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Network Rail on improved reporting of our network system operator activities – an NSO Dashboard.

  1. Freight on Rail thanks Network Rail for this opportunity to comment on improved reporting of its network system operator activities – an NSO Dashboard.
  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. Dieter Helm, an industry commentator, acknowledged in his recent paper -What to do about the railways, in the section on the case for a system operator that “Someone needs to be in charge to make sure the system as a whole is considered.
  4. Freight on Rail believes that the network system operator functions within NR are crucial for rail freight and will explain the reasons in our response below. We support the review to improve this function and the definition outlined in the Executive Summary on Page 2. Additionally we would suggest that the societal and environmental benefits of rail should be highlighted.

    Given that we do not know what the structures of the railway are going to be, would it be better to postpone the work on the dashboard until the situation is clearer?

    Fundamentally, it is needed at national level to ensure national co-ordination and the necessary system planning of the overall system as very little of the railway is separate and discreet. Devolution makes this role even more key. 

    NR is in charge of signalling and the track and it has an overriding command and control function. The system management function within Network Rail (NR) is fundamental to providing a system in which the needs of all the different users, including the rail freight and open access operators, are taken into account. 

    As well as ensuring that rail freight is not overlooked in any other restructuring of the industry, the Government needs to make sure that the system operation function caters for rail freight. Devolution, both Government and industry, present challenges for rail freight as it is a network-wide industry. The vast majority of rail freight flows cross regional boundaries so that is why nationwide access and timetabling and possession planning must be managed centrally by the system operation.

    Timetables need to be co-ordinated between different train operations as well as other modes of transport. Similarly, investment needs to be co-ordinated with integrated transport planning across the rail and road networks. We believe that future strategic planning for investments in parallel rail and road corridors needs to be integrated to maximise the economic, safety and environmental benefit of infrastructure enhancements. Therefore, the next stage of the Road Investment Strategy (RIS2) and CP6 HLOS processes should identify the corridors with the largest opportunities for rail freight to relieve road congestion.
  5. The experience of devolution to date has been challenging for rail freight  which makes the case for a system operator even stronger as the more the system is broken up, the greater the need for a central system operator.
  6. The new monitoring role of ORR for Highways England (HE) should benefit the railways as it  will enable the ORR and the Government to compare costs and subsidies across both modes. The Government will be able to compare more accurately the costs and benefits of different modes, social outcomes and opportunities for efficiency.
  7. The impacts of devolution must be factored into the assessment of the system operation role.
  8. System operation provides a stable and consistent framework so that the industry has confidence to invest.
  9. Any changes to the system operation function which disadvantages rail freight and causes reverse modal shift will result in extra costs elsewhere for the Government in the form of more road congestion, road casualties, the environmental and road infrastructure damage. Therefore, the Government must take into account the scale of subsidy given to HGVs; the latest research carried out for the Campaign for Better Transport 1 using DfT values, found that HGVs pay less than a third of their costs, such as road congestion, road collisions, road damage and pollution which equate to an annual subsidy of around £6.5 billion. These conclusions are in line with a MDS Transmodal study in 2007 which found a very similar amount of underpayment: £6billion.  The Government needs to recognise HGV costs in discussion about rail freight costs so that policy implications can then be understood in both directions with road and rail being examined across the piece. The level of HGV subsidy makes a compelling case for supporting rail, which imposes much lower costs on society and the economy, equivalently. 
  10. The availability of the information from Dashboard could be transformative for the railways as it can inform all the railways customers what is happening on the network and what service changes there are due to problems. In terms of freight services, it would allow better tracking of goods and provide data on likely arrival times.

Detailed comments

Page 2 What is NR system operation in rail and why is it important?

Broadly, we agree with the comments in this section. However, the in the second paragraph it is misleading to say that train operators typically focus on specific geographies while that may be true of the majority of TOCS it is not true for FOCs. Also this statement is contradicted on the same page in the paragraph which states that demand for transport is not confined to separate geographical regions.

However, rail freight does specialise in certain markets but it should be noted that freight markets and modes are subject to big changes and fluctuations according to price, supply/demand , proximity of raw materials, fuel and labour costs and levels of economic activity.

Page 4- This section of your consultation explains very clearly the issues and the importance of rail freight

The Network Rail consultation – Improved reporting of our network system operator activities – explains this precisely on Page 4. Managing the operation of core routes across multiple management units of its network

Examples of the first of these include long distance passenger services, for instance, passenger services of the CrossCountry franchise operator over 7 separate NR rail routes; conversely the London North Western Route has 14 different passenger and freight operators running on its infrastructure, each with services that cross into neighbouring routes.

The consultation states that the network benefits are even more obvious for freight services.

The enormous growth seen in intermodal traffic from Southampton and Felixstowe to the Midlands and the north would be hampered if there was not a national planning function and a national control to oversee their operation.

For any long distance passenger or freight service, the co-ordination of engineering work is important across geographical boundaries so that, where practical, a diversionary route is made available around a line closure.

Page 5 Managing the interactions between different types of train service

Capacity constraints is a growing problem for rail freight so an equitable system for managing access to paths which recognises the economic, safety and environmental benefits of freight services rather than HGVs, the overriding alternative, is crucial.

The paper acknowledges that devolution is likely to lead to increased tension between the differing passenger services on the network; however devolution is also likely to add to more tensions between freight and passenger services.  

Page 6 Dashboard
The external benefits including congestion relief of passenger and freight services should be quantified and updated frequently. Rail has strong environmental and safety credentials which need to be highlighted otherwise road will fill the vacuum with details of its improving emissions record, even though it does not compare favourably with rail.

Page 7 - As said in comments on page 6, rail needs to spell out better its economic, safety and environmental benefits.

Page 8 – We support the priority areas outlined in this section.

In answer to your consultation questions

  1. System operation is an essential element of operations for rail freight. We believe that the definition here needs to be developed to properly capture and define the essential elements, especially because of greater devolution.  All the response above highlights the importance we attribute to network system operation.
  2. Transparency is a goal which all the elements of the Government, including NR, ORR and DfT, should work towards.
    Quantifying as well as explaining the full benefits of the railways through metrics which depict the external benefits of rail is crucial if rail is to continue to compete with other modes and receive the Government funding it warrants. 
    We support the metrics in the appendices which highlight the safety benefits of rail.
  3. Greater access to information would help decision making for customers and operators. At the moment, the freight performance statistics do not provide enough detail of route based performance to be useful to customers.               


1. Addendum to Metropolitan Transport Research Unit MTRU 2014 report February 2015. Heavy Goods Vehicles – do they pay for the damage they cause 2014


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