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Draft revised National Planning Policy Framework -
Response from Freight on Rail
.

May 2018

Freight on Rail is pleased to respond to the consultation on the National Planning Policy Framework. No part of this response is confidential.

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.

Summary  Comments

  1. We welcome the emphasis on environmental protection, healthy lifestyles, sustainable transport and densification in the NPPF revisions and support a  presumption in favour of sustainable development, provided that it is truly sustainable. Our responses to the NPPF consultation questions suggest wording changes that will help deliver such sustainable development.
  2. We have long campaigned for integrated transport and spatial planning policy because having the right spatial planning policy is critical to getting modal shift ; for example, safeguarding suitable rail sites for future rail freight terminals otherwise the sites are lost to the rail industry for ever. Rail freight will help tackle issues of air pollution, carbon reduction and reduce road congestion and road collisions and improve social inclusion.
  3. The NPPF can make a strategic positive contribution to sustainable growth by shaping planning policies and local plans that help promote sustainable freight distribution. For example, encouraging freight transport hubs which are rail served instead of perpetuating road freight deliveries.
  4. Rail freight should have a large role in servicing the Government policy to build housing so spatial policy should encourage rail freight; one freight train can carry enough construction materials to build 30 houses. Rail freight is also important for removing industrial spoil; rail freight was used to transport spoil from Crossrail out of London.
  5. We believe that sustainable transport makes a positive contribution to the Government’s policy goals if sustainable development is prioritised.
  6. Local and devolved authorities have a key role in planning, promoting and protecting sites for rail freight terminals and rail alignments for future possible rail freight use. Devolved authorities set the wider framework which promotes sustainable distribution and local authorities have the powers to protect suitable rail freight sites for possible future use. There is a shortage of suitable sites beside the railway which also have good road connections.   Without more intermodal freight hubs in the right places it will be difficult for rail freight volumes to grow. While the large Strategic Rail Freight interchanges (SRFIs) of 50 hectares and above, come under the remit of National Infrastructure Planningunder the Nationally Significant Infrastructure Projects (NSIPs) regime, small and medium sized terminals fall within the remit of the NPPF and the Town and Country Planning Act.      

    Detailed comments
                   
    Q1 Do you have any comments on the text ofChapter 1?
     
  7. We support the clarification that endorsed recommendations of the National Infrastructure Commission may be material when preparing plans or determining applications. We note the inclusion in para 6 of Ministerial statements and NIC-endorsed recommendations as a material consideration and do not object provided such recommendations have been subject to independent environmental assessment. They should not able able to override key sustainable development requirements such as prioritising sustainable transport. We therefore propose adding the words “where these are compatible with other NPPF policies at the end of para 6.

    Q5 Do you agree with the further changes proposed to the tests of soundness, and to the other changes of policy in this chapter that have not already been consulted on?
    Q6 Do you have any other comments on the text of Chapter 3?
     
  8. It is important to plan freight transport in a way that takes into account effective cross boundary policies as it is important that adjacent local authorities work together.
  9. We propose adding the word “transport” to para 35 so that this reads “relevant economic, social, transport objectives”. 
  10. In paragraph 20 d), it is important to ensure that infrastructure for transport is not just considered for passenger transport but also for the effective movement of goods.  This should be clarified.

    Q21 Do you agree with the changes to the transport chapter that point to the way that all aspects of transport should be considered, both in planning for transport and assessing transport impacts?
    Q23Do you have any other comments on the text of Chapter 9?
     
  11. The changes to wording of this chapter have resulted in some important points being being lost which should be reinstated.
  12. Para 103 (d).  This requires the environmental impact to be assessed and mitigated, whereas the previous text explicitly required ‘encouragement (of) solutions which support reductions in greenhouse gases and reduce congestion’.  This change therefore weakens the emphasis placed on carbon and congestion reduction in favour simply of its assessment and local mitigation.  This change therefore weakens the case for supporting rail freight proposals.  Therefore, the previous text should be reinstated.
  13. Para 105 (e) We support the broad principle of this paragraph, however the changed text has removed the requirement to work with neighbouring authorities and transport providers on such schemes.  Although this is partly replaced by the general requirements elsewhere (see Q5 and 6), it should also be replaced here, as most large scale facilities will have cross boundary benefits and impacts. The local authorities duty to co-operate in itself is not sufficient.
  14. Para 110 (d) The previous text required plans to ‘protect and exploit opportunities for the use of sustainable transport for the movement of goods…’  The current proposed text is much weaker and only requires that applications for developments ‘allow for the efficient delivery of goods..’.  This is a material change and removes any requirement for plans to protect existing facilities used for the sustainable movement of goods.  As outlined in our summary points paragraph 7, safeguarding of existing rail freight terminals is a critical requirement for the promotion of sustainable freight transport, and the weakening of the text here acts against it.  The previous text should be reinstated.
     
    Q25 Do you agree with the proposed approaches to under-utilised land, reallocating land for other uses and making it easier to convert land which is in existing use?
    Q26 Do you agree with the proposed approach to employing minimum density standards where there is a shortage of land for meeting identified housing needs?
    Q27 Do you have any other comments on the text of Chapter 11?
     
  15. We strongly support densification and making best use of under utilised land particularly around transport hubs. However this must not be at the expense of land safeguarded for public transport infrastructure and multi-modal freight terminals which are necessary to deliver the sustainable development aspirations of the NPPF.
  16. Para 118 (d) includes that planning policies and decisions should promote and support  development on railway infrastructure.  Whilst Network Rail are working to identify suitable land for release, a general presumption of development on railway land is unhelpful in the context of providing sustainable transport of goods and people.  As outlined above, current rail freight sites, including a small number of locations for future development should be safeguarded particularly in urban centres, rather than earmarked for other uses.    Railway infrastructure should therefore be removed from this paragraph.
  17. Under paragraph 126e) please change “transport” to “sustainable transport”.
  18. Chapter 13 Protecting the Green belt check Chapter 13 comments – question 30

    We support proposed changes to enable greater use of brownfield land in the Green belt for rail freight terminals

    Q34 Do you agree with the approach to clarifying and strengthening protection for areas of particular environmental importance in the context of the 25 Year Environment Plan and national infrastructure requirements, including the level of protection for ancient woodland and aged or veteran trees?
    Q35 Do you have any other comments on the text of Chapter 15?
     
  19. We support the introduction of the ‘agent of change’ requirements in paragraph 180.

    Q37 Do you have any comments on the changes of policy in Chapter 17, or on any other aspects of the text of this chapter?
    Q38 Do you think that planning policy on minerals would be better contained in a separate document?
    Q39 Do you have any views on the utility of national and sub-national guidelines on future aggregates provision?
     
  20. We have no specific comments on the overall approach to minerals planning. 
  21. However Para 200(e) has been reworded and now excludes the safeguarding of ‘existing, planned and potential rail heads, rail links to quarries, wharfage and associated storage, handling and processing facilities for the bulk transport by rail, sea or inland waterways of minerals, including recycled, secondary and marine-dredged materials’
  22. This significantly weakens the planning framework for rail and water served minerals facilities, leaving them at risk from other development.  This in turn risks the supply chain of construction materials into urban centres.  This change is also in conflict with the strengthening of the safeguarding for intermodal terminals in the Draft London Plan which has sought to strengthen safeguarding of such facilities in London. Therefore, the previous text should be retained instead.



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