Consultation on Land for Transport functions Draft Supplementary Planning Guidance

1. Freight on Rail is pleased to respond to this consultation.
2. Definition of Freight on Rail.
   
   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, EWS, Freightliner, RMT, ASLEF, TSSA, Network Rail and Transport 2000

1. Comments on Draft SPG
   
   The SRA had strong mandate for, and knowledge in, rail freight issues and as such was able to give clear guidance and support for protection of particular land sites. DfT Rail does not share this role to the same extent and is therefore less likely to be able to comment on particular issues. Freight on Rail therefore welcomes the writing of the London Rail Freight strategy. This will include detailed work commissioned by TfL to establish the viability of a range of sites including the planning implications across London for rail freight facilities.
   
   As such, consultation should be broadened to include bodies such as Network Rail, RFG, Freight on Rail or the freight operating companies.  The document should make clear that Boroughs should expect to consult such parties where necessary.
   
   Freight on Rail has also been asking the DfT to produce detailed rail freight guidance for transport and land use planners in regional and local authorities, developers and the industry which would go some way to filling the gap left with the loss of the SRA  in the cases of local planning applications and Public Inquiries and Examinations in Public. We understand that the Department has said in principle that it will produce detailed rail freight guidance outlining Government planning and transport policy and the new structures of the rail industry.

Paragraph 1.6 Freight on Rail believes that abolition of the SRA left a gap in terms of rail planning. This lack of an agency has severe implications for rail.

We welcome the London Freight Plan. In particular the daughter document the Rail Freight Strategy which is currently being written as this will be important reference document for the boroughs and TfL.

Paragraph 1.8
There is no mention of PPG13 which states that rail lands can be protected if identified in Local Development Frameworks by local authorities even where there is no potential rail use envisaged.

PPG13 states
that transport lands can be protected even where there is no identified transport usage as long as it is identified in the Local Plan as railway lands. PPG13 clearly indicated that even where there was not a reasonable chance of future use of an old transport link, unnecessary severance was still to
be avoided.

The important issues are:

• That once the rail land is gone it is lost as part of the railways and to society for ever.
   
• Often it is not possible to forecast whether a site or track bed may be needed in the future as markets and redevelopment etc change.

There are examples of strategic rail and water freight sites, redeveloped for housing, which should have been reinstated for transport use. 

1.9
There is huge competition for development of brownfield sites, encouraged by Planning Policy Guidance note 3 which gives priority for housing on brownfield sites.  This makes a strategic lead by Government all the more important if suitable sites for freight terminals and railheads are to be retained.

1.13
Reference boroughs involve transport agencies
Central and Regional Government should promote partnerships between the rail industry and other interests, such as councils, developers, employers, tourism bodies and development agencies, to improve the railway locally. Local authorities in particular have an important role in brokering partnerships of this nature, alongside Network Rail to implement new rail schemes. The LSDP is a fine example of such a partnership.

11. Road freight section P23 paragraph 11.7
Sites close to the rail network or existing rail terminals are particularly desirable. Protection of these lands for freight transfer purposes should be considered in SRDFS/UDPs/LDFs.

12. Rail freight (depots, terminals and interchanges)

We welcome the writing of the Rail Freight strategy as part of the London Freight Plan and the research being carried out by TfL Rail on the land use planning implications of potential sites for rail freight facilities.

Paras 12.7  12.10

• Promote the upgrade of existing terminals with good road and rail access. It is easier to upgrade existing terminals than provide new ones.
   
• Rail interchanges do not need to be big. There is a misconception that a rail interchange needs to be big. In fact, space to trans-ship the goods and to fit in a couple of sidings may be all that is needed. For example, the DHL depot which serves the daily service from the West Midlands to Scotland consists of a platform, lights and a canopy for a cross-docking exercise. There are examples of small bulk terminals consisting of a siding.  
  
  
• Plan new industrial developments to be accessible by rail. Avoid siting car assembly plants and factories in places without rail access.
  
  
• Be on an existing  railway line – this sounds obvious but as building new railway lines in London is extremely expensive there is little chance of new lines for freight

• Residential property in the vicinity should be designed so that sleep is not disturbed. Lorries need to reach the terminal and the less they have to pass through residential areas, the better.

12.3
12.11
The SRA had strong mandate for, and knowledge in, rail freight issues and as such was able to give clear guidance and support for protection of particular land sites DfT Rail does not share this role to the same extent and is therefore less likely to be able to comment on particular issues. As such, consultation should be broadened to include bodies such as Network Rail, RFG, Freight on Rail or the freight operating companies.  The document should make clear that Boroughs should expect to consult such parties where necessary.

12.17 Planning briefs
Freight on Rail members would be pleased to take part in specifying planning briefs for the boroughs.

GLA Transport Strategy

In respect of distribution and servicing, the Transport Strategy seeks to “foster a  progressive shift of freight from road to more sustainable modes such as rail and water, where this is economical and practicable”.

TfL, along with Local and regional government, should seek to ensure that the planning of additional rail services aligns with the safeguarding of sites for rail freight terminals, such as at Radlett, to ensure that sufficient capacity for freight services remains.

Philippa Edmunds   Freight on Rail Campaigner   July 20th 2006
Telephone: 020 8241 9982
Email:Philippa@freightonrail.org.uk