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Draft TfL Transport Strategy Response.

Freight on Rail is pleased to comment on the TfL Draft Transport 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.

While Freight on Rail welcomes proposal 16 (Page 75) which support rail freight in principle, we do not believe that the other proposals, actions and policies in the strategy follow through on this commitment in a meaningful way. Fundamentally, the references to rail freight under value its role in helping TfL achieve its core aims to reduce congestion, encourage modal shift, reduce CO2, air pollution emissions and reduce road collisions. In particular, we are very concerned about the comments on Page 163 and in proposal 64, which are very negative about rail freight.

  1. TfL should take the following National Government Policies into account:-
    • The DfT Rail Freight Strategy, September 2016, paragraph 135 - At the same time, we recognise the positive benefits of rail freight for the UK – including its environmental and air quality benefits relative to road freight and its impact on reducing road congestion.
    • DfT Carbon Review - February 2017
      Shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits. DfT Freight Carbon Review February 2017. P43 Key messages
    • The National Network Policy Statement – December 2014 recognises the socio economic benefits of SRFIs pages 20/45
  2. Rail freight growth in key markets
    Rail freight has seen consistent year on year growth in key consumer and construction markets. Construction traffic moved by rail freight grew by 7 per cent in the year to April 2017 to a record high of 4.25 billion net tonne-km, according to ORR figures. The largest commodity group is now domestic intermodal which grew by 6 per cent last year reaching 6.8 billion net tonne-km.Furthermore, customer demand for more consumer and construction rail freight services is currently constrained by the lack of space on the rail network.
  3. Rail freight contributes £1.6 bn per annum to the UK economy
    Each year the rail freight industry carries goods worth over £30bn ranging from high end whiskies and luxury cars, supermarket products, to cement and construction materials.
  4. Freight is a big CO2 emitter
    There is a significant opportunity to reduce transport emissions by shifting freight from road vehicles to rail. In total, road freight (Heavy Goods Vehicles and light vans) was responsible for one third of total greenhouse gas emissions from transport in 2015. Source EIS (2017) ‘Final UK greenhouse gas emissions national statistics: 1990-2015. By contrast, the total greenhouse gas emissions from rail (including both freight and passengers combined) are an order of magnitude lower at less than 2% of total UK transport emissions.
    As rail freight produces 76% less CO2 emissions than the equivalent HGV journey, increasing rail freight should be an important part of the TfL’s policy to reduce freight’s emissions and help the UK Government meet its legally binding Climate Change targets. Source DfT Rail Freight Strategy September 2016
    HGVs contribute 17 per cent of surface access CO2 emissions, despite making up only 5 per cent of road vehicles whereas both passenger and freight rail together are less than 2 per cent. Source DfT Rail Freight Strategy September 2016
    Energy efficiency is directly related to carbon dioxide emissions, rail is significantly more energy efficient than other modes with the exception of shipping. A tonne of goods can travel 246 miles by rail as opposed to 88 miles by road on a gallon of fuel 
    Source Network Rail Value of Freight July 2010.
    While electric technology means car emissions can be reduced significantly, current electric technology is not feasible for HGVs as the batteries would weigh more than the payload of the lorry. 
  5. Air quality benefits of rail freight
    Rail freight can be part of the solution to reduce air pollution, critical as London is already exceeding its nitrogen dioxide emissions (NOx) emissions limits. Rail produces 90 per cent less PM10 particulates and up to 15 times less NOx emissions than HGVs for the equivalent journey. Highways England figures show that HGVs are producing around 50% of the nitrogen oxide pollution from road pollution on the strategic road network even though they only make up 5 per cent of road miles driven in the UK.

    HGVs account for around 21% of road transport NOx emissions while making up just 5% of vehicle miles – DfT Freight Carbon Review February 2017.

    While the latest euro VI engines have reduced NOx emissions from truck engines considerably it will remain hard to reduce HGV brake and tyre particulate emissions. Tailpipe accounts for 40%, brakes 50% and tyres 10% of PM10 emissions.

    However proposal 34 does not mention modal shift as a means of reducing particulate emissions, even though the strategy highlights that particulates are a growing problem

    Freight Transport: Average emissions in grams per tonne-kilometre
    Mode PM10 CO NOx CO2 VOC
    Rail 0.004 0.032 0.31 0.05 0.021
    HGV 0.048 0.33 1.74 0.17 0.15

  6. Key:
    PM10 particulate matter of less than 10 microns;
    CO carbon monoxide;
    NOx oxides of nitrogen;
    CO2 emissions
    VOC volatile organic compounds.  Source RSSB 2007

  7. Noise Pollution- Proposal 47
    Far fewer people are negatively impacted by rail noise than road noise.
    DfT stats: only around 40,000 people are impacted by rail noise, but around 700,000 people are impacted by road noise.
  8. The safety case for rail freight reference P 76 of TfL strategy
    Rail freight is also far safer than HGVs; in 2015, Government figures showed that HGVs were almost six times more likely than cars to be involved in fatal crashed on local roads. In 2014, on motorways, HGVs were involved in almost half (45%) of fatal collisions although they only accounted for 11.6% of the miles driven on motorways. Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT

    London Safety Statistics from TfL
    Lorries are disproportionately involved in fatal collisions with pedestrians and cyclists.  Lorries only make up  around 5% of London traffic in miles driven

    Between 2010 and 2014, lorries were almost 10 times more likely to be involved in a fatal collision than cars; Seven of the nine cyclist fatalities in London in 2015 have involved lorries

  9. DfT analysis of costs of fatal collisions in 2015- DfT table RAS 6001


    Accident/casualty type

    Accident/casualty type

    Cost per casualty

    Cost per accident





    Safety issues continued with reference to page 76 TfL draft strategy

  10. 7ft longer HGVs should only be allowed on designated routes in the capital on safety grounds

    The 7ft longer HGVs, known as longer semi trailers, currently being trialled by DfT which it admits have bigger tail swings and blind spot, should only be allowed on local authority designated safe routes within the capital.

    These longer HGVs are particularly dangerous for cyclists and pedestrians as the tail swing is double that of the standard 44 tonne artic. Currently there is no mechanism to stop them using unsuitable roads in the capital and the DfT does not even know what routes the LSTs are using. In urban environments where standard left or right hand turns are made, the out-swing of the rear of the trailer will up from 1.7m (5.5ft)on the standard 13.6 metre trailer  to 3.3m (10.8ft) on the LST under normal road conditions and this will occur in the driver’s increased blind spot. Many urban junctions could not accommodate such trucks without their entering ‘wrong lanes or mounting the footway or traffic islands. This will be particularly dangerous for all other road users who may get side swiped as it will not be obvious to them how the back of the lorry will swing out into another lane.

    The assumptions for economic, safety and environmental improvements depend entirely on the prediction of a dramatic reduction in vehicles kilometres. However, the justification for longer heavier trucks is derived from high levels of load utilisation – in excess of that routinely achieved within the haulage sector. So until there is a rational basis for all existing HGVs to be used more efficiently, it is questionable how assumptions can be made that even bigger trucks will have higher utilisation than existing HGVs.Government figures show that nationally 30 per cent 1 of lorries are driving around completely empty, a figure which has been consistent for some years.

    The lorries in the LST trial are currently well utilised as it is a self-selecting audience taking part in the trial, but once these trucks become the largest standard permitted size - as is already being implied by the Society of Motor Manufacturers and Traders - they will be used for all jobs, whether small or large, exactly as currently happens with standard HGVs and the efficiency benefits will evaporate. 94% of UK HGV fleet operators had fewer than 10 vehicles and approximately 50% of operators were owner drives licensing just one vehicle who tend to get lower utilisation figures than the big operators. 2 The latest DfT Domestic road freights statistics report states that, there has been a shift towards using larger HGVs with the tendency for the vast majority of HGVs to be purchased at the maximum size and weight permitted which optimises the position for the largest and heaviest loads, but creates part loading for other consignments. The proportion of freight lifted by HGVs over 33 tonnes increased from 83% in 1996 to 96% in 2016. In 2000, 22% of HGVs were between 31 to 41 tonnes the maximum allowed at the time. However, now 22% of HGVs are now at the new maximum weight allowed of 44 tonnes.

    The Local Government Association and the Technical Advisers Group are both worried about the safety and cost implications for local authorities. Up until now, the DfT has not known what type of roads the LSTs are using and for how long. But, as a result of CBT, LGA and Technical Advisors Group’s requests, the DfT is now going to use GPS to monitor the trials going forward.

    Detailed comments

  11. We welcome the support in principle for rail freight in Proposal 16 (Page 75) but as explained in the summary, are concerned that the following policies do not follow through on this pledge.
  12. Proposal 15 Page 74

    b) and d) We support the need for consolidation centres but where practical these consolidation centres should be cross modal and be capable of being rail served so that rail can be used either for the long distance consumer deliveries or for aggregates transportation for which there is suppressed demand. 
  13. Rail freight terminals of all sizes are needed for different commodities
    While we accept that the London Plan is the spatial plan, which concentrates on safeguarding and planning policies as well as bringing all the other strategies together, we maintain that the transport strategy needs to highlight the importance of safeguarding key sites for further rail/road consolidation centres. Suitable sites by the railway with good road connections are limited.

    The Transport Strategy should recognise the role rail freight already plays in transporting 40% of London’s aggregates in a safer cleaner way which reduces road congestion and its potential to increase rail’s share of the market if the necessary road/rail transfer points are realised. Five million tonnes of construction materials such as aggregates and cement are delivered to a network of rail depots across London to help supply the material demands of housing, transport infrastructure and other developments across London. Rail wasused to bring in construction materials and remove waste/spoil for CrossRail and the Olympics. For example each freight train carries enough materials to build 30 houses.

    Therefore the Transport Strategy needs to have a policy to safeguard more rail freight sites for aggregates terminals in its strategy and give guidance to the London boroughs to do the same, so that more construction materials can be brought into the centre of London. Rail freight sites should be protected either through a GLA act in the same way that wharves are protected or through another mechanism. In the past, there was a SPG land for industry and transport.

    According to the Mineral Products Association Ltd, which represents the building industry, there are growing concerns about whether planning authorities will safeguard the rail depots currently used to receive materials because of other development pressures such as housing. Without a clear policy lead from the Mayor that the future use of rail freight is economically and environmentally critical for London, there is a significant risk that the operation of existing and potential new rail depots will become increasingly difficult, resulting in significant increases in the long distance lorry movements into London which will increase road congestion, road collisions and CO2/air pollution.

    Furthermore, the Mayor should have a policy to support a network of Strategic Rail Freight interchanges (SRFI) around London and the South East because SRFIs reduce the transhipment costs of rail freight as well as providing value added services which allows rail to compete more fairly with HGVs.

    The Daventry SRFI removes 64 million lorry miles from the road network.

    The night time Colas trials into Euston for both Sainsburys and TNT show the potential for rail freight to bring trainloads of freight into the heart of London, using major stations, when the stations are closed for passengers. The goods can then be delivered by low emissions road vehicles, including e-bikes for light loads.
  14. C) P88 Policy 5 Improving air quality and the environment
    No mention of the benefits of modal shift to rail freight despite its environmental benefits see sections 4/5
  15. Policy 6 Page 94 Zero carbon makes no mention of rail freight which produces 76% less CO2 emissions than HGVs for an equivalent journey. See section 5 for details
    Figure 12 Page 96 says supporting low emission freight but does not spell out what measures will be included.
  16. Proposal 35 and 35 P100
    TfL should lobby the DfT to undertake research into alternative fuels for freight locomotives, given that parts of the rail network will never be electrified.
  17. Page 163 proposal 64
    This section is most unhelpful and negative toward rail freight so we are asking for a forum to resolve issues as it is disappointing that TfL does not recognise the huge economic, safety and environmental benefits of rail freight in the strategy. We believe that the text including words,  such as slow and long trains, is counter-productive on Page 163 and want to work with TfL to promote passenger and freight rail solutions.

    We support the proposal to lobby the DfT for more rail freight capacity to allow more rail freight to go directly from Felixstowe to the West Midlands and the North via Leicester.
    However, TfL needs to recognise that:-
    • Some traffic is destined for the capital
    • Traffic from London Gateway and Tilbury, Channel Tunnel to the Midlands will always need to come via London
    • The vast majority of rail freight services are already not travelling at peak lines on the North, West and South London lines.
    • The rail freight industry has surrendered 4,700 paths out of the weekly timetable and only 1,000 have been allocated as strategic freight capacity to allow for growth.

The strategy rightly says that TfL has a role in support the national economy on Page 33. However, the comments on removing through freight traffic on page 163, are not in keeping with this policy.  

1. Source DfT empty running figures Table RFSO117 July 2017, 2015/2014 were 29%.
2. Source – Energy and Utility skills report 2013.


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