Written evidence from Rail Freight Group
(ARSS 29)
SUMMARY
Rail Freight Group is concerned that the abolition
of Regional Spatial Strategies will damage the rail freight sector's
ability to grow.
A greater use of rail freight is a key part of sustainable
freight transport, but will require new terminals and interchanges
to be developed. Regional planning has been helpful in making
the case for such facilities where the benefits are measured regionally
and nationally.
To avoid a planning vacuum, or a policy that prevents
appropriate development of such facilities, there should be:
A strong National Policy Statement with clear guidance
on the national and regional need for rail freight terminals;
A clear role for National Policy Statements in the
planning process for schemes below the threshold level;
The "duty to co-operate" extended to clarify
the areas which must be covered by such co-operation and the outputs
which are expected;
Clarity on the legal status of documents produced
by Local Enterprise Partnerships in consideration of planning
applications; and
Incentives given to Local Authorities to plan for
"unpopular" developments such as rail freight terminals
in their areas, akin to the recent announcement of incentives
for house building.
INTRODUCTION
1. Rail Freight Group (RFG) is pleased to submit
evidence to the Inquiry by the Communities and Local Government
Committee into the Abolition of Regional Spatial Strategies (RSSs).
2. RFG is the representative body for rail freight
in the UK. Our aim is to grow the volume of rail freight where
it is economically and environmentally sound to do so. We represent
around 120 member companies operating in all sectors of rail freight,
from train operators, ports and shipping lines to customers and
suppliers.
3. Amongst our members are the operators and
developers of rail freight terminals across the UK. These member
companies are often deeply involved in the planning process, for
major new sites and also for modifications and developments of
smaller facilities. They have expressed their concern to us regarding
the abolition of regional planning, and more generally with aspects
of the proposed reforms. This submission seeks to capture these
concerns.
4. We note that the primary focus of the Inquiry
is the implications for house building of the decision to revoke
RSSs. RFG has no opinion on this matter. This submission is therefore
concerned with the impact on rail freight of this policy.
RSSs and Rail Freight
5. In order for rail freight to grow its share
of the logistics market, new and expanded rail terminals and interchanges
are needed. This ranges from smaller facilities through to major
sites with rail linked warehousing. These facilities need to be
located next to rail lines, and also have excellent road links.
This tends to limit the number of locations which are suitable
for such facilities.
6. Rail freight is acknowledged as offering significant
benefits to the UK, through reduced carbon and other emissions,
and by reducing road congestion. The benefits are measurable on
a national and regional basis, but are less tangible at a local
level where there may be specific disbenefits of road and rail
traffic. The planning framework therefore needs to enable these
national and regional benefits to be balanced against the local
disbenefits which occur.
7. RSSs were a key document in setting out the
framework under which such judgements could be made. They provided
a long term framework for land use and transport planning which
would then guide the preparation of local authority development
plans and local transport plans. As they were statutory documents,
they had significant status in the planning system.
8. In some regions, supporting documentation
was also established, such as the Regional Freight Strategy produced
by the West Midlands Regional Assembly. Such documents have been
particularly helpful for developers of potential schemes, and
for the rail freight industry overall, as well as for the local
authorities within the region.
9. This was particularly important as there is
no up to date national strategy for the development of rail freight
terminals which a planning inspector could rely on. Under the
Planning Act 2008, larger rail freight facilities will be included
in the scope of the Infrastructure Planning Commission (until
its abolition) and covered in the National Policy Statements (NPS)
for National Networks. However this has not yet been produced.
10. Overall therefore the RSSs provided a coherent
regional framework against which particular rail freight facilities
could be assessed. With their abolition, there is now a vacuum
of planning policy for rail freight, which will exist at least
until the NPS is available, and beyond for smaller facilities.
The Proposals to replace RSSs
11. Government has suggested that a "duty
to co-operate" should be placed on local authorities to cover
matters formally included in the RSSs. It is unclear what such
a duty will mean in practice. For example, if a group of local
authorities decide jointly not to produce any transport planning
guidance, would this be acceptable? It is unclear that the "duty
to co-operate" will facilitate the development of appropriate
sub regional strategies.
12. Local Enterprise Partnerships may have a
role to play in considering regional strategies for transport.
However, whilst they are being encouraged by central Government
they are neither funded, nor steered by them, and we would therefore
expect that the various Partnerships will vary significantly in
scope and outputs. It is therefore doubtful that they could be
relied upon fulfil a planning function. The current proposals
for LEPs do not give full coverage across England.
13. Any studies or plans produced by a Local
Enterprise Partnership would not have the same legal status as
an RSS. In planning terms therefore, it could not be given the
same weight of consideration as, for example, a Local Development
Plan. As such, its value for rail freight and transport schemes
would be limited.
14. We consider that to facilitate the development
of rail freight there must be strong guidance on a "greater
than local" level to help planning inspectors assess the
case for new facilities. We consider that, as a minimum, this
will therefore require:
(a) A strong National Policy Statement with clear
guidance on the national and regional need for rail freight terminals;
(b) A clear role for National Policy Statements
in the planning process for schemes below the threshold level;
(c) The "duty to co-operate" extended
to clarify the areas which must be covered by such co-operation
and the outputs which are expected;
(d) Clarity on the legal status of documents
produced by Local Enterprise Partnerships in consideration of
planning applications; and
(e) Incentives given to Local Authorities to
plan for "unpopular" developments such as rail freight
terminals in their areas, akin to the recent announcement of incentives
for house building.
September 2010
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