Government policy relating to SRFIs is laid down in the National Policy Statement for National Networks (NPSNN) and states four overriding principles: a) Reduce road congestion; b) Reduce carbon emissions; c) Support long term development of efficient rail freight distribution; and d) Support growth and create employment.
The Government believe that by developing a network of strategically placed rail freight interchanges across the regions, linked by good road and rail connections, it will enable the main part of a freight journey to be undertaken by rail and the final (short) leg to be completed by road, thus reducing the number of miles travelled by HGVs and the consequent carbon emissions. This, in essence, is the fundamental objective of the SRFI policy.
Necessarily, therefore, SRFIs need to be close to major markets otherwise the policy fails. If an excessive number are all clustered in a small area, away from the major urban centres, the final length of the freight transit by road to the market inevitably increases and any carbon savings and reduction in mileage are negated as the lorries travel further to reach their final destinations. Large SRFIs need to be spread out and work together as part of a national network. As is clearly evidenced by the actions of two speculative developers (Ashfield Land and Roxhill), the strategic positioning of such major pieces of infrastructure cannot be left to the private sector.
Unfortunately the policy governing SRFIs is silent on where they should be located; the only relevant (and slightly vague) guidance in the policy being that: SRFIs should be located across the regions; that a small number of large new interchanges will be required; and that it is important that they are located near the business markets they will serve – major urban centres, or groups of centres (and industry). It also stipulates that the existence of an available and economic local workforce is an important consideration.
The most definitive guidance on where SRFIs should be located is found in the Strategic Rail Authority study published in 2001 which sought to establish how many might be required and where they should be located. The report concluded that London required three or four and that the second most densely populated area in the UK, the West Midlands, required two. Northern regions were deemed to be adequately served and other regions were forecast to require new or enhanced interchange capacity to a greater or lesser extent as the rail freight market developed (not necessarily the very large SRFIs that we are now faced with). DIRFT now provides more than adequate (large scale) capacity for the East Midlands.
As well as the network requiring appropriately placed and sized nodes there is also a need for effective transport links. Locating three very large SRFIs on the same 18 mile stretch of the busiest section of the M1 and on the same stretch of the busiest train line in Europe is the very antithesis of an effective transport strategy.
The bringing forward of SRFIs is being left to the private sector and acceptability is being judged on environmental factors rather than whether the chosen location is sound within the context of a national strategy and an effective distribution network. In addition there are serious questions over viability with three large SRFIs competing, at the same time, for a share of the same (limited) rail freight market in a less than ideal location.
Who is policing the strategic aspect of this National Strategic Policy?
Whilst the NPSNN is clear that the policy goal is a ‘strategic network’ which means all facets (nodes and connections) have to function effectively as a whole, the body charged with judging the applications, the Planning Inspectorate, appear set on judging each on its relative merits. This may result in a situation whereby the first of the five SRFIs currently at the pre-application stage in the Midlands is approved, potentially not in an ideal location, in preference to a more suitably located proposal. The location of a poorly placed node in a network would then displace others around it resulting in an even less effective network. Central Government appear unwilling to change, police or monitor this policy.
Private sector opportunism will result in SRFIs being located in the wrong places and an inefficient rail freight network emerging. Road congestion will increase and be concentrated on some of the busiest stretches of the strategic (road and rail) network. Carbon emissions will increase as the final leg of the journey by road is increased (possibly back as far as the ports in some cases) and any potential marginal benefits will be completely negated by the distance the remote workforce has to travel to work on the already congested roads. Massive growth of the logistics sector in a county already dominated by it is not desirable and employment opportunities will only be for those living outside of the area given the proven absence of an available workforce.
What needs to be done?
The Planning Inspectorate need to be directed to consider all the current planning applications in the Midlands collectively, from a strategic perspective, not to judge each individually on the significance of its environmental impact. Government need to provide more detailed strategic oversight, governance and guidance based on an up to date and credible market study.