Mayor’s Transport Strategy Consultation

Response from Rail Freight Group

September 2017

  1. Rail Freight Group (RFG) is pleased to respond to the consultation on the Mayor’s Transport Strategy. No part of this response is confidential.
  2. RFG is the representative body for rail freight in the UK, and we campaign for a greater use of rail freight, to deliver environmental and economic benefits for the UK. We have around 120 member companies including train operators, end customers, ports and terminal operators, suppliers including locomotive and wagon companies and support services.

General Comments

  1. London is a thriving, successful and growing city with demanding transport needs. The current transport network, despite its many successes, has challenges which create adverse impacts on users, businesses and the wider community. The draft Mayor’s Transport Strategy is therefore an important document in planning how the transport network should be developed to better meet the city’s needs into the future. Overall, we support the aims of the strategy and its long term approach to setting a framework for growth.
  2. The movement of freight, whatever the transport mode, is a critical element of a city economy. New houses and offices need construction materials. Businesses cannot function without efficient deliveries, shop shelves need to be kept constantly refreshed, and consumers expect their needs to be met – be that for food, clothes, consumables, household goods and all that is necessary for life. Failing to meet these requirements effectively will damage quality of life, increase costs and create environmental impacts for citizens and businesses.
  3. This fundamental link between economic prosperity and efficient freight and logistics should be an elemental part of transport thinking for any city. We are concerned that this connection is missing from the draft strategy, and that freight movement is considered only in the margins. Although there are proposals for freight in the consultation, there is still a strong feeling that this is just an ‘add on’ to the base proposition that transport is for passengers.
  4. For rail freight the position is acute as the consultation is particularly negative, making a number of critical comments and showing little support for our sector. We have written to the TfL Commissioner (copy attached) suggesting that we need to find a new approach to resolving these issues and to moving forward as the current position is clearly unacceptable.
  1. Rail freight in London today contains a number of important flows. This includes;
  2. Construction trains which deliver around 40% of the building stone, cement and other materials used in the city. These trains operate into terminals around the city, including Battersea, Greenwich, Kings Cross, Bow and elsewhere. Construction waste is also removed by rail, and imported sand, which is delivered by river, is also distributed by train.
  3. The north Thameside corridor is a major generator of rail freight traffic, including the ports at London Gateway, Tilbury and Purfleet, as well as other industrial and construction users. The terminal at Barking is a major hub and is also able to accept trains via HS1 from the Channel Tunnel and mainland Europe. Although these locations are on the periphery, indeed some are outside the London boundary, they are within the employment area. Goods delivered to these locations, for example by retailers, is also warehoused for London nearby.
  4. Small parcels are conveyed on passenger services into St Pancras International and Paddington station, and there have been trials of supermarket goods into Euston station.
  5. Rail freight can deliver fuel to Heathrow, and was been heavily involved in the construction programme for Terminal 5, as well as the Olympics and more recently Crossrail. We expect to play a significant role in construction logistics for HS2.
  6. London’s railways are also used by trains moving from ports and Channel Tunnel to warehouses in the Midlands and elsewhere. Ideally, such services would be routed away from the conurbation, but such diversionary routes do not exist, and are not likely to exist at any time soon. The environmental and economic benefits of these trains are significant, and we would expect the Mayor to support them, even where those benefits fall outside the conurbation, as part of the wider relationship between London and the rest of the UK.
  7. The absence of suitable rail linked warehousing in London also means that opportunities to use rail services to deliver goods to the city cannot be developed as expected. This is a strategic gap and one which we would expect the Mayor to address.

Comments on Specific Proposals

  1. Proposal 15 : We support this proposal, and consider that there are opportunities to increase the proportion of rail freight in some of these areas;
  2. Consolidation centres, whether for construction or other products, should be rail served where possible. There is a particular opportunity to rail serve construction consolidation centres on existing sites or on new fit for purpose locations.
  3. The Mayor should support the development of strategic rail freight interchanges in and around the city to increase the proportion of rail served goods for London. Such a move can also support city centre deliveries for example at night, and use of passenger services for small parcel traffic.
  4. Proposals for retiming deliveries should take account of operational constraints on the rail network, and planning restrictions at terminals. (For example, freight trains will avoid the passenger peak periods so will be timed to arrive ahead of this).
  5. If freight, and in particular rail freight is to prosper, it is essential that there are sufficient terminals which can operate flexibly. Our members are struggling with inappropriate adjacent development, which can hamper operations and cause significant local issues. Rail connected land sites are also being lost for housing. This will hamper our ability to operate efficiently, and once lost, land cannot be brought back into freight use.
  1. Protecting industrial land is therefore key, and we support strong measures to safeguard existing and possible future rail linked sites including from inappropriate adjacent development. We recognise that this is a matter for the London Plan, and there should be strong input from this Strategy. With high land values and pressure for residential development protecting land for freight use is a key priority, without which it will be harder to meet the other objectives of more efficient freight movement.
  1. Proposal 16 We support this proposal, but as outlined elsewhere in this response, consider that the overall support for rail freight in the strategy is poor. A renewed relationship between the Mayor, TfL, Network Rail and the rail freight sector must be established to drive forward this proposal.
  2. Proposal 36 We support this proposal and are keen to work with stakeholders to ensure that rail freight can continue to support emissions and CO2 reduction targets, and move forward in reducing its own emissions. We welcome support for further electrification but note that this needs to be combined with a wider network beyond London, recognising that there would need to be a significant investment in new freight locomotives. In the short term, reinstatement of the electrification of the freight elements of the Gospel Oak to Barking project, which were removed from the scope by Government, would enable some services to convert to electric haulage over time.
  3. Proposal 39 We support measures to reduce emissions from NRMM, but recognise that these can also have implications for our sector. In taking forward this proposal, the Mayor must be mindful of the implications on rail freight and on terminals, and work with the sector to develop the most effective way forward. This should ensure that a progressive approach is taken which allows continued operations and recognises the significant long term capital cost of rail equipment.
  4. Proposal 47 We recognise the need to take proportionate and sensible measures in this area. However there must be a balanced approach with other parts of the strategy. With restricted network capacity, freight often operates at night to avoid the busier passenger periods. Further restrictions will therefore mean freight operators will seek additional daytime paths. The Mayor must work closely with Network Rail and the rail freight sector to find a balanced approach which helps to achieve this proposal.
  5. Proposal 64 This section of the consultation is the most concerning, and reflects poorly on the Mayor’s approach to rail freight. As outlined in our attached letter, we need a more collaborative approach, and to avoid public rhetoric of this nature.
  6. That said, we also need to address the specific points raised. In detail, this would best be done in conjunction with Network Rail and the freight operators, and we would suggest this is taken forward as a priority. Specifically, however, we note as follows;
  7. Currently parts of the London Overground network are shared with freight trains. The Mayor does not own or operate the rail network around London (aside from the East London core), this is for Network Rail. As such, this sentence should say ‘London Overground services share the rail network with other operators, including freight trains’.
  8. These slow moving, long trains limit the full potential of the network for passenger trains. Freight trains are slow moving around London precisely because they are frequently held to make way for passenger services. We would also like to see an increase in average speed, as the currently attained velocity damages productivity. Longer freight trains are more efficient, as they can move more goods in fewer trains. As above, the rail network is not solely for passenger trains, and is a shared resource, with access determined by Network Rail and the ORR.
  9. This impact could be reduced (etc). Freight trains already operate more at night, and generally avoid the passenger peak periods. If there are specific trains at peak times, then the Mayor should discuss this with the operators to see whether retiming is possible. We are unaware of any such discussions.
  10. Unused paths This area has been discussed repeatedly over many years. Whilst freight services do have seasonal variations, and whilst Network Rail maintain some strategic capacity, the suggestion that freight is preventing passenger services is ill founded. We are aware of no cases where London Overground has had access denied because of freight. There are also differences of understanding over engineering access, and the distinction between paths in operator’s contracts, and those which exist in strategic capacity. On the West London Line, paths are defined in law, dating from the Channel Tunnel agreements.
    The perennial tit for tat in this area frustrates sensible dialogue over how future aspirations can be jointly addressed, and we need to move forward more collaboratively to address this.
  11. Reservation charges The ORR have previously ruled out the introduction of reservation charges and this should be respected. The proposal createsa perverse incentive towards short term booking, which in turn can impact on performance. London Overground can already call on ‘use it or lose it’ provisions which allow unused paths to be taken back, but we are not aware of any occasion where they have done so.
  12. Rerouting of Services. We support an upgrade of the Felixstowe to Nuneaton route, to support a growth in traffic from the port. However, all work on the upgrade was effectively stopped as part of the re-scoping of Network Rail’s CP5 programme. As such, it is unrealistic to expect that any traffic can now be rerouted. Although a small number of network paths are available on that corridor, they are expected to be used through growth in port traffic, unlocked by the present work on the branch line. In many cases, available paths have also been compromised by growth in passenger traffic from the Greater Anglia franchise.

The proposal for a diversion for traffic from Essex Thameside is aspirational at best, and should be removed from the strategy. No work has been done on this proposal, and the resultant increase in journey time would be detrimental to costs, such that traffic would likely be lost to road.

  1. Although we support proposal 64, we do not accept the core premise that rail freight should not operate in London. This section should be entirely reworded for the final strategy.

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Attachment – RFG Letter to Mike Brown

10 July 2017

Mike Brown

Commissioner

Transport for London

By email

Dear Mike,

Mayor’s Transport Strategy Consultation – Rail Freight
I am writing to express our concerns over the rhetoric regarding rail freight in the consultation draft of the Mayor’s Transport Strategy.

We will of course respond formally to the consultation on a number of relevant areas, some of which are positive, others less so. Indeed the commitment in Proposal 16 to work to move freight from road onto rail and water is particularly welcome. However I felt it was timely to raise our concerns with you over the issues of North London Line and Gospel Oak to Barking, where freight services operate alongside London Overground.

The particular points raised on page 163 of the consultation are not new to us; indeed they are persistently raised in any conversation relating to rail freight with some parts of TfL. Over time, I know that Network Rail, and the freight operators, have attended several forums with you to discuss these concerns and to look in detail at the points raised, but it is clear now that these have not been successful. Recognising your ambitions for growth, a collaborative approach to the corridor is clearly necessary, but achieving this is not helped by such public rhetoric.

There are many points of detail in the consultation draft which we would dispute, including comments on ‘slow and long’ trains, operations in the peak, the holding of paths, capacity on other routes and the ability to re-route trains elsewhere on the network. I do not intend to get into ‘tit for tat’ words in this letter, but it is clear that there needs to be further discussion and resolution of these points. The draft also calls for new regulatory mechanisms – which have in fact been previously ruled out by ORR – yet we can find no evidence that TfL are using the already available regulatory mechanisms in respect of capacity, for example the use it or lose it provisions.

Most fundamentally however, the consultation text in this section fails to recognise that moving more goods by rail is a stated aim of the Mayor, as well as of Department for Transport and of all major political parties. The freight which moves around London, wherever it is destined, serves to remove lorries from the strategic road network, including around London, and to deliver environmental and safety benefits to the UK. Traffic to and from the North Thameside area, including the major ports at London Gateway and Tilbury is supporting local economies and jobs on the edge of the London conurbation, and also supporting warehousing and distribution activity for London consumers. Construction trains are delivering around 40% of all building aggregate into London yet do not even get a mention!

It is clearly imperative that we seek to find a way forward and to develop a more constructive and collaborative approach to addressing these issues and finding shared solutions on the rail routes around London. I would suggest that, in the first instance a regular ‘Concordat’ is established from which appropriate actions could be developed and rapidly progressed.

I would welcome your thoughts on this approach, and to developing a renewed relationship between TfL and the rail freight sector.

Yours sincerely,

Maggie Simpson

Executive Director

cc Paul McMahon, Director, Freight and National Passenger Operators, Network Rail

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