ASLEF Evidence Submission – Department for Transport - Freight and logistics and the planning system

The Department for Transport ran a call for evidence from 04/07/23 to 06/10/2023 on the planning system and freight and logistics. The intention was to try and understand any areas where there planning system may not be working to the benefit of the freight and logistics sector which is critical to supporting UK supply chains. 

Below is ASLEF's response to the call for evidence

ASLEF Call for Evidence Response – Department for Transport - Freight and logistics and the planning system

1. The Associated Society of Locomotive Engineers and Firemen (ASLEF) is the UK’s largest train driver’s union representing just under 22,000 members in train operating companies, freight companies as well as London Underground and light rail systems.  
    
2. We represent over 2,000 drivers working for freight operators and have working relationships with the employers and the Rail Freight Group. We have campaigned on the importance of rail freight[1] and welcomed the UK Government highlighting the importance of rail freight for achieving net zero and growing the economy in the Future of Freight: A long term plan.             
    
3. We welcome the DfT’s investigation into the relationship between freight and logistics and the planning system in England as we believe there are some areas where the planning system could be reformed to ensure that freight and logistics are better factored in to current and potential development plans. For example, there are under used railway yards which have the potential to play an important role in growing rail freight in the future, but current planning practices could lead to areas nearby being developed to an extent which limits this possibility, we will detail this example and others in line with the questions of the call for evidence.              
    
4. Whilst addressing issues in the planning process should help to ensure that freight and logistics are better factored into local plans. Ultimately, we know that there needs to also be a political will and leadership to invest in freight and logistics, particularly in rail freight if we are to achieve net zero by 2050 and efficiently grow the economy, a lack of an overarching transport strategy in England / across the UK feeds in to this, with projects being able to announced and cancelled without the impact of such decisions being assessed with regards to an overarching strategy. We have unfortunately seen recent infrastructure projects such as HS2 cut back and partly cancelled, reducing the full impact this project would have in releasing rail freight capacity. Any changes to the planning system will ultimately need the political will to invest in our railways to enable rail freight to appropriately grow. Businesses also need certainty from the Government that their investments in the UK will not be impacted by flip flopping on major infrastructure projects which would enable freight and logistics to appropriately grow.  
    
5. Currently rail freight massively reduces carbon emissions by up to 76% for an equivalent road journey. Even when HGVs are battery powered, an electrified rail freight network will make more environmental sense as it will transmit useable energy to the rails with fewer transmission losses than those associated with battery or hydrogen storage for the movement of freight across the country. The choice of rail freight over road for long journeys would ultimately ensure that the road network requires less maintenance due to a reduction in volume of HGVs and their subsequent weight, which batteries will increase. To ensure that businesses have the best choices for the environment, investment is still needed to electrify the railway and ultimately expand the rail network, unlocking capacity for rail freight to allow businesses to utilise the railways for freight and logistics and reduce the environmental impacts of their supply chain.            
    
6. We hope that local planning can be improved to increase freight and logistics and grow rail freight as the Future of Freight plan calls for, to this end we are still awaiting the publication of the rail freight growth target to gauge the seriousness with which the government views growing rail freight. We will highlight via the questions, specific areas where planning may be missing opportunities to grow rail freight and how to address these.                

Question 1
In your view, how effective are local plans at identifying development needs, and then allocating sites, for freight and logistics and how could this be improved?

7. Currently there seems to be a knowledge gap among the planning community when it comes to freight and logistics and the role rail freight can play in sustainable growth as part of local plans. This gap, seems in part, due to the reactive nature of local plans which favour developers in their efforts to persuade local authorities to allocate sites for house building instead of freight and logistics sites as the housing helps to address an immediate concern and offers greater land value in the short term but could lead to further bottlenecks in supply chains in the long run. To help address this, planning guidance should elevate planning for rail freight to the same level that applies to housing or other infrastructure.
    
8. Local plans can be developer led, further compounding short term gains over achieving longer term objectives. This in part is a consequence of recent pressure on local authorities to meet housing targets due to the housing crisis.
    
9. Freight and logistics sites need to be factored in with greater weight where local plans currently favour housing land. The plans can sometimes ignore the freight and logistics demands that these housing developments generate. Planning authorities could benefit from shared data on freight and logistics availability in the area to enable them to better factor in the availability of the freight and logistics required to deliver a housing development, of which rail freight would help to reduce the environmental impact by the reduction in the need for HGVs to make long haul journeys, particularly if rail served warehousing is available within their area. To further assist in this aim, the needs of developers of rail served warehousing and rail served construction material suppliers could be given equivalent weighting within the planning system to those of housing or employment land.               
    
10. Another way to improve the allocation of sites for freight and logistics would be to place a duty on planning authorities to consider the closeness of the rail network when assessing new site allocations for storage and distribution purposes, as linking it to rail will enable wider growth and greater uses. This would further encourage and achieve a modal shift from road to rail and assist the UK Government in achieving net zero on time.               
     
11. Planning authorities may require greater guidance when allocating housing developments which are on land adjacent to existing rail freight operations, particularly rail freight operations which have the potential to be expanded. If the long-term role that rail freight could play in the area is not adequately considered it could lead to local objections blocking any future development of the rail freight operations due to the proximity of those now living in the dwellings at the developed site adjacent the operations. This could ultimately hold back the potential of the freight and logistics sector in the UK and throttle the UK’s economic growth as new rail operations would need to be built elsewhere, taking more time and bringing greater expense rather than expanding and growing in current areas of operation.
     
12. The use of the ‘agent of change’ principle could be developed further to be embedded in the planning process. This could happen via the National Development Management Policies as part of the Levelling Up and Regeneration Bill. This could be enshrined in law which could protect current site operators from having their operations curtailed by a new housing development which did not sufficiently factor in the potential for nuisance for residents that the current freight and logistics i.e. rail freight site could have.

Question 2
How effectively are the policies in national planning policy (Chapter 6) and associated practice guidance applied by plan makers in supporting the needs of freight and how could this be improved?

13. The National Planning Policy Framework (NPPF) could do with strengthening as it does not explicitly state ‘freight and logistics’ when outlining what planning policies should do, with only a brief mention of storage and distribution under paragraph 83.        
     
14. In fact, rail freight is barely mentioned in the NPPF and this should be addressed to further encourage plan makers to support the needs of freight. This would be in line with the Future of Freight Plan and the desire from government to achieve a modal shift to more sustainable transport options for freight.
     
15. The NPPF could further benefit freight by putting a greater focus on the ability of rail freight to deliver a sustainable future. Whilst allocating a site for new rail served warehousing may generate an increase in road traffic around the site which could lead to objections, it would ultimately be for the greater good as it would reduce the miles of HGV movements across the UK as rail freight would be able to replace a large quantity of equivalent long haul HGV journeys. The wider impact of developments with regards to sustainability must also be considered to avoid objectors to site plans influencing local decision makers when the overall impact on sustainability outweighs the local objections.

Question 3
How effective is engagement between industry and local authorities in the course of local plan making? How can this be improved?

16.  Currently there can be failures with engagement in the course of local plan making when the local authorities do not have clear guidance on who it should be engaging and consulting with. For example one authority may be obliged to consult with Network Rail if the railway passes through their local plan area but it may fail to capture the opinion of a port operator that is anxious to increase capacity on the network in the local plan area but whose port is based outside of the local plan area. Whilst local authorities are obliged to consult with their immediate neighbours, users of key freight corridors which start and finish outside of these areas may not be appropriately engaged with. The Future of Freight Plan outlined a plan to review the local planning guidance alongside the identification of the national freight network and we would be supportive of this work being undertaken to lead to the publication of a list of local authorities on the national freight network, outlining their duty to engage with freight stakeholders during the local plan making process. This should of course update when the network expands and encompasses new local authorities.
     
17. Ultimately the freight network and rail freight network cross borders and authorities. It is important that the whole network is appropriate considered when local plans are made with local authorities having a duty to properly engage with the users of the freight network, this could ultimately identify opportunities to grow the sector and boost local economies and increase the freight and logistics knowledge of planners. This will also help to combat some of the efforts by freight operators to not share information amongst each other to avoid losing out on potential contracts to competitors, if all users of the freight network are being engaged with by planners it would help to encourage greater transparency which could further help the sector grow.
     
18. Greater guidance and training for planning officers on the importance of rail freight can help to improve engagement with local authorities as presently many planners are more familiar with road building and can often see rail as too difficult, in part this is a result of UK Government policy which has been to shift funds away from the much needed rail investments, just recently the CILT[2] published a report that outlined how rail freight electrification would be possible for 95% of UK freight trains and transport East published their Keeping Trade on Track report[3] which outlines how an improvement in rail capacity at Ely junction is vital to the UK economy, levelling up and net zero, these ultimately need UK Government to ensure investment is made. Without greater guidance and training for planning officers and without UK Government policy pushing for rail, these innovations for rail freight and ultimately all freight and logistics can be missed, overlooked and not given the wider support that they require to deliver the ultimate economic gains that the UK could benefit from. Greater guidance and training delivered in tandem with local authorities on the national freight network having a duty to engage with freight stakeholders could ultimately lead to local plans that deliver both locally and nationally if they properly factor in freight and logistics, particularly rail freight.

Question 4
How effectively does planning currently support efficient use of established freight and logistics infrastructure? How could it better support existing infrastructure?

19. Local planning policy can sometimes lose focus on the efficient operation of current sites and only focus on new sites. There are potentials to improve efficiency which can be overlooked such as allowing current established rail accessed infrastructure sites to include the co-location of facilities for loading/unloading of express parcels at night, this could help to expand the use of rail for express parcels. 

Question 5
How should freight and logistics be factored into statutory local transport plans and sub-national transport strategies?

20. The Future of Freight Plan suggests an enhanced role for Sub National Transport Bodies (STB) to better align transport and spatial planning by sharing data and fostering greater collaboration across boundaries and between tiers. The widening of an STB’s remit to include spatial planning at a regional level could encourage collaborative work across boundaries with neighbouring STBs and could lead to a greater joined up approach with local authorities having a duty to have regard to regional transport plans when drawing up their own transport and local plans.

Question 6
What aspects of the applications and decision taking process work well and what aspects do not work well?

21. As outlined above there is scope for greater training and guidance for plan makers to further highlight the needs of rail freight and its importance to the wider economy.            

Question 7
How effective is the planning system at addressing the operational needs of the freight and logistics sector and how could this be improved? How could a national freight network be recognised in national planning policy?

22. Recognising a national freight network in a similar way to the national cycling network would give local authorities a duty to recognise and to consult with the network provider and end users, including adjacent terminal operators. The Future of Freight plan commits to achieving a standard where there is a duty to recognise and consult with those involved in the national freight network and we are supportive of this being delivered.           

Question 8
How can the planning system support our net zero ambition for freight and logistics?

23. Firstly the industry and the planning system needs to have confidence in the government’s commitment to achieving net zero and delivering rail infrastructure as this has recently been shaken by the announcement of the Prime Minister Rishi Sunak to push back the 2030 target to which the motor industry had been working to. The cancelling and delaying of parts of HS2 has also severely damaged the possibility of greater volumes of freight being moved by rail which would allow businesses to utilise rail freight to help the UK achieve net zero on target. As the UK government has consistently stated that rail is sees as the low carbon choice, however the actions of the government may leave businesses concerned about investing in utilising rail as part of their supply chain which would ultimately harm the UK’s net zero ambitions.        
     
24. There are concerns that currently the time for applications for strategic rail freight interchanges to receive approval could take longer than necessary. To address this the National Strategic Infrastructure Planning process could introduce an outline consent stage that mirrors the outline consent and reserved matters stages that are a familiar feature of local planning.
     
25. To assist the UK Government’s net zero ambitions the planning system should look to refuse logistic sites which are not rail connected as such sites would be contrary to national policy towards decarbonising freight and logistics.      
     
26. As we have outlined already, rail freight can reduce emissions by 76% for the equivalent road journey and even once HGVs are able to be powered by hydrogen and batteries, rail freight would still be the better environmental and social choice due to the higher efficiency of rail and the emissions from HGV tyres, brake pads and the weight of heavier vehicles damaging the roads, leading to more pot holes and unsafe roads. To this end the planning system should have regard for the importance of rail freight for the environmental and economic future of the UK.    
     
27. In recent years we have also seen the expansion of rail for the movement of ‘express parcels’[4] to enable this market to grow planning authorities should have a duty to assess the potential for sites that can be uses for the handling of rail borne parcel traffic in their local area when reviewing local planning policies. This could help assist last mile delivery in urban areas whilst furthering net zero ambitions.       

Question 9  
What more could local plans and decisions do to facilitate the supply of high-quality HGV parking and driver facilities?

28. We understand the DfT’s focus on HGV facilities due to the nature of planning system but it would be remiss of us to not highlight that access to appropriate welfare facilities can be an issue for our freight train drivers moving freight across the UK and this is something we have highlighted multiple times[5][6] as it is unsafe and has sadly contributed to at least one fatality.            
     
29. Ensuring cross modal movement of freight through the use of strategic rail freight interchanges (SRFI) should help to ensure there are appropriate parking and driver facilities for the traffic generated by the SRFI development, this could at some sites accommodate up to 100 HGVs. We would however be concerned with general purpose facilities for HGV drivers being included in SRFIs as this would unnecessarily increase the road traffic and could impact on the likelihood of a SRFI receiving approval.       
     
30. We have seen issues post Brexit with the movement of goods via Dover in HGVs leading to large delays with a lack of facilities for drivers. We do believe that some of this delay and need for more facilities could be relieved through a different approach to planning which would further encourage growth in rail freight and encourage use of rail freight through the channel tunnel which Network Rail is also working to increase[7].    

Question 10
How can planning policy in England help to support the freight and logistics sector across the whole of the UK?

31. Freight transcends boundaries and borders. To ensure that the freight and logistics sector supports the union, there needs to be complementary policies at the point/s of origin and the destination for freight. This is most important in the intermodal sector where Scotland and Wales require access to freight imported through the deep-water ports in the south of England. There is also a high importance on the ports of Felixstowe, Southampton and London Gateway for the access to trade with Asia that they provide. It is essential that there is a shared understanding in the planning process of the freight needs and the interaction of rail freight with local plans to continue to support the union, grow the UK wide economy and encourage a modal shift. We hope that the DfT is able to take forward some of our evidence listed above to help implement this shared understanding in the planning process.

Mick Whelan
ASLEF
General Secretary
77 St John Street
London
EC1M 4NN