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Freight on Rail response to Joint HOC Improving air quality inquiry.

November 2017

  1. We welcome the opportunity to respond to the House of Commons joint Committee inquiry on improving air quality.  
  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.
  3. Summary

    Our response relates to air pollution issues for the two surface access freight modes. Air quality is an increasingly important issue for road freight transport, which shows that rail freight could and should be playing a larger role in reducing NOx and particulate emissions. There is growing recognition, as your strategy states, of the need to tackle particulate emissions from brake and tyre as well as tail-pipe particulate emissions from freight transport.  Over half of small particle pollution comes from the wear on brake discs and tyres and by throwing up dust from roads known as resuspension; in the case of large HGVs it will be difficult to reduce these emissions.

    Transfer to rail is part of the solution to reducing air pollution from freight as this DfT statement says-

    [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.

    The current research comparison figures between road and rail, which were carried out by RSSB in 2007, need updating by the Government. Lack of  the latest comparison figures, affects Government policy decisions. Rail freight produces 90 per cent less PM10 particulates and up to 15 times less nitrogen dioxide emissions than HGVs for the equivalent journey. Source - RSSB 2007

    Graph - showing benefits of longer lorries is flawed

    Air pollution from large HGVs is a problem

    Air pollution from the largest HGVs, which make up over half of all HGV traffic will continue to use the current engine technology well into the next decade according to the DfT.

    DfT chart shows registration figures by size of large HGVs

    Therefore encouraging modal shift to rail for long distance consumer and bulk traffic should be an important part of the Government’s action plan. This should include looking at urban logistics as well. Clean air zones if properly designed can help support rail freight as long as rail and road costs are more equitable. 
  4. Furthermore, rail freight projects have high benefit cost ratios compared to other transport projects i
  5. We believe that the uncertainty over further electrification schemes, is short-sighted and deeply disappointing. Electrification, which is proven technology, reduces carbon dioxide and air pollution as well as increasing rail speeds, capacity and reducing maintenance costs.
  6. How effectively do Government policies take into account the health and environmental impacts of poor air quality?

    Given the imperative to reduce air pollution, the Government needs to support modal shift to rail, and take into account the lack of parity between the two modes; rail freight has to compete with HGVs, which are only internalizing around 30% of their costs. The Government needs to reduce the amount of large HGV traffic as the following figures show the extent of the road freight problem. HGVs account for around 21% of road transport NOx emissions while making up just 5% of vehicle miles – DfT Freight Carbon Review February 2017

    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.

    High ways England air quality strategy August 2017 states that HGVs contribute 38% of Transport’s NO2 emissions close to motorway network and yet it is building an additional over 1,300 additional lane miles between 2015 and 2020. It cannot rely on upgrades to euro vi engines coming on stream in this time period and furthermore the tyre and brake particulates problems with large HGVs is seen as very hard to reduce.
  7. While the latest trucks with euro VI engines represent a significant tightening of permissible emissions with particulate matter halved and NOx emission reduced by more than three quarters compared to 2009’s Euro V standards, the average HGV is seven and a half years old meaning only a quarter of lorries on the road meet euro V standards and even fewer trucks meeting euro VI standards. The majority fall into the Euro IV and V brackets while 14 per cent of HGVs are over 13 years old. These older lorries are required to meet only Euro III standards or earlier which permit NOx emissions between 13 and 20 times higher than Euro VI and particulate emissions between 13 and 60 times higher source

    EU Emission Standards for Heavy-Duty Diesel Engines: Steady-State Testing













    Euro I

    1992, ≤ 85 kW

    ECE R-49





    1992, > 85 kW





    Euro II











    Euro III

    1999.10 EEV only

    ESC & ELR












    Euro IV







    Euro V







    Euro VI








    a - PM = 0.13 g/kWh for engines < 0.75 dm3 swept volume per cylinder and a rated power speed > 3000 min-1

  8. While progress is being made in smaller freight vehicles operating in urban and suburban areas through hybrid and alternative engines and regenerative braking, there is less scope to replace large HGV diesel engines. Articulated HGVs do most of their travel om motorways ( 58.8 per cent) and on trunk roads a further 22.7 per cent and in these conditions, regenerative braking and hybrid does not offer significant savings. 

    Adaptations for diesel engines with the latest Euro VI engines have helped to reduce exposure to particulates, but new sources of transport emissions associated with brake and track and abrasion threaten to push levels of pollution from this source back up. Therefore, with particulates it is important to record both tailpipe and brake and tyre emissions separately as HGVs present serious type and brake particulates, due to size of brakes and resuspension, which will be hard to reduce. Overall road transport vehicles PM10 is 40% tailpipe, 50% brakes and 10% tyres. Trains have very effective regenerative braking whereas HGVs regenerative braking is less effective.
  9. Addressing air pollution from transport is also essential to achieve climate change obligations. The UK Climate Change Committee advises that we need to reduce motor vehicle miles (even with an electric fleet) by 5 per cent beyond base to meet our carbon budget. Government transport policy, with its major road building projects (RIS2), which stimulates more road
    traffic, is taking us in the opposite direction.
  10. Do these plans set out effective and proportionate measures to achieve necessary emissions reductions as quickly as possible?
    No, the government needs to compensate rail freight for the fact that 70% of HGV costs are not internalised so that rail freight can compete more fairly in order to reduce freight’s air pollution

    Rail freight has to compete with HGVs on price despite the fact that HGVs only internalise around 30% of the costs they impose on society according to the research commissioned by Freight on Rail. Heavy goods vehicles (HGVs) receive a £6.5bn subsidy each year in terms of the congestion and road infrastructure damage, increased road crashes, air and CO2 emissions. Mode shift benefit value for CO2 are 7 pence per mile and air pollution is only 0.1 pence per miles Source DFT MSB Technical report refresh, DfT 2014.
    It is therefore crucial that the government recognises HGV costs in its discussions about rail freight costs because rail freight, which has to compete directly with road produces far less air pollution than large HGVs for the equivalent journey.

    Dangerous, dirty and damaging - New research reveals impact of HGVs

    These conclusions are in line with two other separate reports. MDS Transmodal study in 2007 found a very similar amount of underpayment: £6billion. Transport & Environment research issued in April 2016 found that HGVs were only paying 30% of their external costs.
    We believe that the scale of subsidy to road makes a compelling case for supporting sustainable freight modes equivalently which impose much lower costs on the environment, society and the economy.
  11. Highways England’s work on the Strategic Road Network should be brought within the UK Air Quality Plan as a key player in delivering improved air quality, and empowered to contribute their dedicated funds for air quality work outside the narrow boundary of the SRN in partnership working with local authorities to deliver clean air zone compliance. This could include better integration rail freight interchanges; Highways England designated air quality fund aimed predominantly at NO2 emissions, should also recognise the growing problems from particulates, especially from HGV tyres and brakes.  the  £100m over 5 years until 2021. However, as at August 2017, only a small amount, circa £2.5m had been allocated suggesting that the scheme needs to be broadened and made more accessible. – Freight on Rail is working with the Highways Agency and Strategic Rail Freight interchange developer to see if a sufficient number of pre euro VI hgvs can be removed from SRN if rail freight upgrades are supported in the development of interchanges.
  12. To date, rail diesel and other non-road users including industrial equipment, have largely been excluded from the debate, as their relative contribution is small. However, despite representing only a small percentage of overall air pollution, in some locations rail freight and its associated operations will be significantly impacted by measures to improve air quality.
    Overall, rail plays an important role in reducing the environmental impact of transport and is well-placed to do more. Rail freight’s per tonne air pollution figures are much better than HGVs but despite representing only a small percentage of overall air pollution, in some locations such as urban aggregates terminals, rail freight and its associated operations could  be significantly impacted by measures to improve air quality. Rail freight operations in urban Clean Air Zones are likely to become targets for local authorities. If the need to reduce emissions cannot be mitigated, local authorities may levy charges against rail freight. As well as jeopardizing the viability of some rail freight operations, this could shift freight from rail to road with potential impacts on carbon emissions as well as safety and congestion.
  13. Therefore the Government needs to support rail freight to avoid these adverse outcomes for the industry and society as a whole. The best solution for rail should be electrification but the recent Government announcements replacing electrification with bi-mode operations mean that it is even more important now that the Government commission research into alternative fuels for locomotives and consider grants for retro fitting existing locomotives and other industrial equipment. Construction and industrial freight operations could be doubly affected by the increased focus on air pollution, with heavy plant machinery also often relying on older diesel engines, which will be increasingly fingered as part of the problem.

    In particular we call for the following:

    • Smarter last mile logistics, including use of cargo bikes and ultra/zero emission vehicles;
    • Rail connected consolidation centres on edges of cities using rail for long distance trunk haul for transhipment into low emissions road vehicles.
    • The current OLEV grant scheme should be expanded, particularly targeting small businesses and should include funding for e-cargo bikes.  Grants specifically exclude e-bikes, an error that should be addressed. E-bikes and e-cargo bikes make a valuable contribution to addressing congestion and pollution and are a viable alternative to cars and vans that deserve support. There is a private scheme in Cambridge using e- cargo bikes.
    • Support for more urban aggregates rail freight terminals to bring construction materials into the heart of cities and for removing industrial waste
    • Use of existing passenger rail terminus at night for freight trains – two Colas trials with TNT and Sainsburys show the merits of this approach. It was halted because of the HS2 works at Euston but could be pursued at other passenger rail terminus in London, Birmingham and Manchester for example   
    • The fuel duty escalator should be reinstated, at 1p above inflation as it was originally planned.
    • Fuel duty for HGVs has been frozen since 2011 whereas access charges have increased by more than 20% RPI over the sample period.
      Freezing of fuel duty undermines rail freight as rail freight access charges have increased by 22% since 2009 and fuel duty has been frozen since 2011.
    • End tax loophole on refrigerated lorry units.
      The Government should end a “tax loophole” which allows refrigerated lorries to use cheaper ‘red diesel’, other fleet operators use it to run unregulated secondary engines which power their refrigeration units. Continuing to charge less for the fuel for these units will undermine efforts to clean up cities’ air quality by removing any incentive to move to cleaner fuel types. By hardly taxing diesel used for refrigeration units the Government is providing a perverse incentive for supermarkets and other companies to carry on using diesel, when instead they should be adopting alternative cleaner technologies. The current tax arrangements actually encourage the use of diesel refrigeration engines continuing to exist on supermarket lorries. Transport refrigeration units emit up to 93 times more NOx and 165 times more PM than the standards Euro 6 diesel car. Dearman, which offers its own zero-emission transport refrigeration system claimed that refrigeration units on trucks can use up to 20% of a truck’s fuel, which would result in emission rates six times higher than nitrogen dioxide and 29 times higher than particulate matter from a modern heavy goods vehicle (HGV).
      Source: Diesel tax loophole 'thwarting' Government's clean air strategy
    • The lack of emissions-related charges is a serious omission from recent proposals for the Severn Crossings tolls which is undermining existing rail freight services to Wentloog 1.
    • HGV distance based lorry charging which takes into account the air quality emissions of lorries, using euro engine classifications could incentivise use of modern less polluting engines and reward efficient use of loading capacity: we note that DfT has committed to reviewing the existing time-based HGV levy. Distance based systems on the Continent have greatly reduced empty running and improved efficiency. The German Maut reduced empty running from 29 to 18% over a seven year period to 2008. It is now 1-2% lower at around 16%. Large HGV efficiency needs to be improved in order to reduce HGV vehicle miles and thus pollution.  In contrast to German figures, the UK figure for empty running for 2016 was 30% and DfT figures show that only 34% of lorries were constrained by volume in 2016.

  14. Many of these interventions have multiple benefits not only to air quality but also for tackling congestion which is now estimated to cost the UK £9 billion annually, according to Inrix, carbon reduction, social inclusion, better access to jobs and services, and more liveable cities. 
  15. Are other nations or cities taking more effective action that the UK can learn from?

    A smarter last mile logistics plan should be a key part of Clean Air Zones. Investment in local rail served consolidation centres with delivery by low emission vehicles has proved successful in cities including Brussels, Paris and Gothenberg. DHL, UPS and Fed-Ex are taking part in the schemes. This approach would also cut congestion, with resulting time and cost savings to businesses.
  16. Is there enough cross-government collaboration to set in place the right fiscal and policy incentives?

    DfT & DEFRA are working together better but truly cross Government co-operation, including HMT, is needed.
    There is a strong case of targeted investment to improve emissions performance of the rail freight sector. This should include:
    • Examining the potential for retrofitting existing diesel freight engines.
    • Opportunities for enlarging the electric freight network.
    • Exploring the potential of bi-mode freight traction. In particular, passenger rail may move to bi-mode trains which run electric through urban areas and it needs to be established whether rail freight has any comparable options in this area. DRS has bought 10 dual mode locomotives class 88 which are designed for predominantly electric mode but with the ability to use diesel to go into depots.
    • Government needs to commission revised research to establish the different air quality figures of HGVs and rail locomotives as existing figures, listed below are out of date. Rail freight produces 90 per cent less PM10 particulates and up to 15 times less nitrogen dioxide emissions than HGVs for the equivalent journey. Source RSSB 2007

      It is important Government does not pursue these objectives solely through the regulatory regime but supports rail freight in the same manner it does road transport.

      The priority for assistance on tackling pollution from HGVs should be through a modal shift package. Shifting long distance freight from road to rail in line with the Government’s Rail Freight Strategy would bring significant benefits. HGVs are responsible for 21 per cent of nitrogen dioxide emissions while only accounting for 5 per cent of vehicle miles.

      Strategic Rail Freight Interchanges (SRFI) have an important contribution to make: Daventry SRFI removes 65 million lorry miles mainly off the trunk network each year.2  Rolling out rail electrification should continue as an important part of any clean air strategy, complemented by research into alternative locomotive fuels. While rail freight diesel locomotives emit far less NOx and particulates than HGVs, an electrification or retrofit programme is still needed. 

      There is also a need for integrated transport and planning policies. Building major new roads is an expensive way to increase traffic levels, and will increase congestion in towns and cities, undermining action to tackle pollution. 3 Investment in local infrastructure should focus on improved public transport, walking and cycling, and rail freight provision, rather than trying to make motor vehicle dependency more sustainable. Such infrastructure delivers wider social, environmental and economic benefits in addition to improving air quality and so represents better use of public funds
  17. DfT sponsored research shows the need for integrated road/rail strategic transport  planning

    This DfT sponsored research shows that sending more goods by rail has the potential to dramatically reduce road congestion on some of the country’s busiest trunk roads and confirms 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. Freight on Rail is in the process of calculating what the air quality and CO2 benefits of modal shift on these key corridor would be.

    This research shows that as part of the RIS2 work, the Government should evaluate the benefits of upgrading rail freight network alongside the Strategic Road Network on three key corridors, namely, A14, A34 and M6.

    The official response from DfT which 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.”

    The Government’s own 2014 policy statement on national networks claimed that even doubling rail freight would only reduce road freight by 7 per cent (, pars 2.21). This latest research demonstrates the importance of analysing strategic corridors as well as using national averages in transport planning. It shows the extent to which upgrading the rail freight network on key strategic corridors ameliorates road congestion and therefore improve productivity. Transferring freight from road to rail would bring serious additional benefits not quantified in this report - improved road safety and reduced air pollution and carbon emissions - these should also be considered."

    for more details
  18. National Government needs to give strong policy direction, supported by funding so that devolved and local authorities have the capability to implement meaningful policies. Furthermore, the suggested process for implementing new requirements around the UK could lead to differing standards and policies in different authorities,  that give rise to significant complications and costs for businesses.




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