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Freight on Rail response to Defra Clean Air Strategy.

Freight on Rail is pleased to respond to the Defra Clean Air Strategy

Freight on Rail, a partnership of the rail freight industry, the transport trade unions and Campaign for Better Transport, works to promote the economic, social and environmental benefits of rail freight to local, devolved and central Government.


We welcome the Defra Clean Air Strategy recommendation to reduce emissions by modal shift to rail (ref 5.7 P48). 
Recognition by the Government that there is a strong case for supporting rail freight industry research is most welcome 5.7.1. This is especially important with the current halting of further rail electrification, which has been the tried and tested low emissions option for rail.

Furthermore, the government must take into consideration the fact that the asset life of freight locomotives is between 30-40 years whereas for both HGVs and construction plant it is in the order of seven years.

Support for rail freight is needed in the following ways:- 

  1. In the short term to reduce emissions from existing rail freight locomotives through support for retro-fitting
  2. In the longer term, a Government strategy will be needed so that the industry can gain support for a replacement locomotive plan.

Rail freight has acknowledged superior environmental performance to HGVs, and greater modal shift is an important way of reducing transport emissions, so we warmly welcome the Clean Air Strategy recommending reducing emissions by modal shift.  The rail freight sector equally needs to act to improve its own performance including in air quality and this has been recognised by the industry; indeed the DfT Rail Freight Strategy of September 2016 made a commitment to help the industry explore alternative fuels, which is still ongoing.  (Paragraph 89 DfT will ensure that rail freight is considered as part of work on options for wider deployment of biofuels to decarbonise the freight sector). The Rail Freight Group has also produced a scoping paper on the issues of air quality1

Actions To Date

The rail freight operators are continually acting to reduce the amount of fuel used and hence emissions.  Measures have included driver training, roll out of in cab advisory systems and the fitment of start – stop technology to some of the locomotive fleet (which turns the engine off whilst idling in terminals).  This work has been led by individual freight operators. 

Recently purchased freight locomotives have superior emission standards, including the Class 68s, 70s and 88s, as well as the last of the Class 66s.  As highlighted in the Clean Air Strategy, the class  88 bi-mode locomotives, purchased by Direct Rail Services ref P46 are leading the way.  The class 88s are predominantly designed for electric mode but it can used in  diesel traction on non-electrified lines and terminals.

We also note that the latest report by the Committee on Climate Change, issued in June 2018, said that more freight needs to be transferred to rail to reduce carbon emissions  and air pollution.

We welcome the comment in the freight section 5.7.1. A current programme of work is looking to update the rail freight emissions data, to ensure that the statistics are based on the current locomotive fleet and to consider ways of producing more specific data for rail.  Research into rail freight emissions and air quality to enable better comparisons with HGV emissions is crucial as much of the data has not been updated since 2007 so the industry is working with partners to facilitate getting the necessary data. 

Separately, Rail Freight Group and RDG Freight Group are participating in the Steering Group for the rail decarbonisation strategy, which will consider longer term traction requirements for freight, including their impact on emissions reduction. Some rail freight operators have been in discussion with University research teams to identify potential for developing future options.

Government needs aligned policy across freight modes and to integrate carbon and air pollution reduction policies between departments

Our response also relates to air pollution issues across the two surface access freight modes. Air quality is an increasingly important issue for road freight transport, which means that rail freight could and should be playing a larger role in reducing NOx and particulate emissions. There is growing recognition, as your strategy states and as shown by the call for evidence on the topic, of the need to tackle particulate emissions from brake and tyre as well as tail-pipe particulate emissions from freight transport.  Over half of small particle pollution comes from the wear on brake discs and tyres and by throwing up dust from roads known as resuspension; in the case of large HGVs it will be difficult to reduce these emissions.

While progress is being made in smaller freight vehicles operating in urban and suburban areas through hybrid and alternative engines and regenerative braking, there is less scope to replace large HGV diesel engines.  Articulated HGVs do most of their travel on motorways (58.8 per cent) and on trunk roads (a further 22.7 per cent) and in these conditions, regenerative braking and hybrid technology does not offer significant savings. 

Adaptations for diesel engines with the latest Euro VI truck engines have helped to reduce exposure to particulates, but new sources of transport emissions associated with brake and track and abrasion threaten to push levels of pollution from this source back up. Therefore, with particulates it is important to record both tailpipe and brake and tyre emissions separately as HGVs present serious type and brake particulates, due to size of brakes and resuspension, which will be hard to reduce. Overall road transport vehicles PM10 is 40% tailpipe, 50% brakes and 10% tyres. Trains have very effective regenerative braking whereas HGVs regenerative braking is less effective. 
P48 Reducing emissions by modal shift 5.7.1

The rail freight modal shift grants
These grants, are paid by the Government in recognition of the economic safety and pollution benefits of removing trucks from our roads, especially road congestion relief, of rail taking HGVs off congested roads.   The Government acknowledges that market distortion make it difficult for the sustainable modes to compete on price because of the lack of a level playing field; hence the grants scheme currently with an annual budget of circa £15 million. Mode Shift Revenue Support (MSRS) Grants are only paid by DfT for actual traffic removed from roads, - are therefore risk adjusted for government - and represent excellent value for money to the UK taxpayer.  It is difficult for rail to compete because HGVs only pay a third of the costs they impose on society and yet rail has to compete on price and that is why retention of these grants is crucial if the traffic is not to return to road with all the resulting external and congestion costs imposed on the economy, environmental and society We believe that the grant budget should be expanded to allow more traffic to shift to rail.

For example the large HGVs only pay 11 per cent of their infrastructure costs; a 16.5 metre 44 tonne truck is 136,000 times more damaging to road surfaces than a Ford Focus, known as the Generalised Fourth Power Law.  

Government needs to treat rail freight fairly in relation to HGVs.

At the moment , Government freight policy between the two modes is not aligned which means that the two different freight modes are not being treated equitably, either in terms of charging or in environmental policy.

So, if the Government is serious about Developing and deploying cost-effective options for shifting more freight from road to rail P 5.7, it needs to reform its charging system and environmental policies for both rail freight and HGVs; currently it is not a level playing field between the modes which means that the best most sustainable freight options are not being used. Road and rail complement each other; it is therefore important for the economy, society and the environment that each mode plays to its strengths. Rail freight is well placed to offer long distance consumer haulage as well as the traditional bulk cargoes.

The Government is right to see rail freight as part of the solution to bringing in freight into urban areas; either into the heart of cities using passenger terminals at night or into rail freight terminals. Almost half of London’s building materials are brought into London by rail with much of the industrial spoil being reduced by rail too. There is also a key role for rail in delivering long distance freight to consolidation/interchanges on the edge of conurbations for onward transhipment into low emissions vehicles for the final mile.    

The reality is that HGVs only pay a third of the costs they impose in terms of congestion, fatalities, road damage and pollution with the taxpayer picking up the rest. Since 2011, diesel fuel duty has been frozen and yet rail freight charges have increased by 22 per cent. And yet the latest Office of Road and Rail’s proposed future rail freight charging would exacerbate this market distortion as it is currently recommending that freight charges go up by 29 per cent between 2019 and 2029.  This measure would further tip the balance in favour of HGVs resulting in freight transferring back to road as well as preventing future expansion of rail freight.  

DfT environmental policy on diesel only freight 
However, the Department for Transport plans for rail freight and HGVs are inconsistent with the Defra plans to reduce emissions and encourage freight modal shift. Its policy ‘Road to Zero’, excludes HGVs from the ban to sell new diesel cars and vans from 2040. The only substantive freight measure is a voluntary agreement with the industry to reduce CO2 emissions by 15% by 2025. In contract, rail freight  is being penalised both by the DfT halt to electrification, and its diesel only ban for rail locomotives from 2040. This is despite the fact that rail freight locomotives emit far less carbon dioxide and air pollution than HGVs, for the equivalent journey. These plans, without equal support for rail freight, by the DfT would result in modal shift back to road.

We believe that the answer is for the Government to get a grip on the costs of installing electrification on the railways, not halt adoption of the most sustainable fuel source, which is tried and tested, when there is no alternative fuel in the pipeline to match it. One of the reasons why the GWML project has gone over budget was the lack of relevant professional expertise which will again be lost if electrification is halted again.

Electrification is being rolled out across the rest of Europe; EU statistics show that the UK is now trailing at a woeful 20th in the league table of electrified lines in Europe. Julian Worth,a rail freight expert, makes the case for a modest re-wiring of around 320 key miles over a 30 year period which could see two-thirds of rail freight moved by electric traction2. If Government commits to investment over a period, then the rail freight operators can build the business case for new locomotives.

Need for research into alternative fuels for rail freight.
DfT has funded around £200m research into alternative fuels for HGVs so it is now crucial that it supports the rail freight industry in the same way. We also believe that there will be useful evidence from the HGV analysis of alternative fuels which can be fed into rail freight locomotive research.

The Low Carbon Vehicle Partnership has done important work on HGVs and there is no reason why it could not do work on alternative fuels for rail freight locomotives. Both sectors have power to weight issues.

We also support the Transport Systems Catapult research into hydrogen fuel cells but there is little expectation that fuels cells will be sufficient for HGVs by 2040. 5.5.2

Gas alternatives

Liquefied Natural Gas (LNG) is used in rail by both USA and Russia but they both have large supplies. It works best for high load continuous operations. In urban or start/stop environments however the carbon output can be worse than for diesel. There are also storage issues with it needing to be kept at -230C for LNG. And apparently co-firing of LNG can adversely affect selective catalytic reduction (SCR) after treatment.

It is crucial that the decarbonisation and air quality work by the Government is integrated so we welcome the recognition in section 5.5.2 that the Government will work closely with the decarbonisation task force and the industry throughout 2018 and early 2019 to develop a range of measure to  tackle decarbonisation and air pollution.

Retrofitting class 66 rail freight locomotives to reduce NOx emissions.
The rail freight industry is investigating the viability of fitting after treatment, using add blue and selective catalytic reduction (SCR). SCR technology has hugely reduced  Euro VI engine air pollution.

There are around 550 class 66 engines, a great many of which have the same engine configurations. Eminox has been important work with the Government and LPVP. If there is a positive way forward identified Government support for trials would be crucial. Funding from DEFRA, BEIS, Innovate UK and others who have funded road freight options.

Freight emissions reduction
The Clean Air Strategy references the National Infrastructure Commission freight study which is tasked with making freight more efficient and less polluting.

One of the best ways to reduce freight’s emissions is to make road freight more efficient. Currently HGVs are competitive but not efficient. The latest DfT statistics for 2017 show that empty running of trucks remains at 30 per cent for a second year running.Government statistics also show that only 34 per cent of trucks were full in terms of volume in 2016.

Distance based charging

To improve economic efficiencies there should be a direct relationship between the taxes per km travelled and the marginal costs for freight use. A distance based charging system can provide. It is the calculation of these marginal costs which is crucial as we have said during the discussion on the revision of the HGV levy.
HGVs have a wide range of impacts; these include congestion and pollution but also safety and infrastructure impacts not mentioned in the review.  Currently, HGVs are only internalising around a third of their costs so until HGVs internalise more of their costs HGVs will continue to be a huge problem to society and the economy.  Moving to distance based charging will have economic, productivity and competitiveness benefits as well as environmental benefits and is also likely to lead to a shift to rail, which should have further benefits.
The single most effective change to achieve all the Government’s stated objectives of improving efficiency, reducing exposure to collisions and reducing air and CO2 pollution would be to replace the existing time based lorry charging system with a distance based system which could relate charges paid to the real impacts HGVs have on other road users and the road network.  The current daily charge bears no direct relationship to the amount of use of the network; therefore the system does not incentivise more efficient use of the road network or the time at which it is used.
A distance-based lorry charging scheme could improve HGV efficiency by incentivising more efficient use of lorries, in order to reduce lorry miles. The current empty running and load utilisation figures show that road haulage industry efficiency is not improving.
Whereas distance based charging in both Austria and Germany have reduced both empty running and improved efficiency. Germany had similar levels to the UK of empty running before distance based charging was introduced but now it has decreased by a third. In Austria empty running reduced by a quarter from 21,1 per-cent in 1999 to 15,7 per cent in 2004. At the same time the average load grew 0,6 Ton  to 14,7T.

5.8 Government needs to give real incentives into alternatives to support business

Incentives are needed for companies to purchase new less polluting equipment like fork lift trucks and cranes which have a much shorter asset life than rail freight locomotives at between seven to ten years.




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