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National Infrastructure Commission interim report: Congestion, Carbon Priorities for National infrastructure.

Freight on Rail thanks the Commission for the opportunity to comment.

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.
There are no set questions on rail and freight so we responded in the following way:

A summary making the case & challenging the negative comments about rail freight in the report
Answering NIC points in interim report
Answering consultation questions where appropriate

Summary
The latest National Infrastructure Commission (NIC) report undervalues the socio-economic importance of existing rail freight services and its potential to further reduce congestion, road crashes and pollution even though the report states that the UK crucially needs to resolve these problems, Most worryingly, it suggests transferring freight back onto our congested road network, despite the fact that rail freight helps solve the very congestion and pollution problems the report highlights.

Given these comments on rail freight, we warmly welcome a separate freight inquiry, based on empirical evidence to support its findings in which we are pleased to take part.. CBT, Freight on Rail and Rail Freight Group were also pleased to meet Phil Graham and Satish Luhar in December and Philippa Edmunds has a meeting booked with Satish at the end of January 2018.

  1. Central Government and devolved authorities policies support rail freight 
    DfT Rail Freight Strategy, Scottish Government’s Rail Freight Strategy, the National Planning Policy Framework and the National Policy Statement for National Networks all support rail freight. So do the TfN, Tfl London Plan and the TfWM policy documents.

    The following DfT quote explains the important role rail freight plays in servicing the UK economy while protecting society and the environment. Shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits 1.
    The AECOM report for the DfT, part of the Rail Freight Strategy work in 2016, studied the potential for transfer to rail from longer distance hauls and found the potential for reducing HGV mileage by 19-20 per cent by 2030 if the rail freight network is upgraded. Furthermore, the UK Climate Change Committee advises that the UK needs to reduce motor vehicle miles (even with an electric fleet) by 5 per cent beyond base to meet our carbon budget.

    The rail freight industry welcomes the Government commitment made to continued investment in the rail freight network as well as the increased funding for railway maintenance and renewals in the Government’s recent Statement of Funds Available announcement.  Freight on Rail will be making a strong socio-economic case for continued Government rail freight investment, for which no figures have been given as yet for the next five year period from 2019-2024
     
  2. Recent polling showed that almost two thirds of the public want to see more freight on the railways with only 2 per cent wanting to see more freight on the roads, while other polls have shown deep public suspicion of autonomous vehicles. By contrast, our recent research shows that increased rail freight could make a real difference to congestion and pollution on some of the country's most overcrowded roads. 
     
  3. The economic, safety and environmental case for rail freight

    Supporting productivity
    The socio-economic benefits generated by rail freight delivers economic benefits totalling £1.6bn per year [1].  This includes productivity gains for British businesses of around £1.1bn and congestion and environmental benefits of over £0.5bn per annum.

    Congestion costs UK £30 billion a year according to Inrix’s latest figures with the UK ranked the fourth most congested developed country and third most congested in Europe. Rail freight could and should be part of the solution; shippers and construction firms are crying out for more rail freight services which are constrained by the rail network.  
     
  4. Rail freight continues to grow in key markets
    Rail freight has experienced a period of adjustment and transition as a result of the steep decline in coal traffic. Despite this challenge, it 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. Quarter two rail freight figures show continued record growth in key consumer and construction markets with the other category including biomass and mail traffic growing 23 per cent since the same quarter last year.
    The largest commodity group is now domestic intermodal which grew by 6 per cent last year reaching 6.8 billion net tonne-km. Rail freight has been improving its performance; 87% of trains within 15 minutes of due time.

    Freight moved by commodity and change since 2013/14:

    Diagram: Freight moved by commodity and change since 2013/14
     
  5. Rail freight projects have high cost benefit ratios
    Targeted rail freight upgrades work; the gauge upgrades out of Southampton Port increased rail’s market share from 29 to 36 per cent within a year and had a benefit-cost ratio of five to one.
     
  6. Differences in external costs between rail and HGVs
    Congestion
    An average freight train can remove 70 HGVs whereas an aggregates train can remove up to 136 HGVs – Source Network Rail Value of Freight 2013
     
  7. Carbon dioxide emissions (CO2)
    Road 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
     
    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. 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 and van emissions can be reduced significantly, the DfT has stated that it expects the existing HGV diesel engine technology to be predominant well into the next decade.
     
    Government will struggle to meet its CO2 reduction targets  unless it improves efficiency of road freight and supports rail freight

    Reducing emissions from road freight is expected to be challenging-however, it will be very difficult to meet the 2050 goals without major reductions in GHG emissions from Heavy Goods Vehicles according to Aecom report ECO-driving for HGVs dec 2016
     
  8. Air pollution
    Rail freight is 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. 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
     
    Rail freight’s long-term role in reducing non-exhaust particulates
    While the latest euro VI engine technology reduces exhaust particulates,  non-exhaust particulates pollution from HGV tyres and brakes, which is hard to reduce for trucks, will remain a serious problem for which there is no current solution, especially for trucks which have large tyres. 
     
    Non-exhaust particulate emissions will also continue to be a considerable health risk for electric cars and vans, a point which has not been widely acknowledged todate. 
     
  9. HGV Safety issues
    Supporting rail freight is a great way for the Government to reduce road deaths as HGVs are disproportionally involved in fatal road crashes because of their size and scale.  This graph shows HGV involvement rate in fatal crashes on different road types over the past ten years, where conditions are very different, based on the percentage of miles they represent.

    The latest Government figures for 2016 show that HGVs are almost seven times more likely than cars to be involved in fatal collisions on minor 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 them. Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT

    Graph showing Involvement in fatalities - HGVs iver 3.5 tonnes compared to all traffic

    Table 1 Involvement rates for HGVs

     

    Fatalities

    KSI

    Road type

    Rate per billion veh km

    Rate per billion veh km

    Non-built up A

    13.6

    56.3

    Motorway

    2.5

    15.7

    Weighted average

    6.8

    30.8

    Source: RAS 30017, TRA 0204, MTRU calculation

  10. Road infrastructure damage
    Lorries do cause far more damage to foundations and structures of roads than cars because the damaging power rises exponentially as weight increases. This is called the Generalized Fourth Power Law. The standard six-axle44 tonne 16.5 metre truck is 138,000 times more damaging to road surfaces than a Ford Focus. Therefore some of the heaviest road repair costs are therefore almost exclusively attributable to the heaviest vehicles.

    Social exclusion costs of HGVs
    Passenger and freight rail are far less intrusive than roads. Rail is considered less intrusive than road noise.  The width of land surface taken up by a double railway line is only 12 metres compared with 47 metres for a three lane motorway.

    Detailed comments relating to Interim report & consultation questions

    10.NIC report Page 82
      states that rail becomes more competitive over long distances – In fact long distance consumer and traditional bulk rail freight is in fact competitive. So, if more of the long distance large HGV traffic, a quarter of which are doing journeys over 300 kms, can be transferred to rail, there will be better reliability for all road traffic as well as reducing exposure to road collisions and pollution. This should include looking at urban logistics with rail served consolidation centres incorporated in City plans. 
     
  11. Ref NIC report Page 76 figure 2.5 NIC Interim report states that road freight has doubled over last 50 years. But the report does not recognise the key reason is that HGVs are heavily subsidized and only pay around 30 per cent of their external costs, making it difficult for rail and water to compete. See section 20 Page 20 for details
     
  12. Customer demand for more consumer and construction rail freight services is currently constrained by the lack of space on the rail network. So, the Government should upgrade key rail freight routes and set affordable freight access charges in the forthcoming review in recognition of rail freight's socio-economic benefits to avoid gridlock and control air pollution. If rail freight is undermined there will be more congestion, pollution and crashes.
     
  13. Ref NIC report Page 76 The report acknowledges that urban freight is often overlooked, but it does not recognise that rail freight should have a role in the following:-
     
    1. Delivering long distance consumer freight into rail connected hubs for transhipment into low emissions vehicles.

    2. Servicing the aggregates market - rail already delivers almost 50 per cent of London’s construction materials and could deliver more if extra rail freight terminals come on stream. Each freight train can deliver enough materials to build 30 houses. Rail delivered the materials and removed spoil for CrossRail and the Olympics. Colas Rail undertook two separate trials into Euston with Sainsburys and TNT where full freight trains came into Euston at night for transhipment of cargoes into low emissions vehicles for the last mile delivery. This model could be adopted in other city centre rail terminus at night.
       
  14. NIC report is quoting DfT statistics which used average figures rather than corridor analysis ref NIC report P83
    The report uses national averages in transport planning, instead of analysing individual corridors where there are parallel rail routes, which as in this case, can be misleading. Furthermore, the NIC is pinning its hopes on lorry platooning, which is in its infancy for dense road networks like the UK, whereas rail freight is already removing  large numbers of HGVs from key transport corridors each day. There is considerable suppressed demand for more consumer and construction rail freight services on key corridors such as the A14, A34 and M6, so capacity upgrades could remove serious numbers of the large long-distance lorries from congested routes.

    For example, the 33 freight trains in and out of Felixstowe already remove around 2,500 lorries per day off the congested A14 corridor. Rail freight could be increase by 50 or 60 per cent on both the A14 and A34 out of Southampton Port within the next five to seven years based on a combination of current funded CP5 Network Rail projects and the, as yet, unfunded proposals in the Network Rail Freight Network Study for the Control Period 6 until 2024.

    See our DfT sponsored corridor research , Impact on congestion of transfer of freight from road to rail on key strategic corridors,
     
  15. Reference NIC question 9
    Need for cross-modal transport planning instead of merely using averages

    Our Department for Transport (DfT) sponsored research, Impact on congestion of transfer of freight from road to rail on key strategic corridors, confirms what we have long argued, that integrated rail and road planning is the best way to reduce road congestion, collisions and pollution. It shows that on certain strategic transport corridors it is possible to improve road conditions without needing to add more road capacity. If long distance consumer freight and construction materials can be transferred to rail, the productivity and reliability of existing road services will improve.

    DfT statement which supports corridor analysis and recognises that integrated rail and road planning into a cross-modal approach is the best way to reduce road congestion, collisions and pollution. DfT said: "We agree with the Campaign for Better Transport that rail freight offers real benefits for the environment and helps keep bulky loads off of the road network, helping to ease congestion for other motorists. We look forward to using these findings to help inform our coming road and rail strategies and are committed to working with the rail freight industry to support growth of the sector.”
     
  16. Further corridor research shows that transferring just 2000 lorry loads a day from key corridors reduces nitrogen oxide emissions by 10 per cent and particulates by 7 per cent per corridor
    We augmented the original corridor congestion research (above) to measure the reduction in air and carbon dioxide emissions as well as the safety benefits of rail transfer on the same key corridors.  Our finding show that NO2 emissions could be reduced by 10 per cent and particulates by 7 per cent on each corridor of the four corridors we examined. Furthermore, national carbon dioxide emissions could be reduced by 2.5 per cent and killed and seriously injured figures reduced by 18, nationally.
    In particular it highlights rail’s long-term role in reducing non-exhaust particulates from brakes and tyres, which make up over half of particulates, for which there is no current solution, especially relevant for trucks which have large tyres.
    http://www.bettertransport.org.uk/new-research-shows-just-2000-less-hgvs-would-mean-ten-cent-reduction-air-pollution
     
  17. NIC Question 12
    Use rail freight instead of road freight to deliver materials to railheads near infrastructure projects, where practical. Examples use CrossRail and Olympics used for both delivery of construction materials and removal of waste.
     
  18. NIC Question 20 Autonomous vehicles - Lorry platooning
    The NIC should give priority to increasing the use of sustainable freight modes and making more efficient use of existing trucks rather than new technology which, while technically interesting, is likely to have very limited real world benefits in the UK. 

    Lorry platooning with driverless rear trucks could unquestionably reduce road haulage costs, but presents serious road safety risks, especially in bad weather, on our congested road network as highlighted by motoring groups. While the proponents state that the rear lorries will have drivers now, the longer term aim, given that the technology is expensive, must be to run without rear drivers as their wages make up around a third of the traditional HGV running costs. It could also make it harder for independent hauliers, who still make up a large element of the sector, to compete with the big logistics providers 2. That is why there has been mixed reaction for the measure from hauliers and their representative bodies. Platooning could help the industry overcome its shortage of drivers, though.

    While platooning could be viable in sparsely populated countries, there are serious safety and practical obstacles, such as cyber-crime, in allowing a procession of lorries on our congested motorway network which has frequent exits close together. Other outstanding issues include where these conveys will assemble and how they will work with so-called smart motorways, without hard shoulders for emergencies.

    Platooning, which is expected to reduce pollution by around 10 per cent, could seriously undermine rail freight which reduces congestion, is far safer and produces 76% less carbon dioxide emissions and up to fifteen times less NOx and 90% less particulates than trucks.

    Changes to design of roads for autonomous vehicles.
    Platooning could also increase road damage costs; the standard truck is 138,000 times more damaging to road infrastructure than a Ford Focus.

    Additionally, driverless lorries are likely to need higher quality and more uniform road infrastructure and markings.
     
  19. Inefficiency of HGV operations in UK
    Road freight is competitive but not efficient. Government figures show that nationally 30% 3 of lorries are driving around completely empty, a figure which has been growing for some years. According to DfT figures only 34% 4 of HGVs were constrained by volume, 13% by weight and only 19% limited by weight and volume in 2016 which show the potential to increase vehicle load factors by between 30-45% with the right policies.
     
    The DfT latest domestic road freight statistics report and its statistics confirm this behaviour and 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. DfT statistics show that 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, maximum weights allowed at the time and since the increased allowance to 44 tonnes in 2001, 22% of HGVs were at the maximum weight again.
     
    The reality is that the large logistics operators may get reasonable utilisation out of trucks but medium and smaller sized operators who account for the majority of the industry do not use their trucks efficiently. 94% of UK HGV fleet operators had fewer than 10 vehicles and approximately 50% of operators were owner drives licensing just one vehicle. Source – Energy and Utility skills report 2013.
     
  20. Lack of Internalisation of HGV costs
    As mentioned earlier, HGVs are only paying around 30% of their costs as there are no effective current charging mechanisms which distorts the freight market. This lack of parity makes it difficult for rail to compete on price and that is why the DfT awards Mode Shift Benefits grants in recognition of reducing freight’s external costs. Because HGVs are heavily subsidised and pay less than a third of the costs associated with their activities, it is difficult for rail to compete, especially in the consumer market, unless it is similarly compensated. We therefore believe that the Government needs to recognise road costs, such as road congestion, road collisions, road damage and pollution in any discussion about rail freight costs. The latest research commissioned by Campaign for Better Transport, which used DfT Mode Shift Benefit values, found a high level of distortion of the market across modes - which equates to an annual subsidy of around £6.5 billion. The latest revelations show that there is a strong case for equivalently supporting rail through lower rail freight access charges and continued upgrades to the Strategic Rail Freight Network and other key routes in order to allow rail to compete more fairly with HGVs. Otherwise, HGVs’ external costs 2 will continue to be a huge problem to society and the economy.
    Dangerous, dirty and damaging - New research reveals impact of HGVs
    DF files: 

    2015 addendum to 'Heavy Goods Vehicles - do they pay for the damage they cause?'

    New research: Britain’s lorries receiving £5bn annual subsidy


    Heavy Goods Vehicles - do they pay for the damage they cause?

    These conclusions are in line with two separate pieces of research

    1. MDS Transmodal study in 2007 which found a very similar amount of underpayment: £6billion.
    2. Transport & Environment Research April 2016 which also found that HGVs across the EU were only internalising around 30 per cent of their costs.
      Are Trucks Taking Their Toll?

    Whilst we recognise that road and rail freight must work together to deliver efficient logistics for the UK, we do believe that all HGV’s external costs must in future be taken into account when examining options for rail freight costs and charges, and decisions around capacity. Distance based lorry charging with the right criteria could overcome these problems. See section 22 Page 10

    The following quotation from the DfT Rail Freight Strategy shows that this is not currently the case. “[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. These benefits are not currently recognised in the track access charging” - Rail Freight Strategy of September 2016; p. 42, para 135.

    Therefore, we urge the Government to provide longer-term affordable track access charges for Control Period 6 (2019-2024 and beyond to give operators and customers certainty to invest.

    Whilst we recognise that road and rail freight must work together to deliver efficient logistics for the UK, we do believe that all HGV’s external costs must in future be taken into account when examining options for rail freight costs and charges, and decisions around capacity. Distance based lorry charging with the right criteria could overcome these problems. See section 22 Page 10

    The following quotation from the DfT Rail Freight Strategy shows that this is not currently the case. “[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. These benefits are not currently recognised in the track access charging” - Rail Freight Strategy of September 2016; p. 42, para 135.

    Therefore, we urge the Government to provide longer-term affordable track access charges for Control Period 6 (2019-2024 and beyond to give operators and customers certainty to invest.
     
  21. NIC Question 21
    Rail electrification, which is proven technology, can solve rail’s capacity problems, reduce maintenance costs and help the Government reduce both CO2 and air pollution to meet CO2 targets and legal air pollution limits. 
     
  22. Ref NIC question 22
    Distance based lorry road user charging could tackle lack of internalisation of HGV costs and also pave the way for wider road charging for cars and vans.

    The Treasury has issued a call for evidence to review the existing time based system, introduced into the UK in 2014, with the stated aim of improving efficiency and reducing air pollution.

    The existing time based system was designed to make foreign hauliers contribute and is largely revenue neutral for UK hauliers so it is not making HGVs pay for the impacts they have in terms of miles driven and therefore the congestion, infrastructure track costs, pollution and safety impacts. (See section 20  Page 9 with details showing that HGVs are only paying around 30% of their external costs.) 

    We see this as an opportunity to make the case for a distance based system which we urged the Government to adopt in 2014. In the EU, 15 countries have distance based systems and 11 have time-based ones, the latter are proposed to be phased out by 2024 in the Commission’s forthcoming review. 

A distance-based lorry charging scheme could improve HGV efficiency, reduce air pollution and congestion, improve road safety and allow sustainable modes to compete more fairly. Currently, road haulage is very competitive but not efficient as section 19  explains. Distance based systems can measure the actual impact lorries have on other road users, the environment and infrastructure and price the impacts accordingly.

Benefits of distance based charging in Europe

German Maut
Distance based systems on the Continent have greatly reduced the number of lorries driving around completely empty (empty running) and improved efficiency. The German Maut reduced empty running from 29 to 18% over a seven year period to 2008. Since 2008 empty running reduced another 1% to around 17%. In the UK, empty running has been increasing and was 30% in 2016 up from 29% the previous year.

Tolls can be beneficial to society without placing unbearable financial burden on freight transport and have not had a noticeable impact on consumer prices.

In Germany the price of operating a trucks is around 1 euro per vehicle-km including driver, vehicles and fuel. The toll is approximately 10% of these costs. Hauliers can pass on the majority of tolls for loaded trips to shippers and forwarders, the resulting costs increase remaining with the trucking business is 2% to 5%.

German system supports the purchase of cleaner trucks euro V & VI. Between 2005-2009 euro V and IV rose from 2 to 62%.

Tolls have reduced tonne kilometres in Germany because of better loading rates. The German Government has been using revenue from tolls to provide discounts for hauliers to purchase less polluting trucks. Smaller companies get a bigger subsidy so the revenues are used to support SMEs when buying new trucks.

Austria
In 2013 the introduction of the kilometer-charging for trucks reduced the percentage of empty vehicles in Austria from 21,1% in 1999 to 15,7% in 2004. At the same time the average load grew 0,6 Ton  to 14,7T. https://www.vcoe.at/news/details/lkw-maut-in-oesterreich-ausweiten

EU Eurovignette
Currently, the eurovignette allows member states to charge for kilometres driven, infrastructure wear and tear and air pollution. The EC wants to extend the toll to allow for differentiation based on the CO2 performance of trucks.

Tolls currently apply for all lorries starting from 7.5 tonnes but Commission is suggesting it should be from 3.5 tonnes in the future. But there is a danger that if you charge small lorries, people will use big vans instead which are already much cheaper to run because of the lighter regulations.

We recommend a distance based system with the following criteria:-

  • KM charge
    Should apply to all road types to avoid use of unsuitable roads to avoid tolls
  • Charging differentiation for air pollution based on different euro engines
  • Charging differentiation based on the CO2 performance of trucks. The VECTO software currently being developed by the Commission would allow this. Currently there are no standards or reduction targets for truck CO2 emissions unlike cars and vans. VECTO is the first stage which will allow the measurement. 
  • Collisions costs – see table  1
  • Difference charges for different weights and lengths of trucks. For example, in UK longer semi-trailers should pay more than standard 16.5metre 44 tonne trucks
  • EC wants to charge more for mega trucks but seeing the UK wants to avoid mega trucks agreeing their introduction should be avoided in UK.

The weighted average vehicle involvement rates are set out below.

Table 1 Involvement rates for HGVs

 

Fatalities

KSI

Road type

Rate per billion veh km

Rate per billion veh km

Non-built up A

13.6

56.3

Motorway

2.5

15.7

Weighted average

6.8

30.8

Source: RAS 30017, TRA 0204, MTRU calculation

 



1. DfT Freight Carbon Review February 2017. P43 Key messages

[1] KPMG

2. In fact, 94 per cent of UK HGV fleet operators had fewer than 10 vehicles and approximately 50 per cent of operators were owner drives licensing just one vehicle. Source – Energy and Utility skills report 2013.

3. Source DfT empty running figures Table RFSO117 July 2017, 2015/2014 were 29%.

4. DfT CSRFT data for 2016  issued in 2017 for Freight on Rail



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