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NIC consultation.

  1. This is the Freight on Rail response to the National Infrastructure Commission (NIC) specific studies: call for ideas. Thank you for the opportunity to comment.
  2. 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 in the UK and to the European Commission, Parliament and Council of Ministers.
  3. Introduction
    We agree that infrastructure is vital for productivity and growth and that a key objective must be to improve the quality of life for people living in the UK. However, the Commission’s approach should also be consistent with sustainability requirements and climate change targets, in order to protect the economy and society both now and in the future. We believe a stronger social and environmental remit is needed otherwise short-term economic gain could result in longer-term adverse economic, environmental and social problems.It should not be driven exclusively by economic considerations so precise social and environmental criteria should be written into the remit of the NIC.

    Given that scientists revealed in October 2016 that in 2015, for the first time, carbon dioxide levels in the atmosphere were at 400 parts per million (ppm) on average across the year as a whole 1 , CO2 reductions are crucial.

    The NIC needs to consider infrastructure need in the round, and work across Government, consulting the relevant government departments, integrating spatial, energy and transport planning and engaging with devolved administrations and local authorities.

    The Commission should stipulate that rail should be used during the construction phase of power stations, rail, road and other energy projects, where possible. Previous examples where rail both supplied construction materials and removed spoil, are the Olympics, Crossrail and Heathrow Terminal Five.

    Clearer spatial guidance is needed to ensure developments avoid damaging special places like National Parks and AONBs. It is not clear what the implications are for schemes coming under the Town and Country Planning Act.
  4. Submitting our ideas – Upgrade Strategic Rail Freight Network (SRFN) to reduce road congestion and pollution.

    The case for expanding SRFN
    The strategic benefits to UK PLC of enhancing the SRFN are recognised in both the DfT Rail Freight Strategy and the Network Rail Network Study and meets all five NIC criteria.
    Increasing rail freight volumes will help the Government achieve its policies to reduce road congestion and pollution and improve productivity. Rail freight is a crucial part of freight distribution with significant socio-economic benefits, as confirmed by the Government in its latest Department for Transport Rail Freight Strategy 2
  5. Rail freight is worth £1.6 billion per year to the UK economy 3. A quarter of consumer goods imported into the UK are transported by rail and this traffic can grow if there is more rail freight capacity on key corridors. Rail has an expanding consumer freight market, which grew 7% last quarter compared to the previous year’s same quarter – the highest level since 1998 4; it has grown by 30% in last 10 years and is forecast to grow fourfold by 2043 if the network is upgraded and additional road/rail transfer points obtain planning permission.

    Road and rail complement each other so it is important that each mode plays to its strengths. Rail is well placed to offer the long distance trunk haul for consumer rail freight, as well as traditional bulk traffic having experienced sustained growth in consumer and construction markets.
  6. Freight on Rail therefore asks the Commission to support upgrade of the SRFN which is the central recommendation of the Network Rail Freight Network Study which states the following: The strategy focuses on developing  capacity and capability primarily for intermodal traffic from the major ports and the Channel Tunnel to key terminal locations. In particular, the industry recognises the importance of capacity from Felixstowe and Southampton ports and on the Trans-Pennine, West Coast and East Coast routes as being key drivers for growth.

    The strategy creates a nationally cohesive freight network with complete ‘line of route’ enhancements to enable the forecast growth in traffic to be realised.
  7. Strategic Rail Freight Interchanges (SRFIs) are an intrinsic element of shifting more freight to rail as they enable rail to compete with HGVs by reducing the transhipment costs between the modes. For example, the SRFI at Daventry in Northamptonshire removes 23 million lorry miles each year, mainly off the congested road network. Daventry has shown that interchanges can generate rail freight traffic and local employment without problems on the local road network. Developers want to invest in SRFIs as the growing number of proposals such as East Midlands Airport, Etwall Common near Derby, I-Port Doncaster and Four Ashes near Stafford demonstrate. The NIC can help facilitate a network of rail freight terminals getting planning permission which make transhipment between road and rail cheaper and offer added value services such as warehousing which make rail freight more viable.
  8. In the context of Brexit, there is a strong case for upgrading rail freight links to ports and conurbations in the next Network Rail Control Period 6, to build effective trade links.
  9. Detailed case for continuation of the DfT Strategic Rail Freight Network
    The Network Rail study sets out the short-term priority schemes 5 which we ask the Commission to support because there is suppressed demand, for consumer rail freight services in particular, because of the lack of rail capacity, as explained in sections below.

    Therefore we urge the NIC to upgrade key elements of the Strategic Rail Freight Network to build rail freight infrastructure providing a robust and reliable service for freight customers.

    Potential on Felixstowe to the North Corridor
    For example rail already has 28 per cent of the modal share out of Felixstowe with 33 daily rail services in and out of Felixstowe port to the north; customers want more rail freight services so every additional rail slot which comes free on this key strategic freight corridor can be filled straight away. As part of the current CP5 HLOS upgrades, Network Rail is upgrading the Felixstowe branch line which will provide an additional ten paths. However, further upgrades along the rail corridor to the North, as yet unfunded, could remove 40 million lorry miles from the A14 corridor.

    Examination of the 2015 daily HGVs numbers on the A14 corridor shows the potential to transfer significant flows to rail with each train removing 77 HGVs from the route.

    A14 just outside Felixstowe: 4863 five, six and six + axle HGVs out of total of 5632 HGVs per day.

    A14 just West of Stowmarket:  3771 five, six and six+ axle HGVs out of total 5320.

    A14 West of Bury St Edmunds: 5191 five, six and six+ axle HGVs out of total of 7166 HGVs per day.

    5ax and above as % of all HGVs for the 3 sites: 86%; 71%; 72%.  As % of total vehicles: 16%; 12%; 12%. The preponderance of such large vehicles, 5, 6 and 6+ axle HGVs, prime target for transfer to rail, shows the potential to shift to rail on this corridor.

    M6 corridor analysis shows 9500 five, six and six+ axle HGVs on the route per day. Upgrading the WCLM and allocating sufficient released HS2 paths to freight would significantly reduce these figures. 

    Annual Average Daily Flow divided by 365

    Southampton Port - the electric spine upgrades would increase capacity and reliability enabling rail traffic to expand. Rail currently has 38% of containers and 25% of cars are transported out of the port.
  10. The socio-economic benefits of rail freight

    DfT Freight Carbon Review
    As rail freight produces 76% less CO2 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. In 2014 carbon dioxide emissions from transport went up from 25 per cent to 28 per cent. Surface transport emissions account for the vast majority (94 per cent) and of that HGVs contribute 17 per cent, despite making up only 5 per cent of road vehicles. Both passenger and freight rail together are less than 2 per cent.

    Air Pollution
    Rail freight can be part of the solution to reduce air pollution. Currently, 40,000 people die prematurely in the UK from diesel fumes wide-spread air quality violations, especially in cities like London and Manchester which are already exceeding their NOX emissions limits.
    Rail produces 90 per cent less PM10 particulates and up to 15 times less nitrogen dioxide 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.

    Road Congestion
    The DfT Rail Freight Strategy states that rail freight is a major part of Government policy to reduce road congestion which is adversely affects productivity. An average freight train can remove 77 HGVs and an aggregates train can remove up to 136 HGVs from congested strategic roads.  

    Rail is safer than HGVs
    ORR states that rail is 20 times safer than road.
    In 2013, HGVs were six times more likely than cars to be involved in fatal collisions on minor roads. Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT,

  1. the World Meteorological Organisation’s (WMO) annual greenhouse gas bulletin
  2. DfTRail Freight Strategy September 2016
  3. RDG Keeping the Lights on and the Traffic Moving
    RDG Freight Britain
  5.  summary Table 2 & Figure 2 P9/11

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