National Planning Policy Framework

Written evidence from Rail Freight Group

1. Rail Freight Group (RFG) is pleased to submit evidence to the Communities and Local Government Committee Inquiry into the National Planning Policy Framework (NPPF).

2. RFG is the representative body for rail freight in the UK. We campaign for a policy framework that supports a growth in the use of rail for the movement of freight where it is environmentally and economically appropriate to do so. We represent over 100 member companies who are active in all areas of the rail freight sector, including train operators, customers, suppliers, developers and support services.

General Comments

3. Traditionally, rail freight thrived in the movement of bulk commodities such as coal and stone. These sectors remain important today. However, in recent years, the rail freight sector has made significant inroads into the movement of consumer goods, particularly in the movement of containerised imports from the UK’s deep sea ports. Rail has achieved market shares over 20% at the major locations, with growth continuing. Rail has also started to play an increased role in the movement of consumer goods within the UK, for major retailers such as M&S and Tesco. Forecasts of growth demonstrate that these areas are the most likely to expand, driven by high fuel prices, road congestion and environmental concerns.

4. To support this growth, and to underpin the existing bulk flows, there is a need for new and improved rail terminals. These range in scale from small facilities, such as stone terminals or single user rail linked warehouses to large scale rail freight interchanges such as the site at Daventry in the Midlands. Terminals are the equivalent for freight of passenger stations; without them, goods cannot get onto the railway.

5. Gaining planning permission for rail linked sites has however been difficult. Large scale interchanges have suffered particularly, because of their size and a lack of suitable locations which need to have excellent road and rail links. The largest such facilities, over 60Ha are therefore included in the Planning Act 2008, and we await the relevant National Policy Statement (NPS) which is due to be published by DfT later this year.

6. Smaller facilities have also had difficulty in getting planning permission. Rail terminals are not popular neighbours, and in many cases, housing developments have been permitted close to existing rail lines and rail freight sites which increases the problems from noise and vibration. Such facilities are not covered by the Planning Act and, as such, the NPPF will be the relevant planning document.

7. The lack of suitable facilities is a constraint on rail growth, particularly in the retail sector. It is also of note that such facilities can be significant employment generators – for example the first phase of the Daventry development employs around 2,500 people.

8. One of the principle difficulties faced by rail freight interchanges is that the many of the benefits of such facilities, whilst significant, are measured at a regional or national level, whilst any disbenefits are generally felt locally. It is therefore imperative that the planning framework enables planning authorities to take a ‘larger than local’ view. This has previously been provided by Regional Spatial Strategies, and supporting documents, now abolished. The NPPF therefore has a vital role to play in filling this gap. However, it is unclear whether the duty to co-operate clause alone will fully fill this need.

Specific Comments on NPPF

9. Overall, we consider that the NPPF is a good document for supporting the appropriate development of smaller rail freight terminals, and informing local authorities on the planning considerations for larger facilities which are formally covered by the Planning Act. We would not support significant further changes to the document.

10. Turning to the particular questions;

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

11. We consider that the draft NPPF gives sufficient guidance on planning principles and aims. However, we note that, with a great emphasis on the role of Local and Neighbourhood plans, it will be vital to ensure that the delivery of the aims of the NPPF is carried through into those documents in each planning authority area.

12. The transitional arrangements when Local Plans are not in place, or not compliant with NPPF may need further consideration.

Is the definition of ‘sustainable development’ contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

13. We support the presumption in favour of sustainable development as an important factor in allowing rail freight facilities to gain planning permission where appropriate.

14. Rail freight is acknowledged as a more environmentally friendly mode of transport. On average, it produces around 70% less CO2 than road transport, and also contributes to reducing road congestion and road safety. Facilities which link warehousing and rail terminals help to further reduce carbon emissions by eliminating road hauls to and from the terminal.

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

15. As the National Policy Statement covering rail freight interchanges has not yet been published, even in draft, we cannot comment on the relationship. However, the draft NPPF appears to integrate well with the principles we would expect to see in the NPS.

16. The formal and legal relationship between the NPPF and NPSs may need to be clarified specifically.

Does the NPPF, together with the ‘duty to cooperate’, provide a sufficient basis for larger-than-local strategic planning?

17. The NPPF gives a strong indication to local authorities on the need to work with neighbouring bodies in developing local plans. Diligent, pro growth, authorities are likely to take this duty seriously and to develop plans which do work on a ‘larger than local’ basis. However we remain concerned that some bodies will play lip service to this requirement particularly where they are opposed to infrastructure which meets a sub national or national need in their area. The wording of the relevant NPSs will be important.

18. It is unclear if the NPPF and duty to co-operate clause will sufficiently fill the need for sub national planning for transport.

Rail Freight Group

September 2011