Freight on Rail response to 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).
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:-
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.
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.
The rail freight modal shift grants
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.
DfT environmental policy on diesel only freight
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.
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.
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.
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
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.
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.
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.