England’s Economic Heartland (EEH) Outline Transport Strategy: Framework for Engagement.
Freight on Rail thanks EEH for the opportunity to comment on its Outline Transport Strategy: Framework for Engagement, which will subsequently be referred to as the Transport Strategy in this document.
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.
EEH rightly recognised in its Freight Study, to which we contributed, that rail freight has a key role in the region given its socio-economic benefits to the region and wider country. While the Freight Study identifies the existing flows and terminals and makes the case for increased levels of rail freight investment to increase freight modal shift, we believe that these policies also need to be strongly articulated in the Transport Strategy. So we welcome EEH’s support for the expanding rail freight as the following example states:
We will therefore ensure that the overarching Transport Strategy sets out a framework that will support the development of cleaner forms of haulage, including greater usage of rail freight where appropriate 1.
The following are the Freight on Rail detailed comments on England’s Economic Heartland’s work to better address the needs of the freight and logistics sectors on Page 84
- Identifying the way major infrastructure projects can be optimised to meet freight needs, enabling better east-west access to international gateways and addressing lorry parking challenges
The reinstatement of the East-West rail route can transform the much needed east-west connectivity in the region. The region has a considerable number of traditional radial routes from London and EWR will transform it into an orbital network. For example, in rail freight terms, EWR provides an opportunity to support the construction of new businesses and housing sites as well as providing an alternative route for container traffic between Felixstowe and the Midlands. Therefore, it is crucial that EWR has both freight capability and capacity. See section 4 b for full details of the freight case.
- Collecting and improving the quality and availability of freight data at the regional level by creating a repository of information to inform future interventions and smarter consolidation
Access to up-to-date freight data is crucial if EEH is to make the most informed decisions and recommendations about investing in transport infrastructure.
And we agree that it is important that EEH works to take on board the key recommendations of the National Infrastructure Commission (NIC) Freight Study. In particular:
- More accurate freight data is needed especially up to date comparative road and road emissions data 2.
- Spatial planning which supports the needs of freight logistics 3
- Identifying a network of Strategic Rail Freight Interchanges and rail terminals to address gaps in provision, reducing strategic road traffic and supporting the growth in housing and infrastructure to ensure materials are carried as close as possible to construction sites
The above text is welcome but we believe that the words by rail should be inserted after the words construction sites as above in the bottom left-hand bullet on Page 84 of the Transport Strategy.
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 volumes, was mentioned in detail in the Freight Study in paragraph 8.13 and is recognised in 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. In particular, terminals will be needed to supply materials for infrastructure building.
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.
The strategy highlights the role of strategic rail freight terminals in achieving modal shift and sites the importance of the Daventry International Rail Freight Terminal (DIRFT) which is a rail-connected storage and distribution centre of national significance in the region. The strategy rightly identifies the need for more such terminals to provide a network of such terminals (Transport Strategy P80). The Freight Study recognises the role of SRFIS in 6.4.2 and states that more floor space at SRFIs leads to more rail freight traffic. The Freight Study mentions the 23 active rail freight terminals in the Heartland handle a mixture of intermodal containers, construction materials, domestic waste, automotive and metals 4.
As more rail freight interchanges become operational there is further scope to transfer traffic to rail. For example, the existing strategic rail freight interchange at Daventry removes 23 million HGV miles a year, most of which would otherwise be on trunk roads. See breakdown of this figure in the following link. http://www.freightonrail.org.uk/PressRelease22-05-2017-rail-freight-better-at-reducing-congestion.htm
- There are currently two applications for strategic rail freight terminals in Northamptonshire in the planning process which demonstrates the level of market interest in SRFIs.
- Northamptonshire Gateway – Roxhill – Development Consent given on 9/10/2019
- Northamptonshire Rail Central – Ashfield Land Management is less developed. The Examining Authority Planning Inspectorate (PINS) will carry out an Initial Assessment of Principal Issues derived from its reading of the application and the relevant representations received and set a date for the Preliminary Meeting.
- Working with Network Rail and partners to prioritise capacity enhancement, electrification, loading gauge enhancements and train capacity along the key rail freight corridors serving the region
The EEH’s acknowledgement (in the closing the gap section on Page 83) of the need to reduce the impacts of construction, helps make the case for rail freight which can deliver construction materials and remove spoil in a low carbon, safe mode, which also reduces road congestion 5and road infrastructure damage 6.
a) All the following corridors are critically important for rail freight as highlighted in the Transport Strategy
The M1/West Coast Mainline corridor which passes through the heart of the region is a key freight artery and carries the highest volumes of rail freight of any route.
Given the need to reduce carbon dioxide emissions, serious road congestion and a lack of east-west rail routes, serious attention should be given to the potential of the rail network to accommodate a higher proportion of future travel demand. The outcome of the review commissioned by EEH into rail services is an important opportunity to make the case for serious investment in the rail freight network as referred on P41 under the section on realising the potential of the Rail Network.
The West Coast Mainline, Reading to Banbury and routes from Felixstowe, which include the Great Eastern Mainline and Felixstowe to Nuneaton, see high volumes of containerised freight. Freight needs to get it fair share of released capacity from HS2.
The Midland Mainline is particularly dominant for construction materials
The new rail corridor to support planned growth from Northamptonshire to Old Oak Common will be important for freight.
Rail Freight Priorities:
The Transport Strategy has rightly identified on Page 43 that the following rail route capacity constraints need addressing.
Improving North South Connectivity between Northampton and Old Oak Common.
Addressing capacity restraints on routes serving Cambridge Oxford to Didcot
Expanding capacity on port routes from Southampton and Felixstowe to the Midlands and beyond.
b) Freight case on East West Rail (EWR) needs to be a priority
The reinstatement of the East-West rail route can transform the much needed east-west connectivity in the region. The region has a considerable number of traditional radial routes from London and EWR will transform it into an orbital network. For example, in rail freight terms, EWR provides an opportunity to support the construction of new businesses and housing sites as well as providing an alternative route for container traffic between Felixstowe and the Midlands. Therefore, it is crucial that EWR has both freight capability and capacity.
To drive the expected economic growth in the region significant investment in infrastructure will be needed and that will require a supply of construction materials for at least the next 30 to 40 years. The rail system can help to supply these materials, removing lorries from the roads and delivering environmental benefits too 7. Freight on Rail believes that more aggregates rail freight terminals will be needed to service the house building in a sustainable way. A typical house needs 50 tonnes of aggregate equivalent, which rises to 200 with associated infrastructure and with one HGV moving around 20 tonnes, there is a real potential to bring some aggregate materials in by rail. For example, almost fifty per cent of aggregates are delivered into London by rail and there is demand for more rail services into the capital 8.
As the Transport Strategy states, (in the closing the gap paragraph on Page 83) Taking forward more detailed feasibility work with other regional bodies and Network Rail to quantify the level of freight demand along East West Rail, particularly given the growth in intermodal and construction materials that may necessitate the provision of track access paths is crucial.
We urge EEH to be a strong supporter of freight capacity and capability on EWR given the clear demands for construction materials to be transported along this corridor to build housing and the benefits of using a combination of road and rail. We welcome the fact that EEH’s Transport Strategy expects to see this region playing a significant ongoing role in logistics distribution, mentioning the key east-west rail links and rail freight’s role in the section on improving rail connections to the east of Cambridge, stating the benefits of increasing opportunities for freight from Felixstowe offering an alternative route to the West Midlands P60.
So, we believe that the Transport Strategy could more explicitly mention the benefits of enhancing rail freight in line with what the Freight Strategy says in paragraphs (6.8.9 – 6.8.12, see extracts below)
6.8.9 The East West Rail Company has asserted that capacity for more freight trains could be provided as long as demand could be demonstrated and a business case put forward. The potential demand for rail freight is cited in the Freight Study on Page 68 8.13, 8.14
The Central Section consultation states: “The current indicative cost estimates are based on building a rail link that accommodates all types of rail freight. EWR Co will continue to consider whether providing capability for all types of freight is affordable and provides value for money in the context of anticipated freight demand.”
6.8.11. A key feature of EWR is that it provides links between the various London radial routes (Oxford corridor, WCML, MML, and ECML). To maximise freight potential, ideally each route should provide connections in all directions, although this aspiration could be refined by researching freight opportunities in more detail.
6.8.12. This aspiration would suggest that proposals which provide interchanges between EWR and other routes without any form of rail connection should be avoided.
Delivery of East West Rail is a key element of the new multi-modal east-west spine across the Heartland region as the Transport Strategy states on Page 35 and we believe it must be freight enabled. Funding has now been made available to Network Rail to complete EWR’s western section between Bicester and Bedford and Milton Keynes and Princes Risborough by 2024, including freight capability for the Bletchley flyover.
The situation for the central sections is less favourable for freight. However, delivery of the ‘Eastern Section’ – with improved services east of Cambridge to Norwich and Ipswich – could also an integral element of the overall project as long as offering alternative east-west connectivity for rail freight port services as highlighted on Page 60 and preciously mentioned. Delivery of these improvements could be achieved in advance of the Central Section, as recognised in the EEH Transport Strategy on P38.
c) The need to invest in rail electrification, the proven low-carbon heavy freight solution
Therefore we fully support the following statement -Working with Network Rail and partners to prioritise capacity enhancement, electrification, loading gauge enhancements and train capacity along the key rail freight corridors serving the region
So the Government needs to commit to a programme of electrification so that the rail freight industry has the confidence to invest in electric 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 9 … improving network efficiency and providing wider benefits for passenger services” 10, 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 11 of 2nd May 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 12.
d) Pent-up demand for rail freight and scope for modal shift on key freight corridors
There is suppressed demand for rail freight services due to limitations of the rail network as identified in the EEH Freight Study which needs to be fully articulated in the Transport Strategy. We agree that the Freight Study has provided a solid understanding of how freight operates and the demand for more rail freight services.
Paragraph 11.4.10 on Page 114 in the Freight Study, demonstrate the demand for rail freight services. The MDS study estimates that capacity constraints at key locations could constrain growth in their highest growth scenario to 120 million tonnes from 128 million tonnes, a reduction of 6.6%. In tonne kilometre terms the reduction would be 9%. In future years, as potential demand grows, the impact of these pinch points would be even greater.
However, the opportunities and benefits of rail freight growth to the economy, society and environment need to be highlighted in the Transport Strategy as well to help make the case for investment.
e) How rail freight already services key freight corridors and scope for further modal shift
For instance, the high levels of HGV movements on the A14 and A34 corridors are mentioned in the Transport Strategy section Freight and logistics in the Heartland today noting that the A14 and A34 that provides access to deep sea ports in Southampton and Felixstowe sees high volumes of HGVs. Therefore,the importance of the parallel rail freight routes need to be stressed to demonstrate not only the potential to shift more freight to rail but also to demonstrate the socio-economic benefits of what rail already does:
The scale of existing rail freight services & how it facilitates sustainable freight distribution and removes large numbers of lorry movements
Currently, there are 20 daily intermodal freight trains in and out of Southampton which remove around 1,600 HGVs each day. Additionally there are six automotive services – six trains in, six trains out each day. Rail now represents around 36 per cent market share, having risen from 28 per cent since the route was gauge cleared for intermodal wagons 13.
The latest upgrade of the Felixstowe branch line, which has just been completed, means that there is now capacity for 43 trains in and out of Felixstowe each day. Previously, it was 33 trains. Each of these deep-trains carrying deep sea containers can remove around 100 HGVs as each rail wagon can take one 40ft and one 20 ft container.
Potential to transfer more freight to rail if the relevant rail network is upgraded
The Freight on Rail research, sponsored by the DfT showed that the transfer to rail on key transport corridors where there are parallel rail routes, has congestion, pollution and accident reduction benefits. The MTRU research issued in April 2017, sponsored by the DfT, shows that transferring the equivalent of 2000 HGVs a day to parallel rail routes on A14,34, M6 and M62 corridors could significantly reduce road congestion 14.
The research found that upgrading existing rail lines, which run parallel to the motorway routes and are currently nearing full capacity, would allow large numbers of these lorry loads to be transferred to rail. This would help road congestion - because of the extra road space taken by lorries, transferring 2000 lorry loads a day to rail would be the equivalent of taking 8000 cars off the road. As more rail freight interchanges become operational there is further scope to transfer traffic to rail. For example, the existing strategic rail freight interchange at Daventry removes 23 million HGV miles a year, most of which would otherwise be on trunk roads.
DfT sponsored research two A roads have up to 6,500 of the largest HGVs (5 and 6 Axle articulated lorries) on the corridors each day, between 10 per cent and 17 per cent of all traffic, and the M6 motorway has over 13,500 of the largest HGVs a day and on the M62 over 11,000. This represents 10-12 per cent of all traffic on the two motorway sections.
Research showed just 2,000 less HGVS would mean a ten per cent reduction in air pollution.
Further research on the same corridors showed that removing 2000 HGVs per day could reduce NOx by 10 per cent, particulates by 7 per cent on each corridor as well as reducing overall national CO2 emissions by 2.5 per cent and killed and seriously injured by 18. 15
Our corridor work showed that on key freight corridors such as A14 and A34 and M6, enhancing rail freight network could significantly reduce road congestion on these key routes.
- Developing regional standards and best practice principles on goods delivery restrictions, delivery and servicing plans and solutions for deliveries into historic cities and towns, to ensure the needs of these services are more obviously recognised in land use and spatial planning practice
We support the EEH commitment to take forward more detailed feasibility work with other regional bodies and Network Rail to quantify the level of freight demand along East West Rail, particularly given the growth in intermodal and construction materials that may necessitate the provision of track access paths on Page 84.
Its international links are a priority as are the links with other regions so the collaborative approach with other regional authorities, adopted by EEH is key to maximising the benefits of strategic freight corridors to get integrated cross-modal national and international solutions.
The Transport strategy mentions working with Midlands Connect on cross border issues but it is also crucial that EEH works with all the regions, such as Transport for the South-East and Transport for the North, to plan integrated coherent strategies across the country.
The need for partnership working is also recognised in the Assessing Goods & Services section on P81 which states that a future-proofed approach to managing the access to goods and services across the region can only be achieved through partnership working, and a commitment to align all of the factors that together create community spaces – transport provision, land use planning, public amenity provision and businesses.
- Question 17 How will the way we access goods and services continue to change, and what are the key issues that need to be addressed in the Transport Strategy?P84
Integrated transport and spatial planning needed
The importance of integrated transport and spatial planning policies cannot be overlooked. Therefore, the Transport Strategy is an important document to give guidance to local authorities, who have spatial and transport planning responsibilities in the region. We agree that in the recent past, the lack of integrated local, regional and national freight policies has left the logistics industry with uncertainty. Therefore it is important that the Transport Strategy includes all the important policy points about rail freight made in the EEH Freight Strategy to address the acknowledged freight policy vacuum mentioned in the Transport Strategy on Page 82 - an absence of local policy and national strategy has left the industry with uncertainty. We will therefore ensure that our Transport Strategy addresses this policy vacuum.
Furthermore, both the Freight Study and the Transport Strategy must be aligned with the Government’s Industrial Strategy.
Despite all the changes in how the public access goods and services, the role of rail’s heavy freight traffic, whether it is consumer or bulk traffic, to service the supply chain will continue to be a vital part of the supply chain. In fact, the changes to urban logistics and the need to reduce emissions and road congestion, make rail freight’s case even stronger. Rail can be used for the long-distance trunk operations to the edge of conurbations or into city terminals for onward transfer to low emissions vehicles. So, it is vital that EEH Transport Strategy plans a robust cross modal transport network to support these services which recognises the importance of heavy freight provision.
- Question 18 What freight and logistics services are important for people and businesses? For example, accessing goods (via delivery or in person); a thriving high street; access to health, education and leisure facilities?
Many logistics companies want to use rail as part of their solution for a combination of reasons. These include the serious HGV driver shortage 16, 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 17.
- Question 19 Just in time and last minute operations are affecting the way people and businesses access goods and services. How should this growing trend affect the way we plan transport now, and in the future?
a) 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 lorries 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. The serious HGV driver shortage is yet another reason why the rail alternative is crucial; the average age of drivers in the UK now 53, with only two per cent of drivers under 25 18.
Improved connectivity to international gateways including ports will support business activity by providing access to global markets freight is important.19
So, it is important that the EEH Transport Strategy spells out the benefits of cross modal options 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 20. 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, as the following Government’s Rail Freight Strategy quote highlights.
“shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits”. 21
b) Improving freight efficiency
The references to reducing the unwanted impact of freight and smarter freight management on Page 80 need to take the following points into account:
In terms of freight efficiency, it is important to analyse how existing HGVs are not being used efficiently even though the market is competitive and the resulting increase in lorry miles. Almost a third of lorries are driving around completely empty; 29 per cent were completely empty in 2018 and in 2016/2017 30 per cent were empty 22. A DfT spreadsheet prepared for Freight on Rail showed that only 32 per cent of lorries were full in terms of volume in 2018, 36 per cent in 2017 and only 34 per cent were full in terms of volume in 2016 23.
Rail freight has considerably lower external costs than HGVs 24 therefore it is important that EEH supports modal shift, 25 where viable. Therefore we welcome the following comment in the EEH Transport Strategy, We will therefore ensure that the overarching Transport Strategy sets out a framework that will support the development of cleaner forms of haulage, including greater usage of rail freight, where appropriate.
The Freight Study provided a solid understanding of how rail freight operates and its benefits to the economy and society which need to be stressed in the Transport Strategy as well to help make a strong case for rail freight network investment.
We welcome the EEH commitment to ensure that the Transport Strategy sets out the needs of the freight and logistics sector, promotes a more active consideration of freight requirements within the planning process and identifies the need for regulatory changes on Page 83
In terms of freight, a key measure of success for the Transport Strategy will be increased modal shift to rail from HGVs, which will help EEH meet its sustainability targets.
1. EEH Outline Transport Strategic Framework - Reducing the unwanted impacts of freight P82
2. Better Delivery: the challenger for freight p55/56 New and better data & Data through technology
3. Better Delivery: the challenge for freight P53 The interim report showed how freight is a forgotten element of spatial planning. https://www.nic.org.uk/wp-content/uploads/Better-Delivery-April-2019.pdf
4. EEH Outline Transport Strategy P82
5. An average freight train can remove 70 HGVs, Value of Freight July 2013 Network Rail
6. Lorries do cause far more damage to foundations & 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-axle 44 tonne 16.5 metre truck is 100,000 times more damaging to road surfaces than a Ford Focus.
7. Ibid P78 Maggie Simpson Rail Freight Group
8. Minerals Products Association 2016
9. National Infrastructure Commission Freight Study - Decarbonising rail freight P10
10. National Infrastructure Commission Freight Study April 2019 electrification P73 https://www.nic.org.uk/wp-content/uploads/Better-Delivery-April-2019.pdf
11. https://www.theccc.org.uk/2019/05/02/phase-out-greenhouse-gas-emissions-by-2050-to-end-uk-contribution-to-global-warming/. “Rail electrification should be planned on a rolling basis to keep costs low”.
13. Financial analysis £70.7 million project having a Net Present value of £376m
14. MTRU: Impact on congestion of transfer of freight from road to rail on key strategic corridors March 2017
15. MTRU: Supplementary report on environmental and safety impacts of the transfer of freight from road to rail on key strategic corridors (December 2017)
16. https://www.returnloads.net/hgv-driver-shortage/ HGV driver shortage 2018
17. ORR The Freight Delivery Metric – 26th September 2019 https://dataportal.orr.gov.uk/statistics/usage/freight-rail-usage-and-performance/
18. https://www.returnloads.net/hgv-driver-shortage/ HGV driver shortage 2018
19. Ibid P66
20. 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.
21. DfT Rail Freight Strategy September 2016 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/552492/rail-freight-strategy.pdf
22. DfT RFS0125DfT empty running figures https://www.gov.uk/government/statistical-data-sets/rfs01-goods-lifted-and-distance-hauled
23. DfT spreadsheet at http://www.freightonrail.org.uk/PDF/Proportion-of-HGVs-limited-by-weight-and-volume.xlsx issued July 2019
24. The environmental benefits from moving goods by rail rather than by other modes are substantial – Rail Freight Delivering for Britain P5 Rail Delivery Group 2019
25. Rail Delivery Group Rail Freight working for Britain - rail freight contributes more than half a billion externality benefits Page 5 2018