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Appeal by Roxhill – Howbury Park, Slade Green.

15th March 2019

Freight on Rail supports the Howbury Park revised application for planning consent predicated on the economic, social and environmental benefits of removing heavy goods vehicles (HGVs) from our strategicroad network in line with Government policy.

Increasing rail freight volumes is part of the Government’s strategy to reduce CO2 and air pollution emissions, road congestion and road collisions. In order to increase rail freight, interchanges such as Howbury Park, are needed at strategic locations with good road and rail connections across the UK.
Roxhill/Segro, the UK's largest strategic rail freight interchange developer, is seeking to update a historical planning consent with layout modifications.

In summary, Howbury Park is identified as a site for a Strategic Rail Freight Interchange (SRFI) in the adopted London Plan and is consistent with the National Networks National Policy Statement. Furthermore, the planning application for a revised consent has near universal support from statutory consultees, including the local council, the London Borough of Bexley as well as the local MP, the Rt Hon Sir David Evennett.

Howbury Park will generate around 2,000 direct onsite jobs with a further 2,800 in the wider catchment area. Furthermore, this investment will give the wider rail freight industry confidence to follow suit.

The justification for using greenbelt land, in very special circumstances, is based on the scarcity of suitable sites for SRFIs. These interchanges create essential access to the railways for local businesses and are recognised as key facilities to deliver a modal shift in freight transport, removing HGV traffic from the roads. This part of London has no SRFI provision and evidence submitted with the application demonstrates a complete lack of potential alternative locations where SRFI facilities could be accommodated.

The removal of HGVs from the strategic road network through the use of the Howbury Park SRFI will deliver substantial CO2 emission reductions, estimated at approximately 40,000 tonnes of CO2 per annum and 1.4 million HGV kilometres per annum removed from Kent’s roads alone. Viridor, a site neighbour, is also looking to use the rail terminal, removing existing HGV traffic from the local network.

Uniquely, the proposals offer the opportunity to protect the long-term future of the nearby Crayford Marshes, with the proposed drainage scheme at the site feeding into the Marshes, and hence reducing its susceptibility to climate change. An ecological management regime for the Crayford Marshes will supplement this direct benefit.

Protecting community amenity is inherent to the Howbury Park SRFI design. In centralising all rail activity within an intermodal area located between warehousing, the site will internalise and screen potentially intrusive activities. Extensive landscaping and carefully placed green bunds supplement built design features to further mitigate scheme impacts.

Local traffic and associated air quality impacts have been demonstrated to be limited in nature. All HGV traffic serving the site is captured along a single access road that links directly to the strategic road network at the Bob Dunn Roundabout (the A206). From here, it is a short distance along a dual carriageway to the M25, thereby avoiding any potential conflict with residential areas. Furthermore, with an HGV traffic cap in place, the number of vehicles exiting the site during peak times will be strictly control, to avoid any adverse impact on prevailing traffic conditions.  

The application site itself is also well-suited to the proposed use, located immediately adjacent to the existing Slade Green Train Depot and isolated from existing residential communities not only by this existing operating facility but, in addition, benefiting from a further separation with land that is safeguarded for future Crossrail facilities.   

Freight on Rail believes the Howbury Park proposal meets all the criteria set out in the planning system; we have also written detailed notes expanding on points made in our letter.

 



Socio-economic case for Howbury Park Strategic Rail Freight Interchange

Increasing rail freight volumes is part of the Government’s strategy to reduce CO2 and air pollution emissions, road congestion and road collisions.

Without more rail freight terminals rail freight volumes cannot be increased

In order to increase rail freight volumes, interchanges such as Howbury Park, are needed at strategic locations with good road and rail connections across the UK.

Rail freight terminals enable rail to compete with Heavy Goods Vehicles (HGVs) as it reduces the transhipment costs between the two modes by providing value added services such as rail served warehousing and ancillary service buildings. In particular, off road vehicles can be used around the site rather than registered and more expensive HGVs.

Howbury Park is identified as a site for a Strategic Rail Freight Interchange (SRFI) in the adopted London Plan and is consistent with the National Networks National Policy Statement. Furthermore, the planning application for a revised consent has near universal support from statutory consultees, including the local council, the London Borough of Bexley as well as the local MP, the Rt Hon Sir David Evennett.

Scarcity of suitable sites which justifies use of green belt in very special circumstances

The justification for using greenbelt land, in very special circumstances, is based on the scarcity of suitable sites for SRFIs. These interchanges create essential access to the railways for local businesses and are recognised as key facilities to deliver a modal shift in freight transport, removing HGV traffic from the roads. This part of London has no SRFI provision and evidence submitted with the application demonstrates a complete lack of potential alternative locations where SRFI facilities could be accommodated.

Mitigation measures undertaken as part of this proposal

Uniquely, the proposals offer the opportunity to protect the long-term future of the nearby Crayford Marshes, with the proposed drainage scheme at the site feeding into the Marshes, and hence reducing its susceptibility to climate change. An ecological management regime for the Crayford Marshes will supplement this direct benefit.

Protecting community amenity is inherent to the Howbury Park SRFI design. In centralising all rail activity within an intermodal area located between warehousing, the site will internalise and screen potentially intrusive activities. Extensive landscaping and carefully placed green bunds supplement built design features to further mitigate scheme impacts.

The application site itself is also well-suited to the proposed use, located immediately adjacent to the existing Slade Green Train Depot and isolated from existing residential communities not only by this existing operating facility but, in addition, benefiting from a further separation with land that is safeguarded for future Crossrail facilities.   

Local traffic and associated air quality impacts have been demonstrated to be limited in nature. All HGV traffic serving the site is captured along a single access road that links directly to the strategic road network at the Bob Dunn Roundabout (the A206). From here, it is a short distance along a dual carriageway to the M25, thereby avoiding any potential conflict with residential areas. Furthermore, with an HGV traffic cap in place, the number of vehicles exiting the site during peak times will be strictly control, to avoid any adverse impact on prevailing traffic conditions.     

Job creation and re-generation benefits of Howbury Park

Howbury Park will generate around 2000 direct onsite jobs with a further 2,800 in the wider catchment area. Furthermore, this investment will give the wider rail freight industry confidence to follow suit.

Economic benefits of rail freight

Each freight train using Howbury Park can remove around 76 HGVs. (source:Department for Transport Rail Freight Strategy 2016).

Figures on HGV involvement rates in critical incidents on the Strategic Road Network (SRN) make the economic and safety case for rail freight

For example, the average monthly figures for HGV involvement in critical incidents on the SRN from January to-November 2018 show the following: for incidents of more than five hours, the HGV involvement rate is 42.8 per cent of incidents and for incidents of more than ten hours the HGV involvement rate is 55.72 per cent; even though HGVs make up just under 12 per cent of motorway traffic miles in 2017. (source: Highways England HILO data 2018).

Rail freight also reduces road infrastructure costs

Large HGVs are up to 100,000 times more damaging to road surfaces than a Ford Focusmeaning some of the heaviest road repair costs are therefore almost exclusively attributable to the heaviest vehicles. Rail freight therefore reduces the road infrastructure costs for local, devolved and central Government.

Environmental benefits of rail freight

There is a significant opportunity to reduce transport emissions by shifting freight from road vehicles to rail. In total, road freight (HGVs 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 carbon dioxide emissions than the equivalent HGV journey, increasing rail freight is an important part of the DfT’s policy to reduce freight’s emissions and help the UK meet its legally binding Climate Change targets. (source:DfTRail Freight Strategy September 2016).

HGVs contribute 17 per cent of surface access carbon dioxide emissions, despite making up only five per cent of road vehicles whereas both passenger and freight rail together are less than two 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).

Air quality benefits of rail freight

Rail freight can be part of the solution to reduce air pollution. Rail produces 90 per cent less PM10 particulates and up to 15 times less nitrogen dioxide emissions than HGVs for the equivalent journey.
HGVs account for around 21 per cent of road transport NOx emissions while making up just five per cent of vehicle miles (source: DfT Freight Carbon Review February 2017).

Safety benefits of rail freight

Modal shift to rail can reduce road collisions. This graph shows the HGV involvement rate in fatal crashes on different road types over the past nine years. In 2017 for example HGVs were almost five times more likely than cars to be involved in fatal accidents on minor roads

Graph showing involvement in fataltities HGVs over 3.5 tonnes compared to all traffic


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