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West Midlands Strategic Transport Plan Consultation.
 

  1. Thank you for the opportunity to comment on the West Midlands Strategic Transport Plan
     
  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 and central Government.

  3. How does the Freight addendum of 2015 and the Freight Strategy written in 2013 fit with this?
     
  4. Summary
    The plan still comes across as a vision rather than a strategy which focuses on ideas and lacks concrete plans and would benefit from better integration with the Rail Strategy. We are, however, pleased to see that the ITA has incorporated many of our key points made in the Stakeholder consultation to the WM Transport Presentation in April 2015.

    We support the aims of this plan but would like to see greater recognition in the plan of the role which rail freight can play in helping the West Midlands met all four of its stated main challenges.

    Transport has to reduce its CO2 emissions if the Government is to meet its climate change targets. The latest statistics from the Climate Change Committee show that all other sector reduced emissions in 2013 while transport’s share grew by 1.1%, which means that,transport's share of total CO2 emissions went up from 25 to 28%. Rail freight produces 76% less CO2 emissions per tonne than the equivalent HGV journey.

    There are currently no standards and testing for truck CO2 emissions which experts believe could reduce emissions by around 35% and at the same time reduce fuel costs for operators. Therefore, please urge the Government to back the Commission proposal for a testing tool, called VECTO, which should be available to third parties, despite the truck manufacturers’ objections, which is due for EU co-decision next year.
     
  5. Devolution
    Devolution, both Government and industry, present challenges as well as opportunities for rail freight as it is a network-wide industry. The vast majority of rail freight flows cross regional boundaries so it is important that the wider benefits of rail freight to society and the economy are taken into account. Nationwide access, timetabling and possession planning must be managed centrally by Network Rail.
     
  6. Role of rail freight in WM and beyond
    Rail freight is an important part of the logistics offering in the West Midlands and delivers a wide range of products to and from the region. In particular, rail is well placed to supply the long distance trunk haul for consumer freight which now accounts for around a third of rail freight volumes and is forecasted to grow four or five fold in the next 25 years. Road and rail complement each other and that is why additional road/rail transfer stations are needed to facilitate cost effective transhipment between the modes. Rail also transports raw materials and semi-finished goods to and between manufacturing plants as well as construction materials which has seen a 23 per cent growth in the last quarter compared to the previous year.
     
  7. Land use planning
    We believe the importance of land use spatial planning needs to be highlighted in this document. Without coherent and integrated spatial and transport planning, the ITA will find it difficult to meet all its objectives. The ITA can set the overall spatial planning framework for the West Midlands and direct local authorities to safeguard suitable sites and rail alignments for potential rail use in their Local Development Frameworks.

    For rail freight, it is crucial that local and regional authorities protect suitable sites for terminals for future potential use because there are a limited number of suitable locations which have the necessary rail and road connections.  The Government’s National Network National Planning Policy which includes the Strategic Rail Freight Interchange policy would support applications for SRFIs nationally significant infrastructure projects in the planning system.
     
  8. Role of rail freight in reducing road congestion
    Research commissioned by CBT looked at specific routes which typically tend to be more congested because of more long-distance HGV traffic, particularly to ports. Its key findings were that: 
     
    1. Some parts of road network have more long distance HGV traffic which could be carried by rail
    2. The impact of additional traffic in already congested conditions is far greater than a simple increase in pcu or vehicle kilometres suggest – it rises exponentially.
    3. In congested conditions each single per cent increase in traffic causes several percentage increase in congestion. In fact, Department for Transport figures state that a modest decrease in traffic of around 2%, results in congestion falling by 10%.  DfT figures show that on congested parts of the network, congestion could be three to four times the percentage reduction in overall traffic levels, using a simple low congestion impact multiplier of 3-4. 

    The research found that key in corridors relating to the West Midands that is from Southampton, Bristol, London and Haven ports, all suffer severe congestion at peak hours which could be significantly alleviated by the transfer of freight to rail.  

    Potential reductions in congestion on the strategic road network from alternatives to HGV use - Report prepared for Campaign for Better Transport

  9. Detailed comments

    Rail freight can help contribute to better transport mentioned on Page 3, including the need to improve air quality, improve social well-being, vision for a transport system befitting sustainable attractive conurbation.3.1 Page 5, Reduce transport’s impact on our environment Page 5

    With reference to 2.4 In essence rail freight:-

    A Helps foster green economic growth

    Alleviation of road congestion helps economic efficiency- each large aggregates freight train can remove up to 130 HGVs from Hertfordshire roads. Source Network Rail

    B Can deliver building materials for infrastructure development and consumer goods needed for population growth in a sustainable safe mode.

    C Rail freight creates 76 per cent less carbon dioxide emissions, almost 90 per cent less small particulate matter and up to fifteen times less nitrogen oxide emissions than the equivalent road journey. Source Value and importance of Rail Freight Network Rail 2100

    Rail freight produces almost ten times less externalities than HGVs. This translates into low carbon energy-efficient safer less polluting freight alternative to HGVs which reduces road congestion.

    If the West Midlands is going to play its full role as stated in the plan to reduce CO2 emissions it needs to promote rail freight.

    D Rail is over 20 times safer than HGVs according to the ORR. HGVs are over 6 times more likely to be involved in fatal collisions than cars on minor roads. Source DfT Traffic Statistics Table TRA0104, Accident statistics table RAS 30017 September 2014

    With reference to sections 2.7/2.8/2.9/2.15/2.16/2.17/3.1.

    Road and rail freight complement each other. However, as well as the traditional bulk flows, rail is well placed to provide the long haul trunk movements of consumer rail freight with far lower impacts on the economy and society than HGVs. Your plan mentions the need to reduce emissions from motorway network.

    Need for rail freight links to service growing economy. As document says need to foster and encourage this growth.

    Vision to connect supply chains strategic gateways thru strategic connections by road and rail.

    Page 6 rail freight has a role in ENV1,2,3,4

    SOC1 – social exclusion

    Page 7 We support section 4.4 and the need  for more capacity for freight

    Page 8 should mention more rail freight capacity and need for terminals of all sizes and allow for upgraded road links to Strategic Rail Freight Interchanges (SRFIs)

    Page 8 mentions transport integration but needs also to highlight the link with spatial planning to achieve this integration. See section 6

    Page 9 section 4.11 does highlight need for more rail freight capacity to meet objectives.

    Page 9 section 4.12 Rail freight must get its share of released capacity on WCML as a result of the building of HS2

    Page 9 section 4.13 does highlight need to expand rail freight capacity across the Midlands as a whole.

    Key upgrades needed from Felixstowe to connect to WCML. This is tied in with Leicester re-signalling, a passenger upgrade.

    Page 10 section 4.16 Support the inclusion of the need for terminals of all sizes

    West Midlands needs more rail/road transfer points of all sizes but in particular the large Strategic Rail Freight Interchanges (SRFIs). Mention of the Government’s National Network National Planning Policy which includes the Strategic Rail Freight Interchange policy would support applications for SRFIs nationally significant infrastructure projects in the planning system. This policy gives developers the confidence to submit planning applications for large scale road/rail transfer points. 

    Page 10 section 4.15  It should be noted that the existing charges for HGVs on the private M6 toll motorway reflect the true costs trucks impose on infrastructure and congestion and society, without Government subsidy.   

    Page  10 section 4.17 As listed, the key rail freight priorities are listed. Camp Hill Chord need to increase capacity so existing and future increased volumes of rail freight are not disadvantaged.

    Water Orton corridor is a key rail freight priority, as is the Rail electric spine

    See section 4.15 for comments on M6 toll road.

    Page 18 Under key transport priorities – Water Orton upgrades should be mentioned in detail.

    Page 23 sections 444/448 Reducing air quality impacts – Rail freight produces almost 90 per cent less small particulate matter and up to fifteen times less nitrogen oxide emissions than the equivalent road journey. Source Value and importance of Rail Freight Network Rail 2100

    In order to reduce air pollution, the ITA should support rail connected distribution centres on the edge of conurbations combined with the use of low emissions vehicles in cities for final deliveries. Rail well placed to provide long distance trunk haul of consumer goods to consolidation centres.

    Page 24 section 4.49 Transfer to rail freight will help reduce road fatalities and injuries from freight movements.

    Page 24 Rail freight reduces road maintenance costs. HGVs 160,000 times more damaging than an average car.Reference 4th power law

    Page25 Section 5.1/5.2 Rail freight can help the WEM reduce congestion and air pollution.

    Page 26 what projects got funding via LEPs Sections 6.2/3

    Support key rail freight upgrade schemes;rail’s market share out of Southampton port increased from 29-36% within a year of completion of the gauge upgrade; financial analysis shows £70.7 million project having a Net Present value of £376m.

    We ask the ITA to make the case to the LEPs on the benefits of getting more rail schemes funded through Local Growth Fund.p26. For example the gauge upgrades of the route from Southampton to the West Midlands 

    Rail freight can help the ITA achieve Policies 1 to 7 and all Environmental, public health and social wellbeing policies.


 

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