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The Last Mile – Department for Transport call for evidence on the opportunities available to deliver goods more sustainably - submission from Campaign for Better Transport.

September 2018

Campaign for Better Transport is a leading charity and environmental campaign group that promotes sustainable transport policies. Our vision is a country where communities have affordable transport that improves quality of life and protects the environment.
We welcome the opportunity to comment on this consultation.


We support moves to prioritise space-efficient modes of transport inparticular the aspiration to make use of low carbon transport, complemented by greater use of the rail network and riverfor freight.

Recent National Travel Survey statistics show that car tripsare falling, while there is growth in both HGV and LGV traffic volumes.There is therefore an urgent need not only to reduce emissions from freight but also to reduce the overall vehicle numbers in order to tackle problems of congestion and erosion of public realm.

There is a strong environmental and efficiency case for boosting the useof rail freight. Rail freight produces 76 per cent less CO2 per tonnecarried than the equivalent road journey. Fully laden HGVs are 160,000times more damaging to road surfaces than the average car.Transferring 2000 lorry loads a day to rail would be the equivalent oftaking 8000 cars off the road.

We would like to see greater emphasis on the need to allocate and deliver sites for rail freight interchanges andterminals, without which significant demand for rail freight will becontinue to be suppressed and its considerable benefits unrealised.

We strongly support moves to encourage co-operation within andbetween local authorities, Business Improvement Districts and other bodies to consolidate deliveries.

Weadvocate an accelerated rollout of smarter last miledelivery and area-wide servicing plans, to co-ordinate delivery times andpromote shared use of vehicles.

We favour a package of fiscal and public spending measures to support this approach, including extending Government financial support for low emission vehicles to include e-cargo bikes; reintroducing the Local Sustainable Transport Fund which has demonstrated excellent value for money; introducing distance-based HGV levy; and moving towards usage-based road charging for all private vehicles.

Potential for a multi-modal approach

The scope for multi-modal solutions to help deliver goods more sustainably has been totally omitted from this consultation, which is regrettable as the different modes working together to provide integrated solutions can improve efficiency and sustainability by reducing lorry miles.  Road nd rail freight policy needs to be better aligned overall so that road and rail can play to their strengths. Urban logistics policy cannot be examined in isolation as it is necessary to examine the complete supply chain.

Rail can deliver to consolidation/inter-modal terminals centres on the edges of cities or into rail passenger terminus at night. A network of inter-modal consolidation centres/strategic rail freight interchanges (SRFIs) on the edges of conurbations would reduce the transhipment costs of rail freight as well as providing value added services which allows rail to compete more fairly with HGVs.

Emerging urban logistics policy to cater for clean air zones and safer streets, where goods need to be transhipped into low emissions vehicles for last mile deliveries in urban centres, lends itself to the use of rail. If goods have to be transhipped for the last mile in urban centres, the delivery to the urban centre can be either road or rail. In the past transhipment from rail has been an obstacle for rail competing with HGVs in the consumer market.  Once goods have to be transhipped for final deliveries, the transhipment from rail to low emissions vehicles, instead of from large HGV to smaller low emissions vehicles, is financially viable.  

There are already good examples of this approach

  • The night time Colas trials into Euston for both Sainsbury’s and TNT show the potential for rail freight to bring trainloads of freight into the heart of London, using major stations, when the stations are closed for passengers. The goods can then be delivered by low emissions road vehicles, including e-bikes for light loads.
  • A similar approach has been adopted by Monoprix in Paris. Products are brought by rail from suburban warehouses to the Paris-Bercy freight facility, and low emission gas-powered delivery vehicles complete delivery to 90 Monoprix stores across the city.

This consultation is right to stress that the use of large HGVs, such as the 44 tonne 16.5 metre truck, for deliveries into urban centres is no longer acceptable in many cases on environmental, safety and congestion grounds. Using smaller safer freight vehicles instead of HGVs would improve safety for all other road users, especially pedestrians and cyclists. DfT statistics for 2016, referenced in the appendices, show that HGVs were almost seven times more likely than cars to be involved in fatal crashes on minor roads. 

Rail freight between cities has much better potential for reducing congestion by using smaller vehicles for ‘last mile’ delivery than long distance road freight using larger lorries for door-to-door delivery. As combined authorities set out overarching spatial planning as well as transport planning across city regions, it is imperative that this includes the need protect future potential sites for rail freight interchanges of all sizes. 

Barriers to greater use of rail freight

Road and rail complement each other in the supply chain. Rail is well placed to perform the long distance trunk haulage between ports and conurbations for onward transhipment to low emissions vehicles for the last mile deliveries. It is the preferred option by shippers because it reduces congestion at ports.

At the moment, it remains hard for rail to compete with HGVs. HGVs receives a £6 billion subsidy per annum and are only paying around a third of the external congestion costs which they impose on the economy, environment and society. The latest MTRU report of January 2018 1 and the Department for Transport (DfT) table shows that two thirds of marginal costs of the large HGVs are not being met by the haulage operators.

In 2016, 9 billion vehicle miles were run by articulated HGVs alone (this figure does not include rigid HGVs (source: TRA3105)) implying a marginal cost shortfall of about £6 billion. In 2014 the figure was £6.5 billion. These numbers vary a little from year to year according to traffic and the severity of impacts such as pollution or casualties. However, they remain substantial and completely unmet.

Since 2011, fuel duty has been frozen while rail freight access charges have increased by 22 per cent. Direct economicpressures (fuel costs) are the main driver for maximising efficiency in transport logistics. 2 Furthermore, the proposed ORR freight access charges would increase by 42 per cent for the next ten year period for bulk materials. This market distortion in freight makes it hard for the Government to achieve its environmental, economic and safety targets.

Reducing congestion

Freight is a major component of urban congestion reflecting the growth in online purchasing (from 9.4 per cent of the UK retail market in 2010 to 16.8 per cent in 2016). Unlike shopping in person, there is no incentive to combine purchases in a single delivery and there is a negative cycle of delivery companies deploying additional vehicles to achieve contracted delivery times, thereby worsening congestion.

To address this, we advocate an accelerated rollout of smarter last mile delivery and area-wide servicing plans, to co-ordinate delivery times and promote shared use of vehicles. The ‘Total Transport’ concept of co-ordinating shared use of vehicles from different public sector providers could be applied to delivery vehicles operating in particular areas.

There is growing interest in sharing apps which can partner empty vehicles with freight to make best use of return trips: local transport authorities could act as an honest broker to assist smaller businesses to access such services.

Encouraging the use of local and hyper-local consolidation hubs for neighbourhoods, housing estates, town centres, or business districts, is a cost-effective approach to manage deliveries, which, combined with the use of ultralow or zero emission last mile delivery vehicles (for example cargo bikes or electric shuttles), and designated delivery zones, can address both congestion and pollution.

There are already some good examples of this approach in practice:

  • In Gothenburg, the City Delivery scheme provides a central HGV terminal from which city centre deliveries are completed by electric van and delivery bikes.
  • In London, Regents Street has pioneered a similar approach, with a consolidation centre outside the congestion charge zone where multiple deliveries are transferred to electric vehicles for scheduled delivery: the scheme has seen an 80per cent reduction in retail lorry movements.

We urge extending Government financial support to support moves to greater use of low emission vehicles by extending OLEV grants to include e-cargo bikes.We also advocatereintroducing the Local Sustainable Transport Fund which has demonstrated excellent value for money.

Incentivising efficient use of vehicles

We support the principle of usage-based road charging. Such schemes help make best use of road space, cut congestion, reduce illegal levels of air pollution and free up space for public transport and active travel in a greener and more pleasant city.

The lack of a ‘pay as you go’ model for road transport means that motor vehicles do not pay the cost of their impact in terms of carbon emissions, air pollution or road maintenance. Road user pricing reflects the principle that those who contribute to congestion and environmental problems should help pay for the costs to society this causes.

Road pricing schemes should be designed to deliver environmental aswell as traffic reduction goals, enabling urban areas to tackle both pollutionand congestion in a smart and transparent way, while generating vitalrevenue for greener transport alternatives, public transport, low carbontransport, active travel and improved public realm.

We believe a distance based charging structure is needed for national freight traffic. Charging schemes for urban centres to reduce congestion and emissions need to be tailored for local conditions.

At the moment, the time-based charging structures for HGVs in the UK do not encourage efficiency. The DfT is currently leading on a review of the existing Road User Levy to which we have submitted evidence. 3

DfT figures for empty running figures remain consistently high and were 30 per cent for both 2016 and 2017. Furthermore, a DfT spreadsheet shows that only 36 per cent of lorries were full by volume in 2017 and only 34 per cent were full by volume in 2016.Better efficiency results in lower freight miles and therefore a reduction in congestion, emissions and collisions.

The German distance based system reduced empty running by a third from 11 per cent to around 18per cent and reduced tonne kilometres because of better loading rates. Prior to its introduction, Germany had similar empty running levels similar to the UK. In Austria, per km charging for trucks reduced the percentage of empty vehicles from 21 per cent to 15.77 per cent and average loads grew by 0,6 tonnes to 14,7 tonnes between 1999 and 2004.
Furthermore the evidence shows that tolls can be beneficial to society without placing an unbearable financial burden on freight transport. For example, the German Government has been using revenue from tolls to provide discounts for hauliers to purchase less polluting trucks. If the revenues from the distance based charging are re-cycled into supporting the quality of logistics through training and technology which will help the viability and operations of SMEs.

The Government should consider using the tax revenue from distance based road pricing of HGVs to incentivise investment in digital equipment, efficient logistics and less polluting technology; improve operating centres and staff training; and provide better parking and rest facilities for HGV drivers. Better working conditions could help alleviate the driver shortage, too.  This would provide a more sustainable future for the industry as well as for the urban communities that the sector seeks to serve.


Appendix: Benefits of rail freight.Rail freight reduces congestion, road infrastructure damage, collisions and pollution

A. Congestion

  • Congestion costs the UK £30 billion in 2016 with the UK ranked the fourth most congested developed country and third most congested in Europe. Building more roads alone will not solve the problems as it creates new traffic. When a new road is built, new traffic will divert onto it, a well-known and long-established effect ‘induced traffic’.
  • The largest freight trains in the UK can remove up to 160 HGV journeys from our roads
    - Value of Freight July 2013 Network Rail
  •   One train can carry enough materials to build 30 houses
    Mineral Products Association November 2016
    DfT estimate the cost of congestion being £0.99 per lorry miles on the most congested roads.

B. 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 136,000 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. Lorries are only paying 11 per cent of their infrastructure costs despite what the FTA claims. 4

C. Reducing emissions and improving air quality

  • As rail freight produces 76per cent less CO2 emissions than the equivalent HGV journey, increasing rail freight is an important part of the Ft.’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
  • Road Freight is a big CO2 emitter as HGVs contribute 17 per cent of surface access CO2 emissions, despite making up only 5 per cent of road vehicles. Reducing emissions from road freight is expected to be challenging, confirmed in a report from AECOM:“it will be very difficult to meet the 2050 goals without major reductions in GHG emissions from Heavy Goods Vehicles (HGVs).
  • Revised figures are being drawn up as the current comparison figures for rail and road are out of date. RSSB figures for 2007 showed that rail produced 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 50per cent 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 per cent of road transport NOx emissions while making up just 5 per cent of vehicle miles. A shift to rail freight will play an important long-term role in reducing non-exhaust particulates (PMs). While the latest EuroVI engine technology reduces exhaust particulates, non-exhaust particulate 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 to date.

D. The safety costs of freight should be evaluated and taken into account

  • There is no mention of the considerable safety benefits of rail freight which should be factored into freight transport strategic and planning decisions. HGV involvement rate in fatal crashes on local roads has doubled in the past ten years.
  • Our ten-year analysis of DfT Road Safety statistics, which show that HGVs are now twice as likely to be involved in a fatal collision on minor roads as they were ten years ago, demonstrates the benefits of reducing lorry miles. Despite only making up five per cent of overall traffic miles, HGVs are almost seven times more likely than cars to be involved in fatal collisions on minor roads.
  • Whilst cars are getting safer, HGVs continue to be dangerous in a collision because of their size and weight. The figures also reveal little or no improvement in the rates of fatal collisions involving HGVs on motorways and A roads. In 2014, on motorways, HGVs were involved in almost half (45 per cent) of fatal collisions although they only accounted for 11.6 per cent of the miles driven on them. 

Graph showing involvement in fatalities of HGVs over 3.5 tonnes compared to all traffic
Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT

The following DfT table shows the benefits of preventing collisions

Tabled information showing the valuation of the benefits of prevention of accidents



  1. MTRU Report: HeavyGoods Vehicles - do they pay for the damage they cause? June 2014, updated January 2018
  2. LSTF Case Study Evaluation  Strategic Employment Sites and Business Parks Summary Report 8 June 2017
  3. Campaign for Better Transport; Department for Transport call for evidence: reforming the HGV road user levy January 2018

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