"DEVELOPING AN INTEGRATED TRANSPORT
THE ENVIRONMENT AGENCY'S RESPONSE
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
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
2. RESPONSE TO
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
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
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 countriessuch as Austria, the Netherlands
and Switzerlandwhich 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);
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
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
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
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.