Rail Freight Group
| Section | Closures |
ORR Procedures for Reviewing Closures
Response from Rail Freight Group
June 2006
1. ORR are consulting on their ratification role under the network
modification provisions of the Railways Act 2005. This is the RFG’s
response to that consultation.
2. RFG has already responded to the DfT consultation on this area and a
copy of our response is attached for information. A number of points
were raised relating to the approach set out by DfT.
3. We understand that ORR’s role is limited to one of ratification and that
it cannot alter a decision made under proper and due process. In that
context we have no particular comments on the process set out in the
consultation document.
4. However we wish to highlight three areas of the DfT document where
we would expect ORR to exercise particular care in assessing the work
undertaken. These are as follows;
5. Freight Appraisal DfT have indicated to us that, generally, they do not
have a role in freight appraisal. Whilst generally this is reasonable,
closures are one area where they might need to take freight impacts
into account. Our response to the DfT’s consultation set this out in
paragraphs 12-14, which in summary, suggest that there are a number
of areas where freight costs need to be included which are not stated in
the guidance as drafted.
6. In reviewing closure proposals we would therefore expect ORR to
check that freight elements of the appraisal had been properly and
thoroughly undertaken.
7. Freight Only Lines Since the ORR’s consultation on structure of access
charges indicates that the full costs of freight only lines will fall to freight
operators, closures which de facto create freight only lines by removing
passenger services should be given particular attention, considering
the overall impact on freight charges. (see paragraphs 8&9 of our
response to DfT). Whilst small individual cases are unlikely to have a
material effect, a programme of such closures could, and the overall
impact would need to be monitored.
8. Freight Consultation RFG and rail freight customers are listed as
optional consultees in the DfT guidance. We expect ORR to check that
where appropriate this consultation has been properly undertaken.
Doc # 242358.01
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