes is paramount, is through the Woodhead tunnel which offers an existing rail solution on a congested transport corridor across the Pennines. Freight on Rail will be pleased to take part in any analysis of routes and sites for interchanges/terminals which warrant protection.

PPG13 Freight safeguarding policies must be preserved in Planning Statement Revisions
PPG13 policies which allow local authorities to protect potential and disused rail alignments and sites for possible future rail use are crucial if rail is to be able to play its full role in reducing carbon dioxide emissions from freight transport.  Therefore we ask that these PPG13 safeguarding policies are retained in the forthcoming revisions of planning policy statements and guidance. Unlike passenger services which are specified by the Government, freight has no franchise agreements: this makes PPG13 all the more key to set the parameters for rail freight.

Importance of Regional Strategies in promoting low carbon sustainable freight distribution
In order for rail freight to play its role in reducing emissions planning permission for terminals is needed and it is difficult to get getting planning permission for small to medium sized terminals. Changes to Planning policy with the implementation of the Planning Commission will mean that it is easier to justify large rail freight interchanges of 60 hectares and over. However, if planning permission is to be obtained for small to medium sized terminals, strong regional policy will play a crucial role in getting permission passed because there is a need for the wider regional and national benefits of rail freight to be made so that planning permission can be obtained for terminals. Strong support for rail freight in the Freight Strategies and Regional Spatial Strategy has helped councillors justify giving planning permission for terminals where there is local opposition because of also local disbenefits as well as the wider regional and national benefits from a terminal.

The Planning Bill recognises the importance of Strategic Rail Freight Interchanges (SRFIs) in the context of economic regeneration.

We note that increased housing provision will necessitate more freight distribution in a low carbon mode.

12. Cross regional collaboration is crucial
Regions need to carry on working together to write strategies
For example, rail freight needs cross regional policies to be aligned as the majority of rail freight flows are cross regional.

13. EIP
Retention of rigorous EIP procedures is important as the existing procedures have been able to test the robustness of regional strategies.

14. Consultation periods
4.21 Periods of consultation should not be shortened from current lengths.

15. Independent panel
4.23 We ask who the independent panel would be made up of?

16. Devolving transport decisions
In terms of heavy rail decisions, we believe that these decisions should not be devolved and understand from the DfT that it is not intending to devolve heavy rail decisions.

17. Freight on Rail explanation
Freight on Rail is a campaign working to get goods off roads and onto rail as an important step in developing a more sustainable distribution system.
 

Freight on Rail is a partnership between transport trades unions, rail freight industry and Transport 2000.  It works to promote the economic, social and environmental benefits of rail freight both nationally and locally. It advocates policy changes that support the shift to rail and provides information and help on freight related issues. In particular, it aims to help local authorities through all stages of the process such as planning a rail freight strategy, accessing grants and dealing with technical matters.

The members are as follows: - Rail Freight Group, Direct Rail Services, EWS, Freightliner,    RMT, ASLEF, TSSA, UNITE and Campaign for Better Transport

Philippa Edmunds  20th June Freight on Rail email philippa@freightonrail.org.uk