Memorandum by The British Chambers of
Commerce (IT 111)
1.1 The British Chambers of Commerce (BCC) represents,
through its network of 60 Approved and Accredited Chambers, more
than 110,000 businesses of all sizes and sectors of the British
economy. An efficient transport system is essential to business
competitiveness. Business needs to move both goods and people,
and attract customers. Without efficient transport the creation
of wealth and jobs will suffer. The BCC therefore welcomes the
Government's commitment to overhaul the transport system and as
such welcomes the opportunity to submit this memorandum on the
Integrated Transport White Paper. Our evidence is based on responses
we received from our members to the Government's White Paper and
from the extensive consultation we undertook with business to
develop a BCC transport policy in our recent publication Transport
1.2 The BCC believes that the current transport
system falls short in meeting the changing needs of business.
Commerce requires a transport system that meets the following
Fast and predictable journey times.
Flexibility and choice across different
modes of transport and different routes.
Ease and speed of transfer between
modes for goods and people.
Environmental standards in transport
use that are high but appropriate to business operations and which
do not impede competitiveness.
2.1 Overall, business believes that the White
Paper represents a good framework for transport planning and delivery
over the short, medium and long-term. The lack of detail though
represents a major challenge to understanding the true impact
of measures on the business community and on competitiveness more
generally. The BCC calls for the Government to rectify this situation
as soon as possible with the publication of further documents
related to the White Paper. Without understanding the detail of
Government thinking we cannot comment in detail on many of the
proposals. However, a number of key issues have been raised by
The need for business representation
on the Commission for Integrated Transport.
Stronger recognition of the joint
role of public and private funding in transport investment.
The necessity of strong relationships
between business and local authorities to ensure business is treated
fairly in car park and road charging schemes.
The importance of not discriminating
against rural businesses, which often have a greater dependency
on the transport system due to their geographical isolation from
The need to focus on airports, ports
and rail links, which form the key access points to international
The need not to delay important legislation
on key proposals such as the Strategic Rail Authority and congestion
charging. We believe that these policies in particular are central
to improving the transport system and the lead-in times to improvements
on the rail and local road infrastructure are significant enough
to make them a clear priority for legislative time in the next
(Ref: Chapter 4 Making it Happensections
on UK Action, Regional Action and Local Action)
3.1 To achieve a better deal for transport users,
we believe that national Government must provide focus, regulation
and guidance to the transport industry, and to local government
and regional agencies, in order to enhance the transport system
and improve integration.
3.2 The development of a more efficient transport
system that relies less on the road network will take time to
achieve. The role of planning and strategic thinking is therefore
paramount, as is ensuring that there is coherence across local
and regional boundaries. It is proposed that the Regional Development
Agencies (RDAs) be key partners in the preparation of Regional
Planning Guidance. The BCC agrees that the role of RDAs should
be that of achieving better integration between national policies
and local delivery and we would welcome further detail on how
such integration might be achieved, both in terms of transport
and in the wider context of economic regeneration.
3.3 The effective delivery of Government policy
at the local level will be the true test of this White Paper.
Road charging, car park charging and local transport plans will
require the support of business and communities. Whilst we support
a non-prescriptive approach to local dialogue between business
and local authorities, Government should go further than simply
expecting authorities to engage with their communities and transport
operators. The BCC and the Local Government Association are running
the Listening to Business seminars with the hope of identifying
more effective local dialogue. The results of these seminars would
contribute well to the development of best practice guidance for
3.4 Along with their duty to consult effectively,
the BCC supports the following responsibilities for local authorities
to ensure local transport is tailored to local needs:
Developing local transport strategies.
Developing and maintaining local
Introducing town centre access charges
with hypothecation to increase transport investment at the local
3.5 The BCC supports the introduction of local
transport plans to help create a more coherent transport strategy
at the local level, particularly when hypothecation is involved
and spending priorities need to be set. Whilst the White Paper
indicates that the Government will need to be satisfied that transport
strategies have the backing of local business and communities,
we await confirmation on how the process of community consultation
and Government verification might occur. The BCC believes that
local transport plans must incorporate:
The integration of land-use and transport
The management of car parks.
The identification of funding priorities.
(Ref: Chapter 4 Making it Happensection
on Better Planning)
4.1 The BCC welcomes the Government's recognition
of the need for a more sympathetic planning system that looks
to integrate more fully road, rail, air and sea facilities. We
are particularly pleased to see the White Paper commitment to
require local authorities to consider the appropriateness for
rail links at new and existing distribution and manufacturing
sites. However, we wish to see details of how that consideration
will be undertaken and monitored.
4.2 Guidance from the Government on planning,
together with regional co-ordination on large-scale transport
and infrastructure projects geared towards improving access to
different modes, is essential for the rapid delivery of an integrated
transport system that is less reliant on roads. The BCC therefore
looks forward to commenting on the revised planning policy guidance
for development plans, and land use and transport, and on new
Regional Planning Guidance.
(Ref: Chapter 4 Making it Happensection
on UK Action)
5.1 The European Centre for Infrastructure Studies
estimate that a 30 to 50 per cent increase in transport investment
is needed to bring the UK average transport expenditure per head
up to the annual average per capita in the European Union. Despite
the increase of £1.8 billion spread over three years that
was announced following the Comprehensive Spending Review, more
is needed. Whilst we accept the limitations on the public purse,
the Government must not expect all new investment to come from
the private sector as pump-priming will be needed in many instances.
We also believe that there are a number of options to secure current
and extra investment. These include:
An assessment of the effectiveness
of existing subsidies to transport providers.
Some reallocation of funds to pump
prime research and development into transport technology.
A full assessment of the availability
of European Funds to finance transport infrastructure development.
5.2 In general we support moves by the Government
to increase the extent of private finance in transport provision
through such tools as the Private Finance Initiative and Design
Build Finance Operate. The BCC is concerned about the extent to
which such schemes are restricted by process and bureaucracy.
The innovation and expertise of the private sector is already
benefiting rail investment programmes and we believe that further
investment schemes, such as the issuing of asset-backed bonds
on transport projects, will be forthcoming once a fairer allocation
of risk is achieved between public and private investment.
(Ref: Chapter 4 Making it Happensections
on Changing Travel Habits and Sending the Right Signals)
6.1 The BCC believes that congestion can no
longer be ignored and supports the reconciliation of the demand
and supply of road space through price mechanisms, namely road
charging. Charging motorists in town centres is unacceptable if
investment in the transport system is not forthcoming. The BCC
is pleased to see the introduction of hypothecation alongside
road charging policy although we await further details on any
restrictions applied to spending.
6.2 We also support the use of enabling legislation
to allow local authorities to introduce road pricing only when
justified by local needs. Road pricing will only be appropriate
where congestion and traffic levels are significant. Further detail
on road charging policy is crucial if business support is to be
6.3 In the White Paper the Government committed
itself to further research on the effects of road charging and
on methods of implementation. The BCC fully supports this approach,
particularly on motorway tolling, which we are concerned may lead
to traffic displacement onto unsuitable roads.
6.4 The BCC believes that charging measures
should not restrict essential vehicles from gaining access to
town centre areas. We believe that essential users should be defined
as the emergency services, disabled people and delivery vehicles
where the delivery cannot be easily undertaken by other means.
6.5 It is vital that charges and spending priorities
are set according to the wishes of local residents and business.
The BCC feels that combining hypothecation with increased local
democracy, possibly via a system of elected mayors, would greatly
improve the quality of local decision-making. In general though,
we recognise that the strength and quality of links between business
and local authorities must improve, particularly with the possible
introduction of the local levy on the business rate.
6.6 Whilst spending priorities must be set at
the local level, the BCC identified four areas where expenditure
should ideally occur:
Provision of appropriate priority
routes for public transport, the emergency services, delivery
vehicles and disabled people.
Provision of infrastructure, such
as car parks, to enable transfer between different modes.
Provision of public transport information.
Provision of school transport.
6.7 Despite our support for urban road charging,
the BCC believes strongly that fiscal measures must be used sparingly
and sensitively in order to avoid damaging business competitiveness.
Fuel duties should not rise by more than the 6 per cent year on
year increase to which the Government is already committed. We
see further increases in fuel as a blunt instrument that would
have a disproportionate impact upon rural businesses and rural
communities. However, measures to differentiate Vehicle Excise
Duty according to environmental cleanliness are broadly welcomed.
(Ref: Chapter 3 Integrated Transport, Chapter
4 Making it Happen and Chapter 5 Sharing Responsibility)
7.1 A major barrier to public transport use
is information and we fully support the Government intention to
introduce a centrally prescribed formula for the collection of
public transport information across all modes. We would however
wish to see a quick transition from a service simply offering
timetable information towards the inclusion of details regarding
such things as car parking facilities at transport interchanges,
prices and the ability to transfer between modes. (Ref: Chapter
3 Integrated Transportsection on More Integrated Public
7.2 A major obstacle to achieving such an integrated
information service is the currently fragmented bus industry.
If buses are to play a key role in an integrated transport system
then the quality and level of service must increase. Whilst we
believe an element of re-regulation may be required to facilitate
these improvements, the introduction of Quality Bus Partnerships
at the local level is very much supported by the BCC as a step
in the right direction. (Ref: Chapter 3 Integrated Transportsection
on More Choice).
7.3 The rail industry must also improve the
speed and reliability of journeys if business is to see rail as
an attractive alternative to the car. The development of the high-speed
West Coast Mainline is very much supported by the BCC and we look
to the Strategic Rail Authority to encourage similar schemes.
(Ref: Chapter 4 Making it Happensection on UK Action).
7.4 The congestion caused by school-related
journeys has been raised as a concern by many businesses. The
BCC supports the Government initiative Safer Routes to School
but we also want to see the introduction of school transport to
help meet the concerns of parents regarding the safety of children.
To fund school transport we suggest that hypothecated revenue
from road and car parking charges is channelled towards appropriate
schemes. We also believe that private sector sponsorship of school
transport might also have a role to play. (Ref: Chapter 5 Sharing
Responsibilitysection on Partnership for Action).
7.5 The BCC is concerned over proposals to tax
non-domestic car parking although we support the general principle
of reducing commuter traffic. These concerns are focused on the
damage to competitiveness and the lack of alternatives to car
travel in some areas of the country. We look forward to further
details in order that business might thoroughly assess the implications
of proposals for competitiveness. (Ref: Chapter 4 Making it Happensection
on Changing Travel Habits).
A FAIR DEAL
(Ref: Chapter 3 Integrated Transportsection
on Delivering the Goods)
8.1 To concentrate activity on improving the
non-road options available to business, and to ensure that the
Government commitment to freight stays on track, the BCC supports
the development of a National Freight Strategy. Such a strategy
would aim to direct investment and offer businesses improved information
in order to increase the attractiveness of rail, air and waterborne
transport for all, or part of their freight journeys. The components
of the strategy should include:
The identification of priority routes
and infrastructure for investment.
The wider provision of freight grants
to kick-start modal shift.
Broadening the options available
to business for freight carriage by non-road means, most particularly
by influencing rail investment to accommodate the needs of freight.
Providing quality information to
business to encourage modal shift and efficiency.
Whilst we recognise that many of these are proposed
in the Strategic Rail Authority, the BCC believes that the wider
framework provided by a National Freight Strategy is still required
to ensure the freight issue is brought to the fore in the integrated
8.2 We support the announcement to encourage
Quality Freight Partnerships as a means of developing a mutual
understanding of distribution issues and community well-being
between freight hauliers, business and local authorities. The
process must be very much a two-way process and our endorsement
of the Quality Freight Partnership concept will depend on seeing
more details of the shape that the partnerships will be encouraged
(Ref: Chapter 4 Making it HappenUK Action)
9.1 The BCC supports the concept of the Strategic
Rail Authority (SRA) as a way of bringing together freight and
passenger interests in a more integrated and better planned rail
system. In particular we look to the SRA to:
Identify solutions to the more pressing
capacity constraints on the network as a matter of urgency.
Develop future passenger franchises
to include a rigid framework of investment requirements on each
Develop investment relationships
and greater co-operation between Railtrack, the train operating
companies, freight operators, rolling stock leasing companies
and the regulators. This will be encouraged by changes to franchises.
Develop access to the network for
freight through investment in terminal facilities and more efficient
loading and transfer techniques.
9.2 The BCC is pleased that the SRA will participate
fully in identifying key projects linking ports and airports to
the network and in encouraging the development of important regional
and feeder rail services. We believe that strengthening links
between domestic and international markets, for both business
and passengers, is paramount. We also accept that private sector
finance will be an essential component of such schemes. However,
we urge the Government to acknowledge that there may be the need
for public money to pump-prime investment in a range of projects
and that the SRA must have the ability to secure funds when necessary.
We note that two new funding streams are being introduced, the
Infrastructure Investment Fund and the Rail Passenger Partnership
Scheme. The BCC believes that to be truly effective in stimulating
investment to overcome capacity constraints and encourage modal
shift, these schemes must not be short-term gestures. We would
welcome more detail on these two funding streams.
9.3 To facilitate the expansion of the network,
we support the participation of the SRA in local and regional
land use planning policy to ensure that rail services integrate
with these policies. We believe that this is particularly important
for the development of rail freight terminals and enhanced road
links to such facilities. We await further details on how these
planning responsibilities might be achieved.
9.4 The BCC stresses the need to give freight
a fair deal on the railways. The Board membership of the SRA must
therefore consist not just of passenger representatives as mentioned
in the White Paper, but also business users of the network to
ensure their needs are met. The priorities we set for improving
the attractiveness to business of transporting freight by rail
are as follows:
Investing in track, signalling and
rolling stock to provide a more reliable and faster service to
Increasing freight access to the
network through development of a significantly higher number of
terminals suitable for large and small-scale business users of
Safeguarding rail freight access
to the network in light of timetable competition from faster passenger
Enhancing local road links to terminals
to reduce the chance of increasing local congestion levels.
Investigating new methods of enhancing
the speed and manner in which goods are transferred from road,
air or sea transport to the rail network. This should include
piggyback services, and the development of new wagon designs.
Increasing the information available
to business both for services and for freight grants to ensure
the attractions of the rail alternative are well communicated.
This should include attempts to overcome the lasting image of
rail as a mode most suitable for bulk goods being carried over
9.5 The BCC calls for a number of improvements
to the railway network in order that rail becomes a viable mode
for a greater proportion of passenger journeys. In particular,
we believe that the following recommendations are key:
Rail journey times and reliability
must be significantly improved to increase the attractiveness
of rail to business and leisure users.
Regular, reliable public transport
links to railway stations are essential to complete onward journeys.
The quality of rail information must
continue to improve and should include details of public transport
links to stations and car parking facilities to enable the planning
of a seamless journey.
The security of rail travel must
9.6 Without the speedy implementation of the
Strategic Rail Authority (SRA) these objectives will remain unfulfilled.
The BCC calls for further details on the SRA to be forthcoming
and that adequate time is given to its establishment in the forthcoming
(Ref: Chapter 4 Making it HappenUK Action)
10.1 The influence of the Strategic Rail Authority
in the development of key rail projects is something that we very
much support as a way of ensuring that those schemes which are
important at a national level come to fruition. The same must
therefore happen with other modes, particularly where links to
international markets are involved. We suggest that the Commission
for Integrated Transport might be involved in the identification
of priority infrastructure developments. According to the BCC
Business Survey on Transport 1998, those schemes that business
deems as essential are:
The Birmingham Northern Relief Road.
Developing rail links from the Channel
Tunnel to the North.
The upgrading of the West Coast Mainline.
10.2 The establishment of the Commission for
Integrated Transport to monitor progress against the White Paper
framework is very much welcomed by the BCC. We would wish to see
strong representation of business on the Commission to ensure
business needs and opinions are fed in to the transport debate.
11.1 The BCC supports many of the proposals
in the White Paper. Below are summarised our main concerns:
The paper, whilst being a welcome
framework for transport development over the short, medium and
long-term, lacks detail making any real assessment of the impact
of proposals on business competitiveness difficult to assess.
The supplementary papers are required without delay and adequate
legislative time must be given to transport matters in the next
parliamentary session if we are to progress towards an integrated
transport system with any speed.
An essential element of key proposals
such as car park charging, road charging and hypothecation at
the local level will be more effective engagement between business,
communities and local authorities. Government has not given enough
detailed consideration of improvements to local consultation and
decision-making in this White Paper.
Too much emphasis has been placed
upon private sector investment sources. Although we recognise
the constraints upon public spending and support greater private
sector involvement in transport investment, we believe that the
public sector will still be required to pump-prime investment
and improve the attractiveness of investment on the part of the