Memorandum by The Royal Town Planning
Institute (IT 102)
INTEGRATED TRANSPORT WHITE PAPER
1. One of the Government's key commitments in
its Manifesto was to develop an integrated transport policy. In
aspiring to objectives of a strong economy, a sustainable environment
and an inclusive society, the Government is committed to facilitating
the mobility of the British people in an economically and environmentally
sustainable framework. To achieve these goals, an effective and
integrated transport policy is required, at national, regional,
and local levels, to provide genuine choice in meeting transport
needs, and to provide an answer to problems of congestion and
2. This is the context in which the White Paper
"A New Deal for Transport: Better for Everyone"
(Cm 3950), published in July 1998 (along with its sister documents
"Travel Choices for Scotland" (Cm 4010) and "Transporting
Wales into the Future" sets out the Government's policies.
The agenda is a challenging one.
3. The Institute called for such an approach
in its Transport Policy Statement of October 1994. That
statement was expanded in a comprehensive response, in October
1995, to the then Government's consultation paper "Transport:
the Way Forward", published in July 1996.
4. The Institute is pleased to offer this memorandum
of evidence to the Committee's inquiry. Following this introduction,
a section headed "General Comments" describes some broad
reservations which the Institute has about the content of the
White Paper and its implementation. The "Detailed Comments"
which follow that attempt to measure the White Paper's proposals
against the core objectives which the Institute set for an integrated
transport policy in its response of November 1997 to the Government's
invitation to contribute to "Developing an integrated
transport policy". A separate summary of the Institute's
evidence is attached.
5. The Institute in its initial press reactions
warmly welcomed publication of the eagerly awaited White Paper,
but two months later has to admit to some disappointment with
6. The White Paper gives very broad coveragefrom
airports policy to combatting car crime; from a strategic rail
authority to a safer journey to school. Such a comprehensive position
statement has value in itself. The White Paper also includes worthy
proposals such as national integrated journey timetables and concessionary
fares for pensioners. But these alone will not solve the problems
that confront us.
7. In some ways, the White Paper is a disappointingly
timid document. The Institute suspects that the Deputy Prime Minister's
reference, in his Foreword, to "persuading people
to use their cars a little lessand public transport a little
more" falls far short of the required changes in attitude
and travel behaviour if we are even to begin to tackle the problem.
A major cultural change has to be engineereda change in
public attitudes probably greater than that achieved in relation
to drink-driving, or smokingwhich may take 20-30 years.
This will be a long haul, but the journey has to be taken! The
planning profession is not unfamiliar with the political difficulties
that this might pose, but the problem is so big that the bullet
has to be bitten, and the White Paper stops short of doing that.
Does the Government assume that the public is not yet ready for
a change in lifestyle?
8. There is an inherent difficultywe
must start from where we are today. If more positive restraint
on car usage, or even modest compulsion, were acceptable, these
could not be put into effect without substantial increases in
the capacity and extent of alternative modes of travel. To attempt
to do so would result in economic and social ruin. The White Paper's
approach is to seek these improvements, primarily in public transport,
from income derived from the motorist, who then is to be won over
to the alternative modes he had funded. There is no guaranteed
9. Right at the beginning of the White Paper
(paragraph 1.2), a distinction is made between car ownership
and car usage"we do not want to restrict car ownership
. . . but the way we are using our cars has a pricefor
our health, for the economy and for the environment".
Perhaps, the White Paper could have capitalised more on this distinction.
It demonstrates that the Government does not wish to attack personal
liberty to the extent of restricting car ownership, but that it
is in everyone's interest to be much more selective about when
we use our cars. Efforts can then be concentrated on providing
comfortable, clean and efficient public transport for those journeys
that people choose not to make by car. This might have been used
as a marketing base to promote a much more aggressive car restraint
line, or at least to signal that this might be necessary in the
10. Even before this, however, a fundamental
requirement of a more sustainable future is a reduction in the
overall need to travel. Here, in policy terms, the White Paper
is practicably silent.
Land use and transport planning
11. One of the overall objectives of an integrated
transport policy is to make both development and transport itself
more sustainable, involving a reduction in both journey lengths
and frequencies. Without land use, there would be no need for
transport. It is the subtle variations in arrangements of land
use, and the intensity of activity, overlain by social and economic
factors, that determine the overall need for the transport of
people and goods. To ensure that future development is sustainable,
it follows that the availability of robust machinery to achieve
proper integration of land use and transport planning, at all
levels from national to local, is a vital pre-requisite of an
integrated transport policy.
12. The reality is that much of the right material
is included in the White Paper, but it has to be teased out, and
does not appear as an underlying theme. The Institute's concern,
notwithstanding the definition of "integrated transport
policy" in paragraph 1.22, which includes "integration
with land use planning", is that the importance of the
relationship between transport and land use is not given much
more explicit recognition and stated "up front"
as a starting point from which other policies flow.
13. Much of the practical detail of how the
White Paper's policies are to be implemented remains to be worked
out. Annex A lists the "daughter documents"
which form key parts of the implementation mechanisms. Until these,
often complex, arrangements have been finalised, the White Paper
is more an "act of faith" than a policy document.
14. The White Paper introduces regional transport
strategies and local transport plans. The Institute has a particular
interest in how these will interlock with each other, and with
the development plan system. This is discussed further in paragraphs
15. Many of the White Paper's proposals can
be implemented without the need for legislation, once procedural
matters have been worked out, and guidance issued. But there are
central proposals, vital for the success of an integrated policy,
which do require legislation:
(a) the strategic direction of investment
in rail infrastructure, and an even-handed approach to both passenger
and freight-related investment, require the establishment of the
Strategic Rail Authority (paragraph 4.12); and
(b) the income from road charging (paragraph
4.94), and from private, non-residential parking ([paragraph
4.107) is essential if local authorities are to have the funding
available to make the step changes in the quality of public transport
infrastructure and services that will be required to provide attractive
alternatives to the private car. Without these income streams,
it will be impossible to influence significantly changes in modal
16. The Foreword states "This
White Paper reflects the Government's commitment to giving transport
the highest possible priority". Recent media reports
have been cast in such a way as to raise doubts about the real
level of commitment. The Institute does not wish to overplay thisthe
legislation will require considerable prior consultation, and
it will be some time, in any event, before it can appear on the
statute bookbut stresses the importance of not losing sight
of it, and progressing with all reasonable speed.
17. In responding to the invitation from the
Department of the Environment, Transport and the Regions to contribute
to "Developing an integrated transport policy",
in November 1997, the Institute listed seven broad objectives
to be addressed by an integrated transport policy:
to reduce the need to travel;
to reduce reliance on the private
to enhance public transport;
to establish efficient but more environmentally
friendly ways of moving freight;
to provide a more attractive environment
for walking and cycling;
to ensure a rural dimension in integrated
The following paragraphs attempt to measure
the extent to which the White Paper's proposals achieve the objectives
formerly set down for it by the Institute.
To reduce the need to travel
18. The Institute believes that reducing the
overall need to travelproviding a framework in which people
have realistic choices of travelling less frequently, or over
shorter distancesmust be a central thrust of policy to
achieve a more sustainable future. This is not recognised by the
White Paper, which makes only passing references, such as at paragraph
4.158 or paragraph 5.26, each of which is in a limited
19. This is linked very closely with the White
Paper's failure to recognise the central importance of integrating
land use and transport planning, as a means of providing the key
choices for people on their travel behaviour (see paragraphs 11-12,
above). The arrangement of land uses, and the transport links
between them, are the determinants of people's choices of home
and job location, and on the transport mode they use between them.
This pattern of interrelationships and the choices it offers must
cascade from regional strategy down to local plan.
20. The White Paper tends to say all the right
things, but in piecemeal fashion rather than as a central thrust
of policy. Thus while it does describe the role of regional planning
guidance and the future requirement for this to incorporate a
regional transport strategy (in paragraphs 4.50-4.57),
this appears to be without realising that it is saying "integrate
land use and transport planning at the regional level". Similarly,
paragraphs 4.73-4.77 give an outline of the intended role
for local transport plans (LTPs), while paragraphs 4.156-4.170
cover planning policy guidance and development plans. It is all
there, but in a less than coherent framework.
21. Until the consultation drafts of PPG 11
on the new approach to regional planning, the revised PPG 12 on
producing better development plans, and the guidance on preparation
of LTPs are available, it remains unclear how regional transport
strategies, regional planning guidance, local transport plans,
and development plans will interact. The draft National Planning
Policy Guidance (NPPG) has been published in Scotland. This reflects
many of the principles of the White Paper, but lacks any strategic
approach to location policy.
22. The Institute's concern is that the Government
may have produced an almost insoluble conundrum of overlap, duplication,
delay, and mismatching timescales and plan periods, which is exacerbated
by the expectation that local authorities will have their LTPs
in place as soon as April 1999, replacing the present Transport
Policies and Programmes (TPPs) as the vehicle for their transport
23. The Institute is also concerned that local
authorities might not have the necessary skills nor the staff
resources to prepare regional transport strategies and local transport
plans. the White Paper appears oblivious to the additional workload,
particularly for local authorities, which arises from its proposals.
Paragraph 4.53 lists the material to be included in regional
transport strategies. Some of these reflect new responsibilities
for local planning authorities. In particular, "public
transport accessibility criteria" is a new area of work
on which detailed guidance on methodology will be required.
24. Implicit in the proposals is a requirement
for the next round of development plans to include many more,
often necessarily detailed, policies and proposals on transport,
and especially on public transport. Hitherto, these have been
considered to be outside the remit of the plans, and there are
clear implications for timescales of plan preparation and numbers
of objections received. Both these issues have been exercising
the Department's, and the profession's, mind in recent time. The
Institute has written to the Department about these concerns.
To reduce reliance on the private car
25. Projected growth in car usage currently
stands at billions of additional vehicle-kilometres annually.
This will not go away. Stern measures are required even to contain
the rate of growth (see paragraphs 8-10, above). Vital though
it must be to enhance public transport, in all the ways the White
Paper suggests, to provide an efficient, attractive and viable
alternative to the private car, this alone seems unlikely to be
sufficient to get people out of their cars. In the longer term,
it seems inevitable that more positive restraint, or even modest
levels of compulsionthe "sticks"will be
required alongside the White Paper's "carrots".
26. The Institute is not critical of the White
Paper's abundance of proposals for the enhancement of public transport
and for making walking and cycling more attractivequite
the reverse. These are an essential part of the equation, which
will raise the competitive edge of alternative modes in the battle
for hearts and minds. But they are unlikely to be sufficient in
27. For the same reasons, in principle, the
Institute supports the proposals to introduce charges for road
use in urban areas (paragraph 4.94), on a seasonal basis
in more congested rural areas (paragraph 4.97), and the
possible more widespread extension to inter-urban roads paragraph
4.100). Road user charging, in increasing the cost of motoring,
helps level the playing field with public transport. Vitally,
as proposed in the White Paper, it also will provide a new income
stream for local authorities to apply to public transport enhancements.
28. However, road user charging is not without
(a) if charges are set at a low level, they
deliver little restraint in car usage. If they are more penal,
they disadvantage the less well-off, whose journeys may be just
as vital as those by people who can well afford to pay;
(b) if, as the White Paper implies, local
authorities have the discretion to determine when, where and if
charging should be applied, within their areas, its impact will
be uneven and inconsistent. Paragraph 4.53 suggests that
regional planning guidance might provide guidance to local authorities
on the strategic context for introducing charging, but experience
of the implementation of PPG13 over the past five years has shown
that local authorities can become pre-occupied with maintaining
their own position against competing centres. They are likely
to be reluctant to introduce charges unless their perceived competitors
(c) the revenue raised must be made available
for public transport improvements, if only to address equity concerns
about meeting the travel needs of people priced out of their cars.
For the same reasons, the revenue must be "ring-fenced"to
be used only for transport schemesrather than becoming
part of the local authority's general funding.
These considerations could lead to road user
charging being compromised as a restraint mechanism.
29. Similar considerations apply to the proposal
to enable local authorities to levy a charge on workplace parking
(paragraph 4.107). This again will provide essential additional
funding for public transport improvements, but is also a two-edged
(a) local authorities will not apply charges
evenly and consistently if they are seen as an influence on their
ability to attract employment;
(b) employers have an interest in getting
their employees to work, but will behave differently in deciding
whether to pass car park charges on to the employee, or the customer,
creating differential impacts.
30. From initial comments, it seems probable
that the workplace parking levy is likely to be more widely taken
up than road user charging. It is important that the details are
right. The Institute is disappointed that the proposal is restricted
to workplace parking, and does not extend to all private, non-residential
car parking, where it could be a much firmer instrument of planning
31. The fiscal linkage of workplace car parking
charges and green commuter plans (paragraph 5.20) might
be more productive in reducing car commuting.
32. Digressing strictly from the White Paper,
but relevant to the issue of car restraint, the message in "A
New Deal for Trunk in England": and "Driving
Wales Forward: A Strategic Review of the Welsh Trunk Roads Programme"
the outcomes of the reviews for England and Wales respectively
(and, to some extent, in the current consultation on a "Strategic
Review of the Trunk Road Programme in Scotland"), published
shortly after the Transport White Paper, offers little comfort
to those who believed the Government was switching substantial
investment away from new roads to other transport projects.
33. The White Paper claims the end of "predict
and provide", and yet the review protects a surprising proportion
of the road schemes that were inherited in a programme drawn up
on that basis. Analysis of the review has shown that of 156 inherited
schemes: 65 will proceed over the next seven years; 44 fall to
be reviewed by the regional planning conferences, and so may yet
reappear; 19 will pass into local authority "ownership"
through the de-trunking process, and so, again, may survive; a
final decision is yet to be made on seven more; with the result
that only 21 schemes have actually been withdrawn from the programme.
To enhance public transport
34. Public transport has a central role in the
quest to reduce car usage. The White Paper's approach is clearly
that improvement in the overall user-friendliness of public transportin
its efficiency and effectiveness, the full integration of modes
to provide the "seamless journey", and in the
extension of its geographical coveragewill see us well
on the way to persuading drivers to leave their cars at home.
Whilst the Institute doubts that this will be the case, and that
more robust measures will be required to make significant impacts
on traffic growth, it nevertheless supports the proposed measures
for the enhancement of public transport. These will be necessary,
in any event, to ensure continuation of necessary mobility levels
in the future.
35. In this context, the Institute fully supports
the White Paper's proposals. These are both comprehensive and
varied, including: better interchanges, between different public
transport mode, and between cars and public transport (paragraphs
1.27 and 1.29); better integration of public transport
(paragraphs 3.48-3.78); better buses (paragraphs 1.30
and 3.13-3.25); and a better railway, and establishment
of the Strategic Rail Authority (paragraphs 1.32, 3.26-3.31,
3.36-3.38 and 4.12-4.16). Critical will be the local
authorities' and transport operators' ability to deliver, through
the implementation of Local Transport Plans, the use of planing
obligations, and, of course, the availability of the necessary
levels of funding for local transport schemes.
36. The Institute particularly welcomes recognition
of the need to make housing, employment, and larger developments
generally, more accessible by public transport (paragraph 4.116).
This must be delivered by the development planning system and
the development control process, and the Institute will be happy
to work with the Department to ensure that appropriate guidance
is available, both in PGGs and in the form of good practice.
To establish efficient but more environmentally
friendly ways of moving freight
37. The White Paper recognises that, over recent
years, the conventional wisdom has become that rail will never
regain its former market share of freight transport, not only
because of shrinkage of the rail network, but because, with the
decline of heavy industry and coal mining, the nature of goods
to be transported is less suited to rail. In terms of overall
kilometre-tonnes, this is likely to become a self-fulfilling prophesy.
That belittles the effects of the aggressive marketing of the
principal rail freight operator (English, Welsh & Scottish
Railway) (paragraph 3.32), its increasing ability to handle
wagon-load or less than train-load business, and the facility
for rail to handle containerised goods efficiently. It also minimises
enthusiasm for researching and developing novel ways of road/rail
integration (such as "piggy-back"), within the confines
of the UK's somewhat restricted loading gauge.
38. But in environmental terms, the significance
of each additional long-haul trainload of freight, in terms of
the heavy lorry movements it displaces, should not be under-estimated
(paragraph 3.33). Thus, we need to look at the means by
which the attraction of rail freight can be enhanced, the provision
of proper facilities for the transfer of goods at railheads, and
the possibility of using smaller, low-emission road vehicles for
transfer to final destinations (paragraph 3.41). The same
applies to waterborn traffic, using canals, navigable rivers and
coastal waters, through the potential penetration of these is
more restricted than that of rail.
39. The White Paper covers these issues effectively.
In particular, the proposed Strategic Rail Authority's responsibilities
are to include ensuring that the needs of both passenger and freight
operators are met by new infrastructure plans (paragraph 1.33).
This is a developing issue. English, Welsh & Scottish Railway
has pointed to the lack of daytime capacity for freight trains
between the frequent high speed passenger trains on the East Coast
Main Line, and the need to ensure that its current increasing
usage of the West Coast Main Line is not eroded by the upgrading
plans. Speed, frequency and guaranteed delivery times are as much
a part of the freight railway as the passenger.
40. The Institute accepts that, even with the
greatest possible exploitation of the alternative means of moving
freight, the principal carrier will remain the road vehicle. This
means that roadfreight has to be made as sustainable as possible,
and initiatives such as Quality Partnerships for Freight
(paragraphs 3.170-3.172) are strongly endorsed.
41. Paragraphs 3.173-3.177 discuss the means
by which efficient distribution might be weighed against concerns
about the environment. They include the phrase "Lorries
should not travel on unsuitable roads unless they have to use
them for collection or delivery." This is a fine sentiment,
but it begs the question of enforcement. There may be more scope
to discuss and agree voluntary schemes with the operators, as
an extension to the "Well driven" initiative.
42. It has always been a role of the planning
system to ensure that development which will generate heavy lorry
traffic does not take place where access is unsuitable. An inherent
problem rests with activities such as mining and quarryingwhich
are often located in rural areas without access to the primary
route network, but which can only take place where the materials
to be extracted naturally occurwhere such matters are often
outwith planning control. This is an issue which needs to be addressed
through revised Minerals Planning Guidance.
To provide a more attractive environment for walking
43. The White Paper produces a sound basis for
addressing the needs of pedestrians (paragraphs 3.1-3.7)
and cyclists paragraphs 3.8-3.12), and for developing more
detailed policy in the future. Much can be achieved through the
dissemination of good practice advice and other guidance to local
44. The Institute supports the principle of
including walking and cycling strategies in LTPs. This will ensure
that local authorities give them "strategic" consideration,
as an integral part of transport deliberations. However, whether
such policies should be included in the LTP, or more appropriately
in the development plan, is an issue that can only be determined
when the interaction between LTPs and the development plans, and
their respective roles, has been worked up fully (see paragraph
45. Particularly welcome is the "Streets
for People" initiative (paragraph 3.100 et seq).
In many towns and cities it will be important to be able to demonstrate
how much can be achieved in terms of the walking/cycling environment
now, without having to await the reduction or removal of traffic.
46. The Institute also welcomes recognition
of the importance of the layout and land use mix in new developments
in terms of "pedestrian friendliness". Mixed use developments
can encourage walking by bringing complementary uses close together.
47. The White Paper's proposals in respect of
school journeys (paragraphs 5.29-5.34) seem a little too
simplistic. While "safe routes", from a road
safety point of view may be relatively easy to devise, the personal
safety of children is often a greater concern. The provision of
safe, constantly supervised routes, where parents can be satisfied
as to their children's safety, presents a completely different
range of problems. However, the Institute can support the approach
suggested by the raft of initiatives in paragraph 5.34,
because these begin to recognise that different schools, in varying
locations, will require individual solutions, and each case has
to be looked at on its merits.
To ensure a rural dimension to integrated policy
48. In making its contribution to "Developing
an integrated transport policy", last year, the Institute
was concerned that, because the problems of congestion, air pollution
and poor environment were most prevalent in urban areas, the perceived
solutions would be seen in urban terms, without due weight being
given to the particular travel difficulties faced by people in
rural areas. The White Paper, and its Scottish and Welsh sisters,
however, offer some reassurance on this concern.
49. The White Paper itself was preceded by the
Chancellor's announcement, in his March 1998 Budget, that £50
million was to be made available over three years for the enhancement
of rural public transport, as referred to in paragraph 1.31.
As early as paragraph 1.12, the White Paper acknowledges
the difficulties of inadequate public transport in rural areas,
in the context of choice of transport mode. This is an issue which
must be addressed by regional planning guidance, in an integrated
50. Paragraphs 3.117-3.122 consider issues
of traffic disturbance in the countryside and offers support for
the Countryside Commission's initiatives in this area. The need
for Local Transport Plans to address issues of traffic in the
countryside is also emphasised.
51. The possibility of introducing road charging
in areas where there are seasonal pressures (paragraph 4.96)
may require further consideration, to ensure that it does not
impact unreasonably on people living in those same areas. If decisions
on road charging are to be left to local authorities, in the context
of regional transport strategies, the fears of many rural residents
may be allayed. On the other hand, road charging is likely to
be the principal source of revenue for the implementation of Local
Transport Plans, and local authorities in rural areas will have
to weigh the need for this resource against its local impact.
52. In rural areas, there is scope for many
more local transport initiatives, particularly of an innovative
nature, such as those described in paragraph 5.45. Integration
between modes is just as vital in rural as in urban areasit
simply takes a different form.
To fund change
53. In terms of funding for transport, the commitment
in the White Paper (paragraph 4.10) is "to ensure
that we properly maintain and manage our existing infrastructure
and that we support the delivery of integrated transport locally,
to reduce congestion, improve the environment and increase accessibility
for everyone". The difficulty with such a general commitment,
of course, is to put a figure on the realistic cost of meeting
54. The July 1998 Comprehensive Spending Review
promised a doubling of local transport expenditure by 2001-02.
In the context of implementation of the White Paper's proposals,
this clearly must be welcomed, but it has to be said that the
"doubling" starts from a very low base. Also to be welcomed
is the abandonment of the annual spending round, and its replacement
by spending limits over a three year period.
55. In essence, however, the White Paper does
not deliver the main source of funding. This will come from road
user and workplace car parking charges, requiring legislation.
The legislation has the potential to deliver to local authorities
a level of funding for transport the like of which they have never
seen before. The problem will be to balance the political acceptability
of particular levels and extents of charges against the imperative
of improving public transport facilities and services. Considerable
uncertainty remains, in spite of the assertions in paragraph
56. The Institute welcomes the White Paper.
It is the first attempt by a UK Government to review comprehensively
the issues involved in introducing an integrated transport policy.
it is perhaps stronger on rhetoric than on implementation, but
provides sound base on which to built.
57. In the Institute's view, the White Paper's
greatest shortcoming is that it does not make a strong enough
link between land use planning and transport. To provide people
with a realistic range of choices about how, when and where they
travel, they have to have options on home, job, school and leisure
locations. Land use patterns and transport are inextricably linked.
58. Much can now be achieved without the need
for new legislation , and the Institute looks forward to involvement
in the consultations on the series of policy and guidance documents
listed at the end of the White Paper.
59. The new funding streams, which will become
available to local authorities for enhancing public transport,
are reliant on legislation. These mechanisms are vital to reduce
car-dependence, when car-users can see that public transport is
able to provide an attractive and viable alternative for their
journeys. The Government is urged to bring forward the legislation
24 September 1998