The responses below are those of members of The Chartered Institute of Logistics and Transport(UK) Scottish Policy Group who have contributed to the discussion on Network Rail's Freight Route Utilisation Strategy Draft for Consultation.
Network Rail are to be congratulated on producing a document which lays out clearly, logically and in detail, their assumptions with regard to the growth of freight traffic on rail up to and including 2015.
The number of maps and tables, the information on network capability were all found to be very helpful in consideration of the document. The growth figures projected, based on the information available at the time of the document's publication, are considered to be realistic. It is recognised that the Freight RUS is a consultation document not Network Rail's last word on freight and therefore it can be altered if convincing arguments are put forward for change. The CILT Policy Group hopes that the Freight RUS will be a living document which is revisited and updated throughout the period to which it applies.
We have a number of specific comments on content:
A. "High-Cube" or 9'6" Containers.
We are concerned that the RUS may have underestimated the burgeoning growth in the use of 9'6" containers with consequent demand for clearance to W10 Gauge. It does recognise that the RUS identifies some routes where such clearance will or could be undertaken. It is suggested that before final publication of the document Network Rail does a re-check with the industry on the rate of introduction of this type of container and whether the routes it is proposed to gauge clear and customer aspirations fully take account of demand.
B. Clearance of diversionary route when the WCML is closed.
It is disappointing that within the timeframe of the RUS no provision has been made for the clearance of a diversionary route when the WCML is closed, this should be reconsidered.
C. Sufficient account taken of SFRIs (Strategic Rail freight Interchanges)
At present there are 12 SFRIs (information from Rail Freight Interchange Investment Group and "Intermodality") a further 10 are in various stages of construction, 14 proposals are in various stages of consultation or development and 12 potential sites have been identified. This number of interchanges is seen as meeting demand until 2030. On discounting say half of these proposals and all of the potential sites, a considerable number of SFRIs are left. Have the demands likely to be placed on the network by these facilities been fully taken account of? Has the increasing demand by customers for this type of facility been factored in?
D. "Green Credentials" as a Driver of Demand.
Since the document was compiled and published, environmental concerns have moved rapidly up the agenda and more major companies are addressing issues of Corporate Social Responsibility (CSR) and a number, particularly retailers, are giving greater consideration to use of rail to reduce their carbon footprint. Publication of the Stern Report is likely to increase rather than decrease demand to use rail, does the document fully take account of this?
E. "Shocks" (in the economic sense)
It is not suggested that the document should seek to forecast "shocks", if it could they would not be shocks however it is inevitable that unsuspected events will happen, factors will come into play between now and 2015 which could affect forecasts of rail freight growth. We suggest that it would be sensible for the document to have a section listing some of these possible events such as:
- Increases in access charges paid by freight operators possibly influencing traffic levels, if they alter the competitive balance between rail and road.
- Increasing concern with environmental matters could induce government to take action to put more freight on rail. It needs to be made clear that any such action should be staged and rational to allow the network to absorb these increases in traffic.
- Basically government needs to be warned not to do anything daft too quickly or, as the Latin has it "pro bono publico - no ruddy panico"!
2. Some Additional Comments.
There is considerable interest amongst road hauliers, particularly the larger operators, in making greater use of rail. As the rail freight industry is currently structured the FOCs - EWS, Freightliner, GB Railfreight, DRS, etc. find it difficult to be responsive to the urgent demands and flexibility which the haulage industry requires, because their customers demand it. Some of the 3PL companies such as the Malcolm Group, John G. Russell Transport, DHL etc do meet this requirement but only on highly specific routes.
If the FOCs can organise themselves to be more responsive and if the 3PL companies are prepared to expand their operations or new players experienced in load aggregation to utilise rail, e.g. Kombivehrkehr or Hukapak who operate very successfully in Europe decide to enter the UK market, this could lead to an upsurge in intermodal traffic both on existing routes and on new routes.
There is a feeling in both the shipping and rail industries that the RUS does not fully recognise the interests of many shippers in utilising rail for short-sea container movements from East Coast ports - Hull, Immingham, Teesport - to UK destinations such as the North West and Merseyside and of particular relevance to us - Scotland. There are issues of gauge to be resolved, yet there is strong interest which could result in whole new flows of traffic, so these should be considered.
Should Network Rail want to discuss further any of our comments, we would be pleased to assist.
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