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




  1.1 The Agency welcomes the opportunity to comment on the document Developing an Integrated Transport Policy. This is a subject area which is relevant to the Agency's overall sustainable development remit, and to its specific task of collecting environmental information in order to form an opinion of the state of pollution of the environment. It is also a subject which impinges on a number of areas which are central to the Agency's recently-published Environmental Strategy, including climate change, and air quality. The Agency's success in implementing its own strategy will thus, to a degree, be affected by future trends in transport.

  The Agency recognises that this subject is a highly complex one. It involves a complex mixture of issues relating to people, goods, and services. It involves issues which are societal, cultural, and economic. But it also involves issues which have an impact on the environment, and it is in this area that the Agency is obviously most keen and able to contribute to the developing debate.


  2.1 The Agency has assessed the issues and questions set out in the consultation paper and, although many are pertinent, it has restricted its response to those areas where it is able to make constructive recommendations. These are set out as follows.

2.2 Question 1. "Are the aims we have set ourselves in paragraph 10 the right ones?"

  The Agency welcomes the aims set out in the consultation paper. The need to balance environmental protection with economic development is at the heart of the Agency's principal aim of sustainable development. It is therefore important that recognition be given to the impact and costs of today's choices on future generations. Some 40 per cent of petroleum products are used in road transport, and increasing road transport will restrict the availability of such resources in the future. The impacts of their usage, such as climate change, will be equally long-lived. With the issue of inter-generational equity in mind, it would be wise to ensure future impacts and costs are considered alongside current economic development.

2.3 Question 3. "Recognising that funding available from the public purse is strictly limited, how best do you think our transport systems could be improved?"

  The Agency feels it is inappropriate to comment on the precise mechanisms by which transport systems could be improved, but it is clear that a shift in emphasis away for inefficient forms of transport (e.g., single occupancy car journeys) to more efficient mass-transit systems (e.g., rail travel) is essential.

  2.4 The general level of appreciation for the true environmental impacts of the various modes of transport appears, at present, to be somewhat low. This will have an impact on the acceptability of any measures which are driven by environmental goals. There is however wide acceptance, at a community level, that road transport is environmentally damaging.

  2.5 It would therefore seem sensible that the Government's transport policy seeks to direct more public resources to mass transport systems, and to promote a greater choice of transport options in areas where private motor vehicles are currently the only transport option.

2.6 Question 5. "What roles should be played by pricing, fiscal policies, and regulation to achieve our goals?"

  It is clear that a single pricing measure in support of environmental improvements would be unwise, because the economic burden would not be borne by the most appropriate parts of society. A more balanced approach involving a range of levies, incentives, and charges should be considered in relation to the environmental benefit that each would deliver.

  2.7 The experience of the Landfill Tax has shown that environmentally-related taxation measures are more easily accepted by the public when the benefits of the resources collected are clearly evident. Taking this experience on board, the Agency recommends that any fiscal measures employed are seen to be directly linked to environmentally-beneficial activities.

  2.8 The Agency has committed itself to working with others in improving inland waterways. It recommends that fiscal mechanisms are introduced to encourage waterborne traffic, and that the Agency is then able to recover the costs of maintaining and improving the waterways for both navigable and environmental purposes.

2.9 Question 7. "Would transport policy be enhanced by adopting a range of transport `targets', against which to assess progress?"

  The Agency would encourage the development of any measures against which progress and performance of the transport options may be assessed. The overall aim is to reduce total environmental impact and this can be helped by pointing out the relative, per unit, impact of different transport options available today. It is important therefore, that such measures enable the total environmental impact of transport to be assessed as well as providing a means of assessing the unit impact of each mode of transport, for example:


  CO2 emissions per passenger mile or per tonnage transported from each mode of transport expressed as a percentage of the overall 1990 levels of emissions.


  NOx emissions per passenger mile or per tonnage transported from each mode of transport expressed as a percentage of the overall 1997 levels of emissions.


  The level of water-borne transport expressed as a percentage of the traffic from all transport modes.


  The area of undeveloped land (including green-belt and undeveloped brown-field sites) taken for each mode of transport expressed as a percentage of the 1997 level of undeveloped land.

  2.10 It is essential that any environmental measures that are established can be used to determine progress at the local, regional, and national levels.

2.11 Question 9. "..which aspects of public transport do you think it is most important to improve in order to persuade more people to leave their cars at home and use public transport instead?"

  The diversity of choice open to the public at present, and the lack of interconnectivity where choice exists, are prime constraining factors in persuading people to leave their cars at home. It would seem that town and country development has not been accompanied by an appropriate level of public transport infrastructure, and thus in rural areas private motor vehicles, and in particular cars, are the only practical mode of transport. An extension of choice, together with the integration of transport modes, would therefore be a significant advance. The promotion of positive incentives to offset any negative incentives should be a key part of any integrated policy.

  2.12 There is already much useful experience in other European countries—such as Austria, the Netherlands and Switzerland—which highlights the benefits of single-payment, multi-mode transport systems. The simplicity of such systems for the end-user is often the most attractive feature.

2.13 Question 12. "How can we actively encourage more environmentally-friendly vehicles and fuels, the development of less environmentally damaging technologies and innovations which reduce the need to travel?"

  The development of more environmentally-friendly vehicles and fuels is an important goal, but will require the establishment of criteria against which the environmental benefits may be established. Such criteria should include the following:

    —  resources and energy required for the manufacture of vehicles and fuel;

    —  the efficiency with which fuels are used and the pollutants they generate;

    —  the ability to reuse and recycle vehicle components at the end of life (e.g., GRP body panels); and

    —  the lifetime and impact of vehicle components (e.g., tyres, hydraulic oils).

  2.14 In relation to water-borne transport, boat designs which result in less wash should be promoted because this is an important cause of bank erosion on some waterways.

  2.15 The Agency also recommends that the Government promotes an environmental budget for each type of fuel source. This could help tease out the different but measurable environmental damage caused in the production and use of different fuels.

  2.16 Existing mechanisms for funding innovation (such as Foresight and LINK) should be employed, with the emphasis on supporting more sustainable technologies. Financial incentives such as those through the VAT system could be offered to R&D targeted at improving the environmental aspects of transport.

2.17 Question 13. "How can we integrate land use planning and transport more effectively, with a more strategic approach, so as to cut unnecessary journeys?"

  At the strategic level it is fundamental that an integrated approach be taken towards land use planning, the environment, and infrastructure provision, including transport. It is at this stage that the generation of much of the need and the possibility for journeys is created. The existing system of Regional Planning Guidance needs to be strengthened and expanded to cover transport, planning issues to ensure that the regional development framework has assessed the transport needs of reginal development allocations, and that the environmental constraints and impacts are considered at the same time. The overall trunk road/motorway planning programme should also be linked more strongly with development plans. Regional planning guidance on collaboration between adjacent local authorities should be established to aid a more strategic approach to the emerging issues.

  2.18 Planning Policy Guidelines (PPG) notes still need to be revised. The Agency is currently producing a series of Local Environment Agency Plans (LEAPs) in order to develop its own means of delivering environmental improvements at a local level. These LEAPs gather together a wide range of data on the state of the environment, and what affects it. This data is used by the Agency as the basis for local consultation. The outputs from these documents, and their use, could be of value in enabling the impact of transport issues to be seen in perspective at a local level, and enable their consequences to be fed into the planning system.

2.19 Question 14. "How can we ensure, for example through the taxation system, that the prices faced by transport users more accurately reflect the wider environmental and social costs?"

  The Landfill Tax appears to have had a significant impact on the public's awareness of waste disposal, because it has imposed a financial penalty on those who generate most waste. The potential application of this form of taxation could be explored in relation to transport. It is however important to recognise that one of the factors that may govern the success of any such system will be the frequency at which the message of environmental damage is brought home to the user. In this respect, an environmental tax or levy which reflected the environmental burden of that transport option could be applied either to each journey (as in the case of public transport), or each time fuel is purchased (as in the case of road transport). The "internalising" of external costs appears to be an essential step in reinforcing the message of environmental impact. The Agency would therefore recommend that an indicative environmental cost of each transport option be established and publicised widely to inform the debate, prior to any implementation through the taxation system. The Agency could help in establishing such costs.

2.20 Question 21. "How can we best take account of the differing accessibility needs of urban and rural communities?"

  The Agency is well aware of the importance of having regard to the social and economic well-being of rural communities; it has a duty to do so itself in relation to the exercise of its functions. It is clear that the choice of transport mode is often more restricted in rural areas than for urban communities, and the availability of public transport more restricted or, indeed, totally absent. As far as is practicable, the Government should promote diversification of transport modes in rural areas (e.g., increased bus services or new rail links) to ensure that any economic penalties associated with road transport are offset by a greater choice.

2.21 Question 22. "How can we increase the awareness of transport users about the consequences of their choices?"

  The Government should seek to reinforce the message of the environmental impacts of transport through existing mechanisms, and by providing specific information as suggested in paragraph 2.9 above. The environmental impact of cars could also be an integral component of all sales literature for new vehicles. As the Government's Environment Agency in England and Wales, we would wish to play a role in increasing public awareness of the consequences of transport options. But it is important to recognise that increased awareness of the consequences of transport will only be beneficial if the user is able to make a choice based on this information. At present, the lack of choice of transport modes in some areas may restrict the impact of such information.

 2.22 Question 27. "What should the role of transport be in delivering the national air quality strategy, reductions in acidifying pollutants and our climate change commitments?"

  The Agency is committed to helping the Government meet its emission targets for greenhouse gases, and to deliver the National Air Quality Strategy. However, some 20 per cent of CO2 emissions and over 60 per cent of NOx come from motor vehicles. These mobile sources, which are difficult to regulate, are of major concern to the Agency because they detract from the significance of the Agency's achievements in reducing inputs from non-mobile sources. With traffic projected to grow by 60 per cent by 2031, this represents an increasing challenge, and is probably one shared with local authorities in relation to local air quality plans. It is clear that a rational and fair approach to delivering targets for air quality, acidifying pollutants, and climate change commitments would require proportionate reductions in emissions from the transport sector. In the absence of such an approach it could be argued that an undue burden would be placed on regulated sectors as targets are chased. The Agency will of course continue to work in partnership with (and where necessary regulate) industry to meet the required targets. It is in this area though that the Agency most directly experiences the impingement of transport related impacts on the successful delivery of environmental targets.

  2.23 The current regulatory framework does not lend itself particularly well to the reduction of emissions from vehicles, and yet some form of regulation will be required if there are no voluntary reductions in emissions forthcoming in the future. The Agency recommends that the Government considers such methods as traffic zoning, exclusion zones, and tighter emission controls to restrict further the impact of road vehicles, particularly in the light of anticipated increases in road traffic.


  3.1 The Agency welcomes the Government's initiative in this area. The choice of future transport options will have considerable implications for the environment, and the Agency would wish to work closely with the Government in both developing policy and monitoring progress in this area.

  3.2 Many of the recommendations set out above should be explored at local, regional and national level because it is clear that no single integrated transport option will be applicable in all circumstances. The Agency will continue to work with local authorities in its role as a statutory consultee in the planning process, and will advise via its LEAPs on the environmental implications of the transport options under consideration. Given the importance of such decisions for the environment of England and Wales, the Agency will continue to follow developments in this area very closely.

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