DEFRA / DfT Consultation - Tackling Nitrogen Dioxide in our towns and cities

Response from Rail Freight Group

June 2017

  1. Rail Freight Group (RFG) is pleased to respond to the joint DEFRA/DfT consultation on tackling nitrogen dioxide in our towns and cities. No part of this response is confidential.
  2. RFG is the representative body for rail freight in the UK. We have around 120 member companies including train operators, end customers, ports, terminal operators, developers, rolling stock and wagon businesses, supply chain and support services. Our aim is to increase the volume of goods moved by rail.
  3. The majority of the measures in this consultation relate to road vehicles, and as such are out with the mandate of RFG. However, effective rail freight relies also on effective road freight, for example for final deliveries, and so it is important that measures to reduce emissions from road vehicles enable efficient and cost effective road freight in support of rail based logistics.
  4. For rail freight specifically there are two areas of consideration, neither of which are prominent in this consultation. These are;
  5. Encouraging a greater use of rail freight
  6. Measures to help diesel rail freight to further improve its emissions.

Encouraging a greater use of rail freight

  1. Rail freight is acknowledged to produce fewer emissions harmful to air quality than the equivalent journey by road. Data from Freight on Rail shows Rail produces 90 per cent less PM10 particulates and up to 15 times less nitrogen dioxide emissions than HGVs for the equivalent journey. . Encouraging a greater use of rail freight is important for Government in improving air quality.
  2. Government’s Rail Freight Strategy published last autumn sets out a framework for an increase in the use of rail freight. This includes a providing stable framework of access charges which supports private sector investment, and ensuring that capacity for freight is safeguarded on the network. The actions in this strategy continue to be developed as a priority.
  3. In addition, although we recognise that investment in rail projects is likely to be limited in the next control period, Government should consider how it can enable limited investment to support rail freight projects. This also includes the budget for revenue support grants.
  4. For urban centres where air quality is often worse, a significant factor is ensuring that suitable terminals for rail freight are provided at key locations. With pressure for housebuilding, industrial locations are often under threat of redevelopment and/or inappropriate adjacent development which can limit on site operations and deliveries. These factors are making it hard for rail freight to develop.
  5. We consider that there should be a strengthening of planning guidance and powers to ensure that existing railheads are sufficiently well protected that new locations can be developed. This is particularly important in London.
  6. Outside of urban centres, Government support for new strategic rail freight interchanges continues to be essential to achieve reductions in trunk road movements. This will help facilitate improvements in air quality on the strategic road network, and also enable greater use of rail freight into city terminals. Recent work for DfT by Freight on Rail shows how rail can reduce road congestion as part of an aligned road and rail investment strategy.

Measures to help diesel rail freight to further improve its emissions.

  1. Although rail freight can offer reduced emissions compared to road freight there is no place for complacency. The industry is aware of the need to reduce emissions further and is working on a number of initiatives to do so, such as the introduction of ‘start – stop’ technology in some locomotive fleets. However the long asset life of rail equipment and the small UK market for equipment can make it harder for innovation and change to occur.
  2. Although the private sector operators and customers must lead, there is a role for Government in helping to facilitate improvements. This includes;
  3. Ensuring that Government funded research and development programmes, for example on alternative fuels and battery technology cover rail freight. Presently, such programmes have been focussed on HGV and/or passenger rail.
  4. Supporting improved data on rail freight emissions to help inform decision making.
  5. Clarifying the long term strategy for rail electrification and the expectations on the industry over future traction strategy.
  6. Ensuring that rail freight is a central part of Government investment in digital railway, to enable improvements in freight performance and pathing on the network, which in turn can reduce fuel use.

Specific Comments on Consultation

  1. Section 4.1 We note that Local Authorities will be empowered to take specific and bespoke action within Clean Air zones. For rail operators and customers who operate national businesses such an approach is likely to add a significant burden if individual cities have different requirements and approaches. A national framework should be developed to set out the core standards which will apply.
  2. Section 4.2 As above, the various funding streams to date have focussed only on roads and should be expanded to other modes. The possibility of retrofitting rail vehicles with lower emission equipment should also be explored.
  3. Section 4.4 Ultra low emissions technology research, including hydrogen, should include rail as well as road.
  4. The review of the HGV Road User Levy should take account of alternative modes and encourage modal shift where appropriate. Generally, rail can work most effectively over longer distance trunk hauls, working with road for final delivery.
  5. We will respond separately to the call for evidence on red diesel. However, for rail, it is important to note that although lower duty red diesel is used, operators also pay a specific track access charge for use of the infrastructure which is not paid by road freight. This is paid per ‘tonne-km’ moved, and recognises the wear and tear costs imposed on the rail infrastructure.
  6. We note that Government is also planning to look at emission standards for non-road equipment. For rail, emission standards have been set by the European Non Road Mobile Machinery directive which recognise the specific considerations around diesel rail locomotives, including for the UK market the limited physical space available. Any work to revise standards must have a specific consideration of what is achievable and affordable for the rail freight market, alongside the measures already mentioned in this response.