Memorandum by the Rail Safety and Standards
Board (RSSB) (FT 30)
1. EXECUTIVE
SUMMARY
1.1 Rail freight offers much lower carbon
intensity than road haulage or air freight as well as the potential
to contribute to congestion relief on the roads and reduce noise
and some air pollutants.
1.2 One of rail's contributions to the delivery
of sustainable transport is through modal shift to rail from less
sustainable modes, enabling a reduction in the overall impact
of transport.
1.3 Capacity and network congestion are
key challenges facing the industry.
1.4 The recent Rail White Paper sets out
Government commitments to address network capacity constraints
and to double freight and passenger traffic and in particular
for freight the Strategic Freight Network.
1.5 The outcomes of Government fiscal instruments
are not always consistent with promoting modal shift to lower
carbon impact modes.
1.6 The Strategic Freight Network is critical
to rail freight and the commitment by Government to provide £200
million towards this is a welcome step.
1.7 The Channel Tunnel Rail Link (CTRL)
provides rail with more potential to secure modal shift from air
freight.
1.8 One way to improve road safety is to
realise modal shift from road to rail freight.
1.9 The Government should consider setting
out a strategy for freight transport in GB aimed at maximising
the sustainability of freight movement.
2. RESPONDEES
2.1 This is a submission by the Rail Safety
and Standards Board (RSSB) on behalf of the GB rail industry.
One of RSSB's key roles is to build consensus across the GB railway
industry and to facilitate the resolution of cross-industry issues
and initiatives. RSSB is the facilitator of the Sustainable Rail
Programme (SRP) on behalf of the GB railway industry.
2.2 Recognising the Government's strategy
for sustainable development, the GB railway industry has established
the Sustainable Rail Programme, which commits the industry to
developing a 30-year sustainable development strategy for the
railway.
2.2 The SRP is led by a cross-industry steering
group the Sustainable Development Steering Group (SDSG) comprising
industry chief executives, key policy makers and Government representatives.
2.3 While the rail industry has undeniably
good sustainability credentials, cooperation will ensure its sustainability
performance is optimised. The current structure of the industry
creates the need for cooperation between the different stakeholders
to deliver sustainability improvements as capital investment in
one part of the industry often delivers benefits in a different
part of the industry or society.
3. FACTUAL INFORMATION
3.1 Sustainable development and freight transport
3.1.1 The SRP seeks to optimise rail's contribution
to a sustainable transport system and supports the Government's
sustainable development strategy "Securing the Future"
and the Government's recent White Paper "Delivering a
Sustainable Railway".
3.1.2 Within the SRP, sustainability is
illustrated by considering the impacts on each of the three sustainability
pillars, environment, economy and society. Sustainable transport
outcomes include reducing environmental emissions and securing
improvements in service performance, affordability and accessibility.
3.1.3 Rail freight offers much lower carbon
intensity than road haulage or air freight as well as the potential
to contribute to congestion relief on the roads and reduce noise
and some air pollutants.[36]
3.1.4 One of rail's contributions to the
delivery of sustainable transport is to provide additional capacity
that would enable modal shift to rail from less sustainable modes
and enabling a reduction in the overall impact of transport (all
modes considered) as outlined in the Government's White Paper
"Delivering a Sustainable Railway".
3.1.5 Given the growth in the use of GB
railways by passenger and freight during the last decade, and
the predicted growth in the future,[37]
capacity and network congestion are key challenges facing the
industry. The Government's White Paper "Delivering a Sustainable
Railway" sets out commitments by Government to double
freight and passenger traffic, which should provide an opportunity
for the rail industry to secure modal shift from other modes.
3.1.6 We have tried to focus our response
as closely as possible on the strategic issues identified by the
Committee as being of particular interest. Our comments on these
are set out in more detail below.
3.2 Investment in logistics Programmes (Bullet
1)
3.2.1 The Government funds a number of rail
freight programmes. These include the Transport Innovation Fund
(TIF) for infrastructure capacity upgrades and the Sustainable
Distribution Fund (SDF), part of which supports the movement of
deep sea containers (Rail Environmental Benefit Procurement Scheme
[REPS]).
3.2.2 The REPS has encouraged significant
growth in the inter-modal rail sector by promoting modal shift
to rail. As the sector has become more efficient, the grant rates
have reduced, and value for money increased.
3.2.3 In 2007-08, the REPS budget has been
significantly reduced from previous years, which will limit the
modal shift of deep sea containers by rail and reduce the proportion
of freight moved by rail. The impact of the REPS budget is not
in line with the growth in rail freight set out in Delivering
a Sustainable Railway.
3.3 Promoting modal shift from road and air
freight (Bullet 2)
3.3.1 One of the principal Government interventions
for freight transport is fiscal instruments such as taxation,
regulation and cost/benefit appraisal. The outcomes of such instruments
are not always consistent with promoting modal shift to the lower
impact modes creating an uneven playing field.
3.3.2 To secure modal shift from higher
to lower impact modes requires that lower impact modes offer appropriate
economic and social incentives. This interpreted for rail freight
means an adequate loading gauge with sufficient capacity, reliability,
punctuality, speed and competitive cost.
3.3.2 Delivering a Sustainable Railway sets
out the Strategic Freight Network (SFN) to be defined by the industry.
The commitment by Government to provide £200 million towards
this is a welcome step. Providing the SFN should offer the opportunity
to secure modal shift from other higher impact modes by providing
increased capacity, reliability and punctuality for rail freight.
3.4 Implication of growth in air freight (Bullet
3)
3.4.1 Import or export air freight has to be
moved between suppliers/customers and airports—a role which
is currently fulfilled by road haulage. At present, there are
no dedicated rail freight links to airports for the transfer of
air freight despite rail infrastructure running adjacent to many
of Britain's airports.
3.4.2 Over the last 10 years there has been
significant investment in improving passenger rail links to airports
to address congestion and pollution caused by those travelling
to and from the terminals. Given appropriate traffic volumes,
rail freight could have a significant role in transferring air
freight between suppliers/customers and the airport.
3.4.3 For inter European air freight, the
Channel Tunnel provides the opportunity to completely remove the
air freight component of the current journey. At present, there
are some ongoing issues concerning the use of the Channel Tunnel
by rail freight, which the Government is seeking to address. We
encourage the Government to continue exerting pressure to ensure
freight is able to use this key international route in an affordable
and efficient manner.
3.5 Planning and delivering integrated infrastructure
(Bullet 4)
3.5.1 Integrated rail freight infrastructure
such as large scale rail freight interchanges struggle to gain
planning permission and often face lengthy and expensive planning
inquiries. The proposals in the Planning White Paper made no reference
to rail schemes and as such offered little chance of addressing
these difficulties.
3.5.2 One of the weaknesses of local planning
inquiries is the lack of a national policy on freight transport.
A policy of this kind would present the benefits and impacts at
the national level and set local planning decisions in the context
of the national need to achieve modal shift.
3.6 Influencing Europe (Bullet 5)
3.6.1 As set out above, we encourage the
Government to continue to press for a satisfactory outcome to
freight access on CTRL and through the Channel Tunnel.
3.6.2 Road haulage has an advantage over
rail freight when travelling to Europe and beyond as it can use
the Transports Internationaux Routiers (TIR) system. TIR is a
system which enables the movement of goods under custom seals3.
These seals provide a guarantee that the custom duties and taxes
are covered and this alleviates the need to check goods at customs
and excise. This aids the smooth movement of goods through TIR
countries and in-turn reduces delays in transporting good and
reduces associated costs. Rail freight does not have such a system
in place and when transporting goods into Europe it may be in
a poorer position to compete with road haulage between TIR affiliated
countries. This is particularly the case when importing and exporting
perishable goods.
3.7 Freight quality partnerships (Bullet 6)
3.7.1 No specific comments
3.8 Improving road safety (Bullet 7)
3.8.1 Increasing the permitted weight of
HGVs to 60 or 84 tonnes is expected to introduce new types of
risks and have a detrimental impact on road safety,[38]
which is contrary to a point raised by the Transport Committee.
3.8.2 It is widely recognised that rail
transport is much safer than road transport.[39]
One way to improve road safety is to realise modal shift from
road to rail freight.
3.9 Further areas for consideration
3.9.1 Increasing permitted weights of HGVs
could bring additional impacts on the existing road infrastructure.
Increasing the weight leads to the need for enhancement to the
existing infrastructure to cope with the extra tonnage and more
costs in terms of maintenance to repair wear and tear.[40]
This will bring extra cost in terms of undertaking the work and
also extra carbon cost in terms of producing and delivering the
materials to undertake the enhancements. Taking these factors
into account, Government needs to take into consideration whether
rail is better placed to carry increased loadings by extending
train length instead of increasing the permitted weight of HGV.
3.9.2 Similarly, increasing the length of
vehicles can have adverse impacts on the road transport network.
The suggested use of longer, heavier vehicles (LHVs) in the UK
has led to concerns ranging from environmental efficiency to safety
and societal implications.[41]
Other concerns relate to the impact these vehicles could have
on existing road infrastructure and the possible increase in traffic.
3.9.3 Freight customers need to be carefully
considered when developing an integrated transport plan. The development
of a national policy for freight could help to influence customer
decision making towards rail through placing an increased emphasis
on the need to use more sustainable modes. Incentivisation of
major suppliers by Government could also help to influence this
shift.
4. RECOMMENDATIONS
FOR ACTION
4.1 One of the key weaknesses in respect
of freight transport that emerges in the points raised by the
Transport Committee is the lack of a national freight policy in
Great Britain. We ask that the Transport Committee recognise that
a policy which sets out the Government's long term strategy for
freight, including their support for rail freight and priorities
for the development of the GB freight network and services, would
assist the rail industry, those who operate and use logistics
services, and planning authorities.
4.2 It is our aspiration that rail freight
should form part of an integrated freight network where each mode
is used to realise its relevant strengths in delivering sustainable
freight movement. We encourage the Transport Committee to promote
this sustainable approach.
36 The Case for Rail 2007 by the Rail Safety
and Standards Board. Back
37
Government's White Paper "Delivering a Sustainable Railway"
indicates that the projected growth of freight carried by rail
over the next 10 years as 30%. Back
38
International Road Transport Union website www.iru.org Back
39
Mega-Trucks versus Rail Freight? Facts and Arguments by UIC, CER,
UNIFE, ERIM and ERFA dated June 2007. Back
40
Annual Safety Performance Report 2006 by the Rail Safety
and Standards Board Back
41
Study by Freightliner on the affects of modal share in the deep
sea container market of the introduction of the Longer Heavier
Vehicles (LGVs) Back
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