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Charlestown, Limekilns and Pattiesmuir Community Council Response to

“Rail Freight Access” In the Community Council’s response to the HRO application, we wrote as follows concerning the option to use rail freight - a significant plank in the promotion of the proposed terminal as multi-modal: ‘Claims that the container terminal may offer comparative advantage over other ports in terms of multi-modal transport linkages are misleading and factually incorrect. Multi-modal refers to rail freight. Our very serious doubts as to whether rail freight was ever a realistic option are now clearly confirmed by the Environmental Assessment and Traffic Assessment. There is a single track railway line that runs from Inverkeithing station. However, as the connection at Inverkeithing is north facing, any freight trains accessing the proposed terminal from the south would somehow have to change direction north of Inverkeithing. Furthermore the number and frequency of passenger trains passing through Inverkeithing station would severely limit access to and from the Rosyth branch by freight trains. It is now clear that a suggested realignment of the Charlestown junction to provide a south-facing junction will not be realised in the foreseeable future. Furthermore, freight capacity over the Forth Rail Bridge is severely limited by the frequency of passenger trains, so onward southerly movement of freight trains would be severely limited, even if they could be turned round to face in the right direction. The inadequacy of the rail connection with the Dockyard and proposed terminal is further emphasised in Section 8 of the Transport Assessment and 13.4.7 of the ES where it states: a) That the low radius curve under the A90 ultimately limits the speed that can be achieved. b) The existing structures along the route as well as the track itself may ultimately need to be replaced. c) Loading gauge constraints may require infrastructure enhancements to permit containers to be carried. It is patently misleading to suggest that the proposed freight terminal would be multimodal. Furthermore, it is a generally recognised that for transport of containers by rail to be viable, there needs to be a long haul distance and, generally, a manufacturer or consumer of freight goods which requires delivery/collection of multiple numbers of containers at any one time. Rail freight is not sufficiently responsive to the requirements of individual containers’ Further detail and information now provided in the additional Rail Freight Access document prepared by Jacobs and published in May 2011 does nothing to refute our arguments. Indeed it confirms all that we have written and more. As most of the document rehearses and reiterates factual information, we will comment only on the second paragraph in the introduction and on Section 2 ‘Conclusions’. The second paragraph of the introduction states: ‘Transport of containers by rail is desirable …. However this is not something which can happen immediately at the start of the life of the RICT project, but will take time to develop as markets are identified and infrastructure improvements are implemented over time.’ Comments: 1. This statement clearly implies that markets have yet to be identified. The Community Council’s carefully researched and demonstrated view is that there is no identified market for any output from this proposed container facility. 2. Transport by rail requires that a significant number of containers need to go at the same time to or from the same place. Scotland just does not have, nor is it ever likely to have, the population or the economic activity to imply any need for such bulk movement of containers. 3. Rail freight is only economic over relatively long distances of 200 miles or more. Most of the journeys made by containers in Scotland are within the central belt, where most distances are nearer 50 miles than 200. 4. Transport Scotland have made it very clear that improvements to rail infrastructure as are suggested later in this document will not be funded by the Government.

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5. On page 4, it states that, ‘in early 2010, the cost of infrastructure improvements involving a Charlestown chord was estimated at £65m’. When this is added to the considerable costs involved in upgrading the rail access from the proposed terminal to Inverkeithing, the scale of investment would require more money from the public purse than Babcock have said they will invest in the terminal itself! Babcock has repeatedly stated that no public money will be required for this project.

Comment upon the various conclusions of this document: ‘Babcock has by its actions demonstrated its commitment to rail freight by seeking to protect the future of the line.’ This is about the limit of what Babcock has done and can do. ‘The creation of the RICT has the potential to act as a catalyst for other infrastructural improvements such as the construction of the Charlestown Chord.’ No it won’t because there is no chance that there will ever be enough business for rail freight to be an option. ‘If the granting of the Harbour Revision Order to authorise the RICT project (HRO) were to be dependent upon the achievement of certain rail movements for the Development then this would severely undermine the attraction of the terminal for investment and prejudice the viability of the project.’ As we have argued. ‘The Carbon Balance study accompanying the HRO application concluded that there will be a net reduction in carbon emissions associated with the project. The provision of additional container freight capacity as envisaged by NPF2 will promote modal shift by increasing the transport of containers to and from Scotland by sea rather than by other modes. Overall this will result in a reduction in HGV road miles that would not occur if the Development were not to proceed.’ This oft repeated argument by Babcock has no substance. Their blinkers prevent them from understanding what goes on at the existing and efficient container terminal 10 miles away. Any capacity for transfer of container traffic to and from Scotland by sea will already have been absorbed by Grangemouth. ‘It is hoped that, as the Development reaches its proposed capacity, investment within the rail network will have taken place to allow some transfer of containers from road to rail.’ Hope springs eternal. ‘In that regard, Network Rail has indicated that the existing track and structures on the network will require to be assessed and a major programme of enhancements implemented.’ Yes, as we have all said. ‘It is considered that these are appropriate matters for Network Rail and Transport Scotland to address. Babcock will continue to seek to safeguard and promote the Rosyth Branch line and to engage with other stakeholders to facilitate movement of freight to and from the Port by rail as appropriate opportunities are identified.’ ‘Multimodal’ indeed!

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Rail Freight Access response