Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence


Memorandum by The Royal Town Planning Institute (IT 102)

INTEGRATED TRANSPORT WHITE PAPER

INTRODUCTION

  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 pollution.

  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.

GENERAL COMMENTS

  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 its content.

  6. The White Paper gives very broad coverage—from 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 less—and 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 engineered—a change in public attitudes probably greater than that achieved in relation to drink-driving, or smoking—which 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 difficulty—we 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 success.

  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 price—for 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 future.

  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.

Operational detail

  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 18-24 (below).

Legislation

  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 split.

  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 this—the legislation will require considerable prior consultation, and it will be some time, in any event, before it can appear on the statute book—but stresses the importance of not losing sight of it, and progressing with all reasonable speed.

DETAILED COMMENTS

  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 car;

    —  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 policy; and

    —  to fund change.

  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 travel—providing a framework in which people have realistic choices of travelling less frequently, or over shorter distances—must 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 context.

  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 funding allocations.

  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 compulsion—the "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 attractive—quite 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 themselves.

  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 its problems:

    (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 do; and

    (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 schemes—rather 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 sword:

    (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 policy.

  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 transport—in its efficiency and effectiveness, the full integration of modes to provide the "seamless journey", and in the extension of its geographical coverage—will 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 quarrying—which 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 occur—where 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 and cycling

  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 authorities.

  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 21, above).

  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 manner.

  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 areas—it 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 it.

  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 1.29.

CONCLUSIONS

  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 without delay.

24 September 1998


 
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