Tees Valley Combined Authority Draft Transport Plan Consultation Submission from Freight on Rail.
Freight on Rail thanks the Tees Valley Combined Authority (TVCA) for the opportunity to comment on its Draft Strategic Transport Plan and associated Rail and Freight implementation plans:
Definition of Freight on Rail - a partnership of the rail freight industry, the transport trade unions and Campaign for Better Transport, which works to promote the economic, social and environmental benefits of rail freight to local, devolved and central Government.
We welcome the Tees Valley Draft Strategic Transport Plan and its Rail and Freight Implementation plans which recognise rail freight’s key role as part of the logistics supply chain in the region and nationally. We would like to make the following points to endorse and augment what TVCA has stated.
As acknowledged in the TVCA Transport Plan, rail freight is a low-carbon clean safe alternative to Heavy Goods Vehicles (HGVs) which reduces road congestion and road infrastructure damage, which can therefore help TVCA meet its three strategic transport objectives.
In fact, per tonne carried, rail freight produces 76 per cent less than HGVs 1 for the equivalent journey so shift to rail can help reduce carbon emissions in Tees Valley, one of the most carbon-intense regions in the UK 2, as stated in the Strategy.
This Government statement illustrates its support for rail freight:
“shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits 3
TVCA identifies that, road transport continues to be the main source of some air pollutants and air pollution 4. Rail freight has lower air pollutants than HGVs. As the FTA states, 5 rail freight offers substantial environmental benefits, compared with carrying the same tonnage by road, producing less than a tenth of the carbon monoxide, around a twentieth of the nitrogen oxide, less than nine per cent of fine particulates and around 10 per cent of the volatile organic compounds. This is true for diesel traction, which provides most rail haulage, while electric trains are even less polluting.
Road and rail complement each other and getting more freight onto rail makeslorries more reliable as well as delivering significant socio-economic benefits. Rail is well placed to offer long-distance consumer services, as well as traditional bulk traffic. Many logistics companies want to use rail as part of their solution for a combination of reasons. These include the serious HGV driver shortage 6, the good reliability of rail as well as their commitment to sustainability. The latest ORR figures on freight train reliability recorded its highest level in the first quarter of 2019/2020 for the past five years showed that 95.3% of trains arrived within 15 minutes of their scheduled arrival time 7.
Rail freight can help build more homes identified as needed 8 by TVCA, by supplying building materials in a sustainable way. The Minerals Products Association 9 estimates that each freight train can carry enough materials to build 30 houses.
- Demand for rail freight
There is pent-up demand for rail freight services because of the capacity and capability constraints on the rail network. Network Rail has forecast that rail freight could grow by around 30% by 2035 if sufficient capacity were made available 10.
- Rail network upgrades needed
We welcome the recognition of the need to upgrade the rail freight gauge route from the port to the East Coast Mainline, which entails the gauge clearance between Northallerton and Eaglescliff 11 to facilitate the most efficient movement of containers and ease capacity issues on local roads. As the rail implementation plan states 12 the lack of gauge enhancements is stifling the port and the lack of capacity and capability is a massive issue. The Freight Implementation Plan also makes the case that the gauge upgrades makes consumer freight more viable 13.
We agree with TVCA that this project should be a key early requirement and priority for the Transport Plan 14 as the document estimates that this work will create an additional 4000 direct and indirect jobs at the port. It is therefore welcome that the scheme is also mentioned in both the Freight Implementation and Rail Implementation Plans.
In our view, this is the first priority as we also agree that the provision of W12 gauge clearance of the line should be viewed as a precursor to electrification of the route.(See section 11 on electrification)
We agree that the gauge clearance could be delivered relatively quickly as only three structures need modification. Currently, there are two DB Cargo UK trains a day from Teesport to Mossend and two GB Railfreight services to I-port Doncaster and there is considerable potential to grow port-related rail freight traffic. For example, Asda and Taylors of Harrogate have depots within the port which can access the rail facilities without having to go on public roads, which reduces the costs of transhipment between the two modes considerably.
It should be noted that the gauge upgrades to W10 on the Southampton route in 2009 led to a rail market share increase from 29 to 36 per cent of intermodal traffic out of the port within a year of completion of the project. A partnership between the South East Regional Development Agency and Network Rail organised the funding with further financial support from local authorities which demonstrates the importance of partnership working. 15 (See section 3 on working with partners)
Capacity upgrades needed on East Cost Mainline (ECML) too
Furthermore, we support the case made for additional capacity upgrades on the ECML 16. As the Transport Strategy states the W12 clearance upgrade will also facilitate the passenger rail service improvements required at Darlington and Middlesborough 17 which demonstrates the synergy between the upgrade of the network for passenger and freight 18.
Furthermore Trans-Pennine upgrades should be freight capable, which is not currently part of the specification which is a serious omission 19.
- Working with Partners
We agree that the TVCA needs to work with other regional bodies such as TfN as well as DfT and Network Rail as the following statement 20 confirms :Working with DfT, TfN Network Rail and partners to prioritise capacity enhancement, electrification, loading gauge enhancements and train capacity along the key rail freight corridors serving the region. For example, the gauge enhancements and the capacity increases on the ECML are being considered by TfN through its work on the Connecting the Energy Coasts and East Coast to Scotland Strategic Development Corridors 21 to inform its emerging long-term Investment Programme for the North as well as by TVCA.
TVCA policy also needs to take into account the Government’s Industrial Strategy.
- Integrated transport and planning decisions
Furthermore, cross border issues are key as transport planning needs to be strategic and look more broadly than within the remit of TVCA,to achieve the best sustainable outcomes for the economy, the environment and society, as acknowledged on Page 45 22. Therefore transport and spatial planning functions need to be integrated so that strategic transport and land-use planning decisions can be made and the necessary land safeguarded for transport 23 24.
- Importance of spatial planning and safeguarding sites for transport
Even though TVAC does not have specific spatial planning powers, the Draft Transport Plan can give direction to local authorities to help ensure that there is complementary, supportive infrastructure to facilitate their ambitions and those of the Combined Authority. We also welcome TVCA highlighting the case for safeguarding rail lands and directing local authorities to do so in local plans. The requirement for rail freight 25 terminals is rightly mentioned as is the safeguarding of suitable sites given that these sites are scarce.
So we support the following wording in the Draft Freight Implementation Plan 26:
Preserve rail network access where the case for retention can be made,as well as other initiatives that can be pursued via the planning process to enable modal shift of freight from road to other modes. This will include TVCA and local authority partners ensuring that suitable facilities are available to enable the transfer of freight to rail or water through the protection of existing sites and the provision of new sites. In pursuit of this we will produce an agreed map showing existing and potential strategic rail freight sites.·Identify and protect key sites for freight-related development, recognising the synergies between assets, e.g. a deep-water port on the East coast, and particular types of industry which rely on imports and/or exports where freight can be a significant cost.·Ensure rail’s potential is considered alongside road when new developments are being considered with an impact on freight flows
Multimodal freight terminals of all sizes required
The fact that more terminals of differing sizes are needed in the region in order to increase rail freight volumesis rightly acknowledged in the Freight Implementation Plan and the Transport Strategy. It must be noted that without more terminals, in the right locations with good rail and road links, it is difficult to significantly increase rail freight volumes.
Mitigation measures of terminals on local communities
Terminals and the surrounding road network must be designed to minimise the local adverse impacts of increased HGV movements, noise, light and air pollution.
In addition to the list on Page 12 of existing rail connected sites the following site should be recorded. Even though the Freightliner intermodal has closed at Wilton 27, it should be noted thatDB Cargo UK.runs daily services from Knowsley on Merseyside to the Wilton energy-from-waste facility located on Teesside.
We support the following text in section 3 of the Draft Freight Implementation Plan 28
Safeguard rail freight infrastructure assets within the Tees Valley map current rail freight assets and work with Network Rail, Freight Operating Companies and companies with rail-connected facilities to ensure: TVCA and stakeholders are fully consulted where Network Rail is selling or leasing rail assets or withdrawing rail assets from the operational network; Rail facilities remain viable; Tees Valley does not lose strategic rail freight assets and capacity: Tees Valley is investment-ready for rail-related opportunities: Future jobs growth
- Safety case for rail freight
Transferring more freight to rail, can reduce the numbers of HGVsand the exposure to road collisions, an identified TVCA aim 29. The latest DfT safety statistics show that HGVs are almost five and a half times (541%) more likely than cars to be involved in fatal collisions on minor roads 30. The graph below shows HGV involvement rate in fatal collisions over the past eleven years broken down by road type.
- Congestion relief benefits of rail freight
HGVs were involved in 43 per cent of critical incidents lasting more than five hours, and 56 per cent of critical incidents lasting more than ten hours on motorways and trunk roads last year 31. This despite the fact that HGVs account for just one in ten vehicles on our motorways.
- The Importance of cross-modal freight solutions need to be highlighted in the Transport Strategy.
Many freight journeys are multi-modal. Road and rail complement each other and getting more freight onto rail makes road more reliable as well as delivering significant socio-economic benefits. Rail is well placed to offer long-distance consumer services, as well as traditional bulk traffic.
Improved connectivity to international gateways including ports will support business activity by providing access to global markets. 32
So, it is important that the draft TVCA Transport Strategy spells out the benefits of cross modal options 33 which would complement the work of the Department for Transport (DfT) which is looking at a Future of UK Freight Strategy to support multi-modal freight solutions. This initiative, which contains a virtual freight unit, is responding to its own Ports Connectivity Study of 2018 which recognised that freight needed more Government support with particular emphasis on intermodal solutions. Greater recognition of the benefits of intermodal freight solutions can help make the case for rail freight, if its considerable socio-economic benefits compared to HGVs, are properly taken into account. The following quote from Government’s Rail Freight Strategy acknowledges these advantages to the economy, environment and society.
“shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits”. 34
- Distance travelled by HGVs
The longer than average road legs, mentioned on Page 7 of the Draft Transport Plan indicate that there could be more scope to shift some of this traffic to rail as rail is more cost effective over longer distances. Therefore, rather than just looking at averages, it is useful to study the following data from the DfT.
The largest HGVs (5+ axles) make many long-distance trips –Almost a quarter (23 per cent) of all their trips are over 300 kms and just over a half over 200 km, eight per cent are over 400 kms. 35
- Efficiency of HGVs
Even though the HGV market is competitive, it is important to analyse how existing HGVs are not being used efficiently 36 and the resulting increase in unnecessary lorry miles. Almost a third of lorries are driving around completely empty; 29 per cent were completely empty in 2018 and 30 per cent were empty 37 in 2016/2017. A DfTspreadsheet.prepared for Freight on Rail,showed that only 32 per cent of lorries were full in terms of volume in 2018; In 2017 the figure was 36 per cent and in 2016 only 34 per cent were full in terms of volume 38.
- The need to invest in rail electrification, the proven low-carbon heavy freight solution
The need to decarbonise freight has brought into focus the need for both HGVs and rail freight, which both have to deal with the same power to weight issues to plan the move away from diesel. That is why rail electrification, the proven solution for rail must be supported by the Government which needs to commit to a programme of electrification 39 to give the rail freight industry the confidence to invest in electric locomotives. Freight locomotives have long asset lives of between 20-40 years unlike HGVs which have asset lives of between seven to ten years. Many of the existing class 66 freight locomotives are now at half-life so research and development is needed now to provide alternative traction solutions for rail freight .Therefore, Government commitment to electrification is needed so that the sector can invest in new electric and bi-mode locomotives.
In fact, the National Infrastructure Commission (NIC) confirms that rail electrification is a “proven technology”, which “could turn out to be cheaper and quicker than other approaches 40 … improving network efficiency and providing wider benefits for passenger services 41, as already demonstrated across Continental Europe. And it also states that “there is currently no commercially available solution to decarbonise the heaviest HGVs”.
The Committee on Climate Change report 42 of 2nd May 2019 supports a rolling programme of rail electrification. Industry expert Julian Worth makes the case for a re-wiring of around 320 key miles over a 10 year period which could see two thirds of rail freight moved by electric traction 43.
Therefore, we believe that electrification must be promoted alongside hydrogen 44. It should be noted that Institute of Mechanical Engineers sees hydrogen as a suitable fuel for local passenger services but not for high speed passenger or freight services 45.
Freight on Rail welcomes the comprehensive support for rail freight as part of its sustainable transport solution in its Transport Strategy and the supporting rail and freight implementation plans.
1. Network Rail Value of Freight 2013
2. Tees Valley Draft Strategic Transport Plan section 2.3 P18
3. DfT Rail Freight Strategy September 2016
4. Idib Page 18
5. Freight Transport Association Helping rail freight deliver for its customers 2018
ORR The Freight Delivery Metric – 26th September 2019
7. ORR The Freight Delivery Metric – 26th September 2019
8. Tees Valley Draft Strategic Transport Plan Page 16
9. Mineral Products Association Why is rail freight vital for housing and construction? 2016
10. Network Rail rail freight forecasts Scenarios for 2033/34 & 2043/44.2019
11. TVCA Rail Implementation Plan Page 31: Freight Implementation Plan Page 22
12. Rail Implementation Plan P15 Page 12
13. Freight Implementation Plan Page 22
14. Draft Transport Plan Page 24
15. Financial analysis £70.7 million project having a Net Present value of £376m
16. Draft Transport Plan Page 16
17. Ibid Page 24
18. Ibid Page 22
19. Ibid Page 22
20. Ibid Page 44
21. Ibid Page 24
22 Ibid Page 45
23. Ibid Page 21
24. Ibid Spatial Planning 4.7 Page 49
25. Ibid Page 35
26. Draft Freight Implementation Plan Page 23 Land use and economic policy
27. Draft Freight Implementation Plan Page 9
28. Draft Freight Implementation Plan Pages29/30
29. Draft Transport Plan Page 43
30. Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017 DfT issued September 2019
31. Source Highways England via FOE on HILO data
32. DfT Connectivity Study April 2018 p6 One of the key findings from my engagement with industry was the need for more consistent cross-modal, cross-government and cross-industry engagement to raise the profile of our ports.
33. TCVA Freight Implementation Plan P5
34. DfT Rail Freight Strategy September 2016
35. Source DfT CSRGT data 2018
36. Transport Strategy Page 7
37. DfT Rail Freight Strategy September 2016
38. DfT Rail Freight Strategy September 2016
39. TVCA Electrification is the answer for rail P35
40. DfT Rail Freight Strategy September 2016
41. National Infrastructure Commission Freight Study April 2019 electrification P73
42. DfT Rail Freight Strategy September 2016
43. DfT Rail Freight Strategy September 2016
44. TransoirtStrategey Page 28
45. Institute of Mechanical Engineers The future of Hydrogen trains Feb 2019