Memorandum by the Environment Agency (IT
INTEGRATED TRANSPORT WHITE PAPER
1.1 The Agency welcomes the opportunity to submit
comments to the Select Committee in respect of the Government's
White Paper, A New Deal for Transport: Better for Everyone.
These comments are set out below under the following headings:
Proposals endorsed by the Agency.
Matters giving rise to Agency concern.
Options proposed by the Agency but
omitted from the White Paper.
2. GENERAL COMMENTS
2.1 In November 1997, the Agency submitted its
response to the Government's consultation paper "Developing
an Integrated Transport Policy". A copy of that response
is attached. (Appendix 1).
2.2 Towards the end of 1997 the DETR requested
advice from the Agency regarding the potential impact on the environment
of the road schemes included in its short-term programme and,
in conjunction with other relevant government agencies, to advise
on the development of a New Appraisal Framework. The Agency recommended
and devised a risk-based approach which was then used to assess
the potential impacts of road schemes on the water environment.
This approach has the potential to be adapted to appraise multi-modal
transport schemes and the Agency is now discussing this possibility
with the DETR. The Agency also believes that there needs to be
considerable public involvement in the application of the New
2.3 The White Paper states that the new Commission
for Integrated Transport "will bring together transport
users, the private sector, local authorities and others to make
recommendations to Ministers". The Agency considers it
can make a significant contribution to the work of the Commission
by providing expert advice on relevant environmental issues.
3. PROPOSALS ENDORSED
3.1 The Agency welcomes the Government's commitment
to giving transport the highest possible priority, and the emphasis
given to the importance of achieving sustainable development.
Recognition of the fact that the way forward is through an integrated
transport policy is endorsed by the Agency, in particular the
commitment to setting out a framework which, among other environmental
objectives, "ensures that the environmental impacts are
taken fully into account in investment decisions and in the price
3.2 Recognition of the importance of introducing
measures to reduce rural isolation and social exclusion is also
welcomed by the Agency, particularly in respect of rural communities.
An effective level of public transport infrastructure in rural
areas will clearly contribute towards improving the social and
economic wellbeing of rural communities, but this needs to be
a sustainable measure and should not be undertaken at the expense
of the environment.
3.3 The construction of new roads brings substantially
increased risk to the environment, especially where the route
impinges on environmentally sensitive areas. The Agency therefore
welcomes and supports the emphasis which the White Paper places
on maintaining existing roads rather than building new ones, and
that it sets out to reduce the growth of road traffic, and encourages
the use of alternative modes of transport by seeking to secure
an integrated system through national, regional and local strategies.
3.4 The maintenance of existing roads may, in
most instances, have less of an impact on the environment than
the construction of new roads. Nevertheless, all maintenance proposals
must have regard to the potential risk of impact on the local
environment and include appropriate mitigation and enhancement
measures. The key to the success of this measure will be the introduction
of pollution control devices on existing roads and their effective
maintenance by the Highways Agency and others.
3.5 The proposed revision of planning guidance,
together with an increased emphasis on urban design, will provide
an essential opportunity to ensure that the issues relating to
transport and the environment are taken into account at the planning
stage. This is particularly important in respect of determining
the locations for major growth and travel generating uses. Similarly,
the integration of local transport plans and development plans
will afford greater opportunities to safeguard the natural environment.
3.6 The initiatives to reduce congestion by
allowing local authorities to charge road users are welcomed,
as are the proposals for charging users of motorways and trunk
roads. These measures could be important for achieving an appropriate
balance between the demand for transport and the provision of
transport infrastructure which does not incur excessive environmental
costs. The development and monitoring of pilot charging schemes
should be introduced as soon as possible.
4. MATTERS GIVING
4.1 Whilst the integration of local transport
plans and development plans is welcomed, this will only result
in positive benefits if the lifespan and timescales for implementation
and review of both documents are closely co-ordinated. Development
plans are currently at different stages of preparation and the
timescale involved in reviewing such plans varies considerably.
The review of planning guidance will need to address the co-ordination
of local transport plans and development plans.
4.2 The proposed increased use of waterways
as a means of transport is recognised. It is however important
that any such increase is not at the expense of environmental
considerations; for example, the reference under Thames 2000
to "a programme of infrastructure works to create up to
10 piers at key locations on the river, modernise existing piers
and improve linkages with other public transport" must
respect the sensitivity of the tidal foreshore areas.
4.3 Although the technological solutions identified
in the White Paper will contribute towards improving the current
transport situation, it is nevertheless necessary to recognise
that behavioural change is also needed. The relationship between
attitudes and behaviours is complex and poorly understood with
respect to environmental issues. The Agency therefore urges that
greater consideration be given to this complex aspect, particularly
to the identification of measures that can most effectively succeed
in altering actual behaviour and reducing road travel.
5. OPTIONS PROPOSED
5.1 Statements on the environmental benefits
and rationale for using a variety of economic instruments are
welcomed. Such instruments can play a major part in achieving
environmental objectives concerning transport. Unfortunately,
the White Paper does not set out the scale, nature, significance
and costs of the environmental damage that is caused by each transport
option. Environmental damage caused by individual transport users
must form part of any consideration of fiscal and other control
measures if they are to be accepted, implemented, and acted upon
effectively. The Agency therefore recommends that indicative estimates
of the environmental damage caused by each transport option be
published at the earliest opportunity. The Agency is willing to
help in this process.
5.2 The White Paper does not specify the extent
to which the projected growth in traffic presents an increasing
challenge to achieving environmental targets for the emission
of pollutants from motor vehicles. The Agency therefore welcomes
the statements describing the important role which local authorities
will have in the new system of Local Air Quality Management for
achieving air quality targets. As a consultee in the process,
the Agency looks forward to contributing to the development of
action plans for each air quality management area.
5.3 The Agency suggests that the current review
of the National Air Quality Strategy should detail the specific
measures to be taken, and highlight any uncertainties concerning
their effectiveness and the extent to which these could jeopardise
achievement of the targets. It is also recommended that the DETR
establishes a system for monitoring and regularly reporting the
progress made towards achieving targets.
5.4 With regard to the stated aim to reduce
greenhouse gas and CO2 emissions in the UK, the Agency
looks forward to seeing the consultation paper on options for
meeting targets. It considers that the consultation paper should
identify and analyse in detail the likely effect of each of the
various measures in the White Paper and, more importantly, their
effectiveness. The paper should also set out what additional measures
will need to be considered if the proposed measures do not turn
out to be as effective as originally envisaged; for example, if
there is not in practice a significant change in attitude to road
6.1 The Agency welcomes the Government's White
Paper as a way forward in the pursuit of achieving sustainable
development, and wishes to work closely with the Government, the
new Commission for Integrated Transport, the Regional Development
Agencies, and local authorities in developing policy and monitoring
progress. The Agency already works closely with local authorities
as a statutory consultee on land use planning matters, and during
the preparation and implementation of Local Environment Agency
Plans (LEAPS). These activities are particularly relevant to the
issues contained in the White Paper.
6.2 Many of the environmental impacts of transport
options affect the way in which the Agency is able to discharge
its statutory obligations, and its ability to maximise its contribution
to sustainable development.