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The sustainability challenge for future development is stark: it should contribute to tackling the big global environmental issues we need to resolve by 2030.
Iberdrola’s stark article based on the UN’s 2030 Agenda for Sustainable Development (adopted in 2015!) has far reaching consequences for how we live, work and move our goods – with particular respect to:
• Climate change mitigation and adaptation;
• Pollution problems and their effect on health;
• The energy transition and renewables;
• Protecting biodiversity;
• Sustainable urban development and mobility;
• Hydric stress and water scarcity; and
• Overpopulation and waste management.
The European Environment Agency went even further, creating this beautiful diagram in expressing six clusters of challenges and opportunities for sustainability in Europe. The key themes though are similar to what the UN expressed however – Growing urbanisation and movement; increasing climate change; fewer natural resources; increased technological change. You can read more on this report here.
Fast forward seven years from that initial landmark UN report. The issues at hand are better known than at any point since 2015 – but it’s the lack of joined up, meaningful action that is now viewed as the key impediment to progress. The UN’s own environment programme described the outcome of COP26 as ending ‘with agreement but (falling) short on climate action’, with United Nations Secretary-General António Guterres stressing in his wrap up message to the conference that:
“Our fragile planet is hanging by a thread. We are still knocking on the door of climate catastrophe. It is time to go into emergency mode — or our chance of reaching net-zero will itself be zero.”
Immediate action is needed to reduce emissions. That in itself should be a huge feather in the cap for both the increased use of rail freight to move goods and for the development of an increased number of Strategic Rail Freight Interchanges (SRFIs) – large rail served distribution and warehouse parks linked into both rail and the strategic highway network. After all, as the UK Government itself has pointed out:
“Tonne for tonne, rail freight produces 70% less CO2 than road freight, up to fifteen times lower NOx emissions and nearly 90% lower PM10 emissions. It also has de-congestion benefits – depending on its load, each freight train can remove between 43 and 77 HGVs from the road.”
As of today however, JUST 20 are in operation or under construction in the UK – why?
The latest of our in-depth reports looks at SRFIs in detail. It considers how they’ve developed across the UK, the demand for new ones and the barriers stopping them being developed. It is particularly well-timed given the publication of the UK’s new Future of Freight plan and this report concludes by asking whether this will act as a help or hindrance in accelerating SRFI development.
Its findings will also be the subject of Bellona’s first ever podcast as part of its ‘BetterWorld’ series, with rail and development experts expanding on the key themes of this report. Keep your eyes peeled and your ears to the ground for it going live during week commencing 18th July…..
The purpose of an SRFI is to maximise efficiency and sustainability in how goods are moved from the point of supply to the point of demand. A typical SRFI has warehouses connected to rail lines and terminal facilities to handle freight containers – thereby reducing carbon emissions in the supply chain and the cost of movement, whilst also increasing the efficiency and speed of distribution.
The Government provides this definition of a SRFI:
“A Strategic Rail Freight Interchange (SRFI) is a large multi-purpose rail freight interchange and distribution centre linked into both the rail and trunk road system. It has rail-connected warehousing and container handling facilities and may also include manufacturing and processing activities.”
Taken from National Planning Statement for National Networks (NPS NN), 2014
Rail Freight Interchanges have been in place in the UK since the 1960s following the creation of Freightliner to facilitate domestic movement of freight in containers – an idea initially advocated by the much maligned Richard Beeching in the 1950s. SRFIs however received their catalyst from the advent of the Channel Tunnel opening, supporting intermodal services in Britain being divided into three streams; traffic to and from ports, Channel Tunnel traffic and domestic flows (of which much Anglo-Scottish traffic falls into the latter). Direct rail links to the continent suddenly brought the potential of more efficient (and cheaper!) movement of goods, and the likes of Trafford Park in Manchester sprung at a time when closer ties with mainland Europe were rather more encouraged.
Arguably the best known SRFI in the UK – the logistics powerhouse known as DIRFT (Daventry International Rail Freight Terminal) in Northamptonshire – opened in 1997, with a direct link to the West Coast Mainline. Its subsequent success for the likes of Eddie Stobart and Tesco has helped to drive a continued growth in the volume of intermodal traffic in the UK since 1998. Tesco runs at least 5 trains a day (with plans to double that) through the proximity and opportunity that DIRFT created – providing a positive outcome for rail freight without any cost to the public purse.
This in turn has driven the expansion of freight operators on the network itself. Since rail privatisation in the mid 1990s, Freightliner and EWS (now DB Cargo) have been joined by Direct Rail Services and GB Railfreight – as well as challenger third-party logistics operators including Maritime – in moving goods across the network. By 2017, rail freight was moving one in four of containers that entered the United Kingdom, carrying up to £30bn in goods annually.
All of this growth meant that rail freight contributes £2.45bn to the UK economy each year based on research completed by Deloitte on behalf of the Rail Delivery Group – roughly three times industry revenues. This estimate consists of:
• Over £1.65bn in benefits enjoyed by customers of rail freight; and
• Around £800m in benefits to wider society through removing 7m lorry journeys from the road network each year.
Crucially, Deloitte also forecast that rail freight is likely to play an even bigger part in the UK economy in the future, with:
• Key sectors including intermodal, construction, express goods and automotive projected to grow with more businesses interested in using rail freight in their logistics chains along with other modes such as road and waterways; and
• The UK’s withdrawal from the EU, meaning increased activity at UK ports with new trade arrangements and the need to relieve road congestion while maintaining links to inland conurbations.
Deloitte’s lofty view is shared by a number of other key commentators, all pointing towards a significant projected expansion in rail freight movements over the next decade. In this excellent article by Simon Walton at Rail Freight, both developers and Network Rail point to the UK urgently needing more rail-linked warehousing via the development of SRFIs. Of most importance:
• Rail freight is forecasted to grow by 30% over the next decade, as expressed by Peter Frost of Kilbride Holdings. This growth needs to be accommodated somewhere!
• Guy Bates, Head of Rail Freight Development at Network Rail, has also expressed that ‘intermodal’ freight movements is a key pillar of growth for the organisation. In a revealing quote, he stressed that:
“the important thing to note for SRFI and rail-connected warehousing is that they have a role to play for the other emerging sectors that we see in rail freight – express freight and high-speed parcels. You don’t get that sort of traffic to rail unless you’ve got somewhere to put it to rail. That’s a role that SRFIs can play.”
Whilst Deloitte’s findings and the views of industry are promising, we also believe this will cause a bottleneck: only some of this projected growth will be met by the existing 20 SRFIs in operation, in construction or currently within the planning system.
A full list of how things stand today, according to Network Rail (who retain responsibility for the operation of the ‘Strategic Freight Network’) can be found on the right-hand side.
The current cluster of operational SRFIs serve towns and cities close to the M1 and M40 extremely well. DIRFT in Northamptonshire and Hams Hall in Warwickshire clear a combined 24 full trains per day, whilst newer entrants East Midlands Gateway (Segro’s flagship SRFI in Leicestershire) and iPort (Verdion’s sole UK site in Doncaster) have increased their rail movements to accommodate the requirements of occupiers including Amazon. Some capacity remains but to a far lower extent than before the COVID lockdown of 2020.
So far so good. Let’s have another look at that Network Rail map in detail however and you could argue a significant geographical and operational disparity……
• Only one SRFI north of the Pennines actually exists – Mossend in Scotland, directly tied to the West Coast Mainline (soon to be joined by another SRFI across the main line).
• Let’s have a look at those SRFIs to the West or East of the M1. Correct, there are none! Road reliance post-Port remains the order of the day in the west country and across great swathes of the UK’s Eastern flank.
• It’s then worth looking at the status of SRFIs as things stand today. Some are only just beginning to emerge from the ground following convoluted planning journeys – the most obvious being Parkside Colliery in Newton-le-Willows, close to where I grew up. Others are being actively battled for, including Tritax’s proposed scheme at Hinckley which has recently been the subject of public consultation. These are a number of years away from operation subject to planning, local politics (more on that later) and the build process.
Our conclusion up to this point is therefore a simple one – there are hundreds of road-served distribution parks scattered around our motorway junctions and urban fringes, but only a handful of sites being SRFI with rail access. We need to build more SRFIs in the UK to handle trade to support decarbonisation and productivity gains, including accelerating the progress of those either in-build or subject to planning. But how straightforward is it for an SRFI to secure an elusive planning consent, given they are not common or garden developments?
SRFIs are recognised as ‘Nationally Significant Infrastructure Projects’ (NSIPs), a term introduced by the Planning Act (2008). This introduced a new consenting regime for major developments that was designed to speed up the decision-making process for major infrastructure and to give developers, consultees, stakeholders and the public certainty that a decision would be taken within a set statutory time period.
The process – explained by the Planning Inspectorate here – brings forward consultation and design processes and acts as a ‘one-stop shop’ allowing a number of powers and other consents, including compulsory purchase powers, to be included within the final consent. SRFIs that are larger than 60 hectares and capable of receiving at least four freight trains per day have the option to pursue a Development Control Order (DCO) to secure consent.
Ultimately it is therefore on Government, via the Secretary of State for Transport (SoS), to determine whether a proposed SRFI should receive planning. This means any SRFI developer following the National Policy Statements (NPS) in the decision-making process – statements approved by Parliament and forming the policy basis and justification for all consenting NSIPs.
The National Networks NPS (designated in January 2015) provides the policy framework for not only SRFIs, but also development of the strategic road network and the national rail network. The NPS recognises that there is a “compelling need for an expanded network of SRFIs” which means this aspect does not have to be made for individual sites. Critically, the NPS does not identify specific sites or suggest how a network of regional, sub-regional or cross-regional SRFIs is to come forward; this is up to the private sector to determine. This suggests, in theory at least, that providing the economics of a scheme works for the developer and they can meet planning requirements, a planned SRFI will be supported.
Despite this supportive background, very few DCO applications for SRFIs have been submitted to, and consented by, the secretary of state for transport (SoS) in recent years. DIRFT III and East Midlands Gateway were consented by Patrick McLoughlin in the middle of the previous decade, with the latter granted by the SoS against the recommendation of the Examining Authority! Even slower progress has been made since then. Since 2016:
• The Secretary of State has only granted one DCO – for Roxhill’s Northampton Gateway scheme – at the end of 2019.
• A nearby scheme – Rail Central Northamptonshire – has fared less well however. The JV with responsibility for it – owned by Ashfield Land and GLP – withdrew their DCO application in 2019, prior to the entire scheme being placed on hold a year later.
• Other schemes aren’t even getting this stage yet! After a fractious planning battle, Parkside Colliery’s DCO is planned to be submitted in 2023. Segro’s long-running saga at Radlett in Hertfordshire, lasting well over a decade in an era before the NPS or DCOs (see here for a clear recap of how it’s ended up in this position) rumbles on, despite frequent vocal local opposition.
Three new schemes in 14 years does not sound like strong progress, particularly when you think how many road-served distribution parks have been built over the same period – putting yet more occupiers beyond the reach of direct rail access. This points to a ‘missing middle’ between the thrust of the NPS and the eventual schemes that need to satisfy the demands of local stakeholders and the DCO process. As that wise sage Simon Ricketts from Town Legal LLP pointed out back in 2017:
Why don’t we bite the bullet and arrive at more spatially specific policies in the National Networks NPS rather than leave it for promoters to read between the lines as to what the Government’s approach may end up being to particular proposals – particularly given the inevitably sensitive locations involved, often in the green belt?
It is hard to argue against this position. Rather than accelerate the adoption of SRFIs, the Government’s present policy position is undoubtedly both lengthening and increasing the cost of securing consents, resulting in only those in real estate with deep pockets, strong stomachs and some form of foresight being left to get new SRFIs built.
It would be wrong however to solely lay blame at the NSIP process, which – with spatial reform, as suggested by the aforementioned Mr Ricketts – could deliver the stable process needed to govern the acceleration of SRFI development. We believe there are two other key factors at play that are acting as key impediments.
POLITICAL POSTURING – AGAIN
The first, sadly, is a recurring theme amongst recent Bellona reports – the politicisation of issues to curry favours with voters rather than to help future-proof the UK.
In this case, it’s national and local politicians turning against SRFIs – usually on green belt or ‘transport’ concerns – within constituencies with marginal seats or areas in the midst of local plan review processes. Every one of them should be ashamed given the often appalling quality of their arguments.
To illustrate the point, let’s look at a recent House of Commons debate on the proposed Hinckley National Rail Freight Interchange proposed by Tritax. Here’s local MP Albert Costa with a sadly familiar dose of invective:
The planned site for the Hinckley rail hub would, in its totality, encompass 440 acres of land—for scale, that is about a quarter of the size of Gatwick airport. That area is currently beautiful, rolling south Leicestershire countryside. The site will neighbour the historic and picturesque county villages of Elmesthorpe, Stoney Stanton, Sapcote, Sharnford, Aston Flamville, Potters Marston, Croft, Huncote, Thurlaston and Wigston Parva—collectively and colloquially referred to as the Fosse villages.
My constituents in the Fosse villages contend with overburdened infrastructure at the best of times. There are already heavily congested roads in the area, many of which are narrow and winding and therefore quite unsuited to the levels of traffic that would be seen should this awful proposal be approved, given the HGV traffic entering the site and the alleged approximately 8,000 employees who would be trying to enter it for work.
‘A quarter the size of Gatwick Airport’, an ‘Awful proposal’, the ‘alleged approximately 8,000 employees’ – there’s nothing like playing to the gallery or wilfully ignoring balance. Bear in mind that this is an area that’s home to road-based warehousing, a Calor gas tank farm, and has a major motorway running through it. This was further compounded by the response from former Cabinet Member Andrea Leadsom, who brought her previous opposition to Northampton Gateway to the boil:
My hon. Friend will be aware, because we have discussed this before, that a strategic rail freight interchange is under construction in my constituency of South Northamptonshire. Just as he has outlined, however, it covers an enormous area, including a greenfield site, and it borders beautiful villages and residential areas. In fact, now that it is starting to be built, it turns out that Network Rail cannot find the promised rail links that were part of the plan*, and my constituents are saying to me, “We told you so. We said it would never be a rail freight interchange; it is just about yet more logistics warehousing.” I am grateful to my hon. Friend for allowing me to put that on the record, and I encourage him to fight against this until there is a proper national framework in place that can stop this type of development-led abuse of local communities.
(* Bear in mind that Network Rail is working with SEGRO to deliver the very same rail links into the site, being an essential pre-requisite of the DCO that her colleague the Secretary of State for Transport signed off on.)
….and so the endless trite criticism continued in Parliament: no answers here guv, only problem stating. All of this posturing simply does two things: it winds up local residents and businesses without consideration of all of the facts of individual developments; and it makes local planning significantly more difficult. Neither does anything for the quality of public debate nor in properly grappling with the issue at hand – generating more sustainable development in the right places.
To give credit to Wendy Morton MP as Minister of State for Transport in her response, she reiterated the Government’s long-standing support for SRFIs – stating that it was necessary to “recognise the important benefits that rail freight offers to the UK. It plays an important role in helping the Government to meet our greenhouse gas legislative targets, as it is one of the most carbon-efficient ways of moving goods over long distances.” She also emphasised the following:
I take this opportunity to highlight the drivers of the need for strategic rail freight interchanges, which can all be linked to the broader objective for rail freight. The right infrastructure needs to be in place to support our ambition of achieving growth and the benefits that I mentioned. Although rail freight makes up only 9% of the total goods moved in the UK, it is nevertheless an important part of building resilient supply chains. It is, therefore, a Government priority to support the sector in its endeavours to help us to get critical goods, such as medicines or supermarket supplies, to where they need to go.
Whilst it was excellent to hear the Government’s clear rationale for backing SRFIs in recent weeks, it rather emphasised the need for it to give further spatial direction to accelerate them being delivered – exactly as Simon Ricketts suggested some five years ago.
LAND VALUES AND THE TOO DIFFICULT PILE
The second issue is out of Government hands however – and boils down to straightforward economics.
To make an SRFI work profitably as Prologis have done at DIRFT requires five key elements: enough serviced land and infrastructure to ‘mix modes’ effectively; a planning consent that can be efficiently implemented; enough rail and road capacity to effectively move goods; an experienced operator to run the rail terminal; and enough market demand to make the most of an SRFIs bi-modal status. This in turn can only be unlocked once that weighty DCO process has been navigated by the developer.
Committing to an SRFI takes foresight, patience and resolve. Whilst demand for rail is strong and there is no shortage of quality rail freight operators in the UK, it is a far easier sell for commercial developers with land close to motorway/principal road junctions and rail connections to simply promote road-based development through the local planning process rather than committing to the DCO process.
This is particularly relevant in 2022 given the underlying strength (read: the rising value) of serviced, consented commercial development land. The move from physical retail to e-tail, the unblocking of consumer spending post-pandemic and a paucity of new development land and space have all contributed to the rising cost of land and rising costs of rents for logistics-related occupiers. There is also little incentive on National Highways or Network Rail to make the process of plugging sites into the network any less expensive or protracted.
This creates a headache for potential SRFI developers. Why should they upgrade, reinstate or create a rail connection and follow a lengthy, expensive DCO process to secure consent when industrial values for ‘standard development’ are going through the roof and any planning application would be locally determined? Those questions will ultimately be answered by the owners of those developers, based on how their sites are perceived (both by the market and in planning terms) and where that business is at that moment in time.
Can anything be done to stop any ‘potential’ sites being lost? There are two potential interventions in our view. The first is some form of SRFI accelerator fund at national level with the proviso that all spending must be linked to the operation of rail-based development; the second would be to strengthen planning guidance under the NNNPS (as Simon Ricketts suggested) to make the DCO process easier and less convoluted. Someone in Government has already been thinking about the latter……
The timing of this report is rather fortuitous, as the Government has recently published its Future of Freight Plan – described as ‘the first ever cross-modal and cross-government plan for the UK freight transport sector’. Created as a response to the National Infrastructure Commission’s 2019 report ‘Better delivery: a challenge for freight’, it has identified the main challenges, objectives and actions in five priority areas:
• National Freight Network (NFN);
• enabling the transition of net zero;
• people and skills; and
• data and technology.
Given SRFIs touch upon each of these five priority areas, both the role of SRFIs and the future of rail freight are considered within the plan. What is immediately clear from the plan however is that it is fairly limited in its scope, focusing on planning and procedural reform and as a request for further industry input rather than laying out immediate changes or providing further fiscal stimuli to encourage SRFIs to come forward. In this respect, it is a missed opportunity.
It does however provide a first pass at tackling some of the existing issues within the NNNPS/NSIP process, which if properly implemented could accelerate SRFI development. This, according to the written ministerial statement within the plan from the Department for Transport (DfT) and transport minister Trudy Harrison, says that the government wants “a planning system which fully recognises the needs of the freight and logistics sector and empowers the relevant planning authority to plan for those needs”.
Some of those key points are as follows:
• National Policy Statements: Through the current review of the National Networks National Policy Statement (NNNPS) – which government aims to complete by Spring 2023 – the government will consider the growing importance of major freight schemes to the economy, ‘particularly the increasingly important role of strategic rail freight interchanges (SRFIs) and the interdependencies between different transport hubs along the supply chain.’ This should be welcomed provided the Government actively listens to the experience of those actively involved in bringing forward schemes within the confines of the current process. Separately, the DfT says it also plans to consult on and publish an updated DfT Circular 02/2013 on The Strategic Road Network and the Delivery of Sustainable Development later in 2022.
• The plan includes a call for evidence, expressing the hope that “this will help us build a comprehensive picture of where the planning system can appropriately support the freight and logistics sector”. It’s a slight concern that the Government wants to do this – given two of its agencies, Highways England and Network Rail, have responsibility for the maintenance of the very systems that keep the freight and logistics sector going – but if it leads to sustained engagement with those actively developing SRFIs then it can only be a good thing.
• A programme of engagement with councils is promised by the statement, aiming to provide planning officers with an understanding of the benefits of freight infrastructure, as well as the environmental impacts, and to provide specialist training and look at how to strengthen their capacity. It is also asking for views on how the planning system could promote development of more edge-of-town centre warehouses to which goods can be delivered for onward distribution by sustainable transport methods.
We cautiously welcome this proposal, subject to the method that the Government use to undertake this exercise. It however misses a major local stakeholder in its proposal – planning committee members and Councillors local to planned SRFI development, who are often unaware (or worse) of the wider strategic implications of what they’re being asked to consider.
Mark Sitch, planning director at consultancy Barton Willmore, now Stantec, summed up the Plan’s contents and gaps extremely well through the following two paragraphs:
“We welcome the statement, which is recognition of the important role of the national infrastructure and freight.
“We now need clear evidence of rule changes which would make it easier to build new sites – because there is a real shortage of the right size in the right location. There is also a need for a proactive approach to finding locations through local plans. We hope a new approach could lead to enough sites in the right locations – and quicker than currently.”
Bellona Advisors will be responding to the key parts of the Plan’s consultation to help accelerate SRFI development: get in touch if you’d like us to formally respond on your organisation’s behalf.
The development of SRFIs cover multiple areas of discipline and we recommend experts in four particular fields for more detailed information in what is a very knotty subject.
On anything rail-related, I always recommend Nick Gallop from Intermodality (heavily involved in bringing a number of SRFI schemes forward over the past twenty years) for specific freight issues and Gareth Dennis (rail engineer and journalist) on anything to do with the network.
On planning law, the aforementioned Simon Ricketts has just been voted the #1 planning solicitor in the UK and I would struggle to recommend anyone else for clarity of thought. He also hosts an excellent Clubhouse podcast and you can read his regular views on all things planning here.
On promoting rail schemes through the planning system (including to secure DCO), a number of the major planning agencies do this well – particularly Turley and Barton Willmore, now Stantec. Other wise sages on NSIP-related matters include my old mucker Nick Lee from NJL Consulting – get in touch with Nick and his team here – and Ormskirk’s finest Dave Rolinson at Spawforths (see here).
Finally, on transport infrastructure I’d be hard pressed to recommend anyone other than David Cummins at ADC Infrastructure, whose probably the most sensible Civil Engineer I’ve worked with. You can get hold of Dave here.
Get in touch to discuss your projects further:
07599 916 firstname.lastname@example.org