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Response to TfL Draft Environmental Strategy.

Freight on Rail is pleased to comment on the TfL Draft Environmental Strategy.

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.

  1. Summary
    We have commented on three chapters, namely air quality, climate change mitigation and waste in terms of the two surface access modes for freight. We believe that there needs to be a transformative change in the way freight is delivered into and waste removed out of the capital if the air and CO2 reduction targets are going to be achieved. Both the TfL Transport and Environmental Strategies need to recognise that many of the existing freight delivery methods are not sustainable.  In particular, there is a need to get freight out of large HGVs in the capital into low emissions vehicles.  Rail should and could be part of the low emissions freight solution if TfL implements the right, transport, spatial planning and environmental policies.

    Therefore encouraging modal shift to rail for long distance consumer and bulk traffic should be an important part of TfL’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. 

    This can be achieved through a number of policies as long as the treatment and support for all modes is fair with rail freight getting equal treatment.

    For example, both the Transport & Environmental Strategies should recognise the role rail freight already plays in the capital in improving the environment. 40% of London’s aggregates are already transported by rail in a safer cleaner way which reduces road congestion. Furthermore, there is potential to increase rail’s share of this construction market if the necessary road/rail transfer points are realised.

    The rail freight which moves around London, wherever it is destined, serves to remove lorries from the strategic road network, including around London, and to deliver environmental benefits to the UK.  Traffic to and from the North Thameside area, including the major ports at London Gateway and Tilbury, is supporting local economies and jobs on the edge of the London conurbation, and also supporting warehousing and distribution activity for London consumers. 

    Many of these interventions have multiple benefits not only to air quality and carbon dioxide emission reductions but also for tackling congestion and improving road safety. The latest analysis by Inrix calculates that congestion is now estimated to cost the UK £9 billion annually. Lorries are disproportionately involved in fatal collisions with pedestrians and cyclists.  Lorries only make up  around 5% of London traffic in miles driven; And yet seven of the nine cyclist fatalities in London in 2015 involved lorries.



    Do you agree that the policies and proposals outlined will meet the Mayor’s ambitions for air quality in London and zero emission transport by 2050? Is the proposed approach and pace realistic and achievable, and what further powers might be required?

    Please provide any further comments on the policies and programmes mentioned

    in this chapter.
  2. Air Pollution
    At the moment, the role that rail freight can play in reducing air pollution is undervalued in the both the draft TfL Environmental & draft Transport Strategies.

    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 in the capital. There is also growing recognition 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; in the case of large HGVs it will be difficult to reduce these emissions.

    The Government and TfL need to reduce the number of large HGV traffic in the capital 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 1.
  3. TfL should take into account national Government’s policy to promote rail freight which expressly mentions its air quality benefits as well as carbon dioxide and congestion benefits.

    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.
  4. Proposal 4.4.1c  P65

    The London Plan should make the case for rail freight terminalsof all sizes for different commodities. While we accept that the London Plan is the spatial plan, which concentrates on safeguarding and planning policies as well as bringing all the other strategies together, we maintain that the transport and environmental strategies needs to highlight the importance of safeguarding key sites for further rail/road consolidation centres. Suitable sites by the railway with good road connections are limited.
  5. Rail freight’s role in reducing air pollution
    Reference Policy 4.2.1 P80 Strategy should recognise the role rail freight already plays in transporting 40% of London’s aggregates in a safer cleaner way which reduces road congestion and its potential to increase rail’s share of the market if the necessary road/rail transfer points are realised. Five million tonnes of construction materials such as aggregates and cement are already delivered to a network of rail depots across London to help supply the material demands of housing, transport infrastructure and other developments across London. Rail wasused to bring in construction materials and remove waste/spoil for CrossRail and the Olympics. For example each freight train carries enough materials to build 30 houses.

    The London Plan needs to have a policy to safeguard more rail freight sites for aggregates terminals in its strategy and give guidance to the London boroughs to do the same, so that more construction materials can be brought into the centre of London. Rail freight sites should be protected either through a GLA act in the same way that wharves are protected or through another mechanism. In the past, there was a SPG land for industry and transport.

    According to the Mineral Products Association Ltd, which represents the building industry, there are growing concerns about whether planning authorities will safeguard the rail depots currently used to receive materials because of other development pressures such as housing. Without a clear policy lead from the Mayor that the future use of rail freight is economically and environmentally critical for London, there is a significant risk that the operation of existing and potential new rail depots will become increasingly difficult, resulting in significant increases in the long distance lorry movements into London which will increase road congestion, road collisions and CO2/air pollution.
  6. Air pollution much lower from rail than HGVs
    P69 the improvement in euro VI HGV emission levels are rightly mentioned. However, the fact that Rail freight’s per tonne air pollution figures are much better than HGVs must also be taken into account.Rail produces 90 per cent less PM10 particulates and up to 15 times less NOx emissions than HGVs for the equivalent journey.
  7. Consolidation
    P70 and page 72 Policy 4.2.1 consolidation centres should be rail connected as rail freight is well placed to offer long distance trunk haulage to consolidation centres for onwards transhipment into low emissions vehicles including electric cargo bikes. The Mayor should therefore have a policy to support a network of Strategic Rail Freight interchanges (SRFI) and smaller consumer terminals around London and the South East because SRFIs in particular, reduce the transhipment costs of rail freight as well as providing value added services which allows rail to compete more fairly with HGVs.
    The Daventry SRFI removes 64 million lorry miles from the road network.
  8. P81 Examining other ways in which freight can be delivered … making better use of river and rail services. We support this statement but there is no explanation in the draft strategy of the TfL policies needed to realise rail freight growth.
  9. P81 policy 4.2.2c  We support the policy to increase electrification. But there is no mention of rail freight even though large quantities of rail freight travels to the capital, both consumer and bulk materials using electric traction.
  10. In particular we are calling for TfL to do 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 
    • Congestion charging
      Transport for London’s emissions surcharge and a planned Ultra Low Emission Zone both based on Euro vehicle classifications are good first steps for all traffic. However, need a distance based lorry charging systems which take account of the proper impacts on the road network and other users. This is because trucks only pay 30% of the costs they impose on society at the moment. 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.
      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
  11. The Mayor should be calling on the government to implement the following as national policy
    • 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) 2.
      Distance based lorry road charging.
      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; 30% of trucks are driving around completely empty According to DfT figures only 34%3 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. 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%. Load efficiency has also improved significantly.
    • DfT should commission alternative fuels research for freight locomotives in the same way that it has done for HGVs so rail is treated fairly. P97 Targeted retrofitting should also include rail freight diesel locomotives. P105 As well as alternative fuels research for HGVs, there should also be the same research for rail freight locomotives.
  12. Transferring freight to rail is key to reducing particulate emissions especially from brakes and tyres
    P101 proposal 4.3.1a and P110 proposals 4.32e to reduce particulate emissions from brakes and tyres shows that transferring more freight to rail is key to reducing particulates emissions. Reducing brake and tyre emissions from large HGVs will be challenging whereas freight from small HGVs and vans should use electric vehicles.
  13. Supporting rail freight in clean air zones
    It is important that TfL does not pursue these objectives solely through the regulatory regime but supports rail freight in the same manner it does road transport. To date, rail diesel and other non-road users including industrial equipment, have largely been excluded from the air quality 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.

    Therefore the Government and TfL need 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.
  14. Do you agree with the proposed approach to reducing emissions from non-transport sources (including new buildings, construction equipment, rail and river vehicles and solid fuel burning)?

    More help is needed in the non-transport sources of air pollution on building sites
    P88 Policy 4.2.3 P 88 and policy  4.2.3b P 91
    TfL needs to help these businesses retro-fit existing plant equipment and incentive newer lower emissions equipment for non-road mobile machinery (NRMM)
  15. TfL should needs to give strong policy direction to the 33 London boroughs, supported by central Government funding so that local authorities have the capability to implement meaningful policies. Furthermore, the suggested process for implementing new requirements could lead to differing standards and policies in different authorities, that give rise to significant complications and costs for businesses.
  16. Adapting to Climate Change
    Freight on Rail responded in detail to the draft Transport Strategy on how rail freight needs to be a major part of the freight solution to reducing carbon emissions.

    The emissions reduction required from Transport, shown in figure 39 demonstrate that TfL will need to transfer freight deliveries to low carbon modes. TfL will struggle to reach its carbon dioxide (CO2) reduction targets unless more freight is transferred to rail. CO2 reductions from the larger HGVs, which will continue to use the current engine technology well into the next decade, according to the DfT Freight, will be much harder to achieve than other smaller road freight vehicles.

    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.

    As explained in the summary and air quality, climate change adaptation and waste sections, rail freight should and could be part of the low emissions freight solution if TfL implements the right, transport, spatial planning and environmental policies.
  17. Waste

    Proposal 7.3.1b

    We support this proposal to reduce waste removing by road in favour of rail and water.

    Rail freight, which has provided transportation for municipal waste removal for many years still has an important role with potential to expand services. Currently, its services include West London Waste removal from Brentford and from waste flow from Cricklewood (Brent – North London waste) to Calvert. TfL should make using rail a planning obligation for the construction of HS2 to bring materials into and remove waste which will reduce HGV traffic around Euston and Hampstead.


1.DfT Freight Carbon Review February 2017

2. Source
Diesel tax loophole 'thwarting' Government's clean air strategy

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

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