Memorandum by the National Farmers' Union
PROPOSALS IN THE INTEGRATED TRANSPORT WHITE
The National Farmers' Union
The National Farmers' Union (NFU) represents
some 75,000 farming members in England and Wales, and an additional
40,000 "countryside" members with an interest in farming
and the countryside. Agricultural industry representation covers
tenant farmers and owner occupiers as well as farm co-operatives.
With a wide range of agricultural and horticultural
businesses, the NFU has a vital interest in securing a sensible
transport strategy. Furthermore, many of its members also provide
tourism, recreation and leisure facilities, and their land may
be used by other industries such as wind farming, aggregate extraction,
rural crafts, storage, fuel for power generation or even licensed
waste disposal. Finally, its members are rural dwellers. They
and their families have a keen personal, as well as business,
interest in the transport debate.
The White Paper has many laudable aims, and
few could object to the overall objectives of reducing congestion,
improving public transport and a cleaner environment. However,
it is an eclectic document with few new ideas for immediate action,
but lots of promises of new policies, mechanisms and structures
for the future. Whilst it is accepted that it is intended there
should be further consultation in many areas of more detail, few
hard facts are presented on which to judge whether or not the
objectives will or indeed can be achieved. This is especially
the case with many of the important decisions in how to achieve
objectives being devolved to Local Authorities or new quangos.
Commission for Integrated Transport
The intention to establish an independent body
to provide advice on implementation of integrated transport policy
and related issues is a worthy objective. In the light of the
example of the Firearms Consultative Committee, it is, however,
questionable as to the benefits that will accrue from such an
approach. It is imperative that if the Commission for Integrated
Transport is established, it must be an effective body.
Funding for Transport
The White Paper focuses on the comprehensive
spending review three year approach as giving a better base on
which to plan and manage transport programmes and also highlights
a number of new funding areas for development, including road
user charging. In that review, significant sums are to be retained
by the DETR to be invested over the thre year period in other
areas of transport apart from rail. Around one-third will be spent
on improved road maintenance and much of the rest passed to Local
Authorities for transport related measures including support for
The increase in investment is welcomed after
cuts of previous years and the emphasis on road maintenance is
also welcomed. The White Paper's recognition of the importance
of investment is noted as responding to lobbying from transport
interests. However, the increase is still significantly less than
the increase in transport investment required to comprehensively
modernise our transport system.
We note that there will be additional funds
made available to cover infrastructure and passengers. We welcome
the infrastructure investment being focused on addressing capacity
constraints on key rail infrastructure to supplement that invested
by Railtrack with a view to ensuring sufficient capacity to meet
anticipated increase demand fro rail freight. However, such investment
should not be the expense of investment in the road infrastructure.
Whilst noting that the Highways Agency will
explore the scope for private financing of trunk roads and will
be giving maintenance of current trunk road infrastructure priority,w
e also note that the White Paper contains a proposed series of
routes for de-trunking. Whilst it is difficult at this stage to
make any informed conclusions on the proposal as criteria for
de-trunking is not available, we question whether this is not
a case of giving with one hand whilst taking away with the other.
We note that it is the intention of Government
to publish draft guidance (PPG 11) setting out new arrangements
for Regional Planning Guidance to include Regional Transport Strategies.
In the absence of further detail, we cannot comment further on
this except to highlight the need for such guidance to address
the rural dimensions of the transport debate.
Whilst in theory we support the proposed changes
to the procedures involved in the production of Regional Planning
Guidance, this would be with the caveat that the Regional Planning
Conference comprises as wide a range of interested organisations
and democratically accountable members as possible to ensure that
a single minority interest does not have undue influence. The
DETR's consultation on the Future of Regional Planning Guidance
(January 1998) aims to ensure that any organisations with a purely
commercial interest in the planning process will not be able to
unduly influence decisions. We would also wish to ensure that
those elected members that represent rural wards and those organisations
that represent rural issues are fully involved in the process
on the basis that in the past, there has tended to be an urban
emphasis on the production of Regional Planning Guidance.
Noting that local transport plans will be the
centrepiece of the proposals in respect of integrating transport
and planning, our main concern is the failure to identify in the
White Paper if local transport plans will become a material planning
consideration. Although the paper makes it clear that the plans
will be statutory, it does not identify their future role in the
development plan process.
We would also raise reservations about any linking
of the plan to Local Agenda 21 strategies. All too often Local
Agenda 21 strategies are perceived as a green policy tool i.e.,
they reflect closely the Bruntland definition (1987) of Sustainable
Development (development that meets the needs of today's generation
without compromising the ability of future generations to meet
theirs) by interpreting this into local protectionist policies.
Planning Policy Guidance 7 gives a much wider definition of sustainable
development that reflects rural economic and social matters, and
we believe this should be incorporated into Local Agenda 21 strategies
in rural areas particularly if they are to inform local transport
We welcome the recognition given in the White
Paper to the poor state of public transport in rural areas. We
note that the Commission for Integrated Transport willb e asked
to advise on future funding priorities in this area. We welcome,
in line with Planning Policy Guidance 7, the emphasis on encouraging
local services. However, we are concerned about the potential
use of key villages as a policy tool. Key villages are an outdated
planning tool whereby resources and services are focused on one
village (in a hierarchy of rural settlements) leaving others to
fend for themselves. This is no longer recognised as a valid planning
tool and instead villages etc. are considered on their own merits.
It is important that policies for reducing the need to travel
should be considered in the same light.
We note the intention that planning guidance
will be updated to create the right framework to deliver integrated
transport policy at a local level. We note that in respect of
transport, the guidance will be updated in a number of areas but
it would appear that what is being suggested is merely good practice
already in many Local Authorities.
We note that for housing, planning guidance
will be revised to give clear advice on the location and form
of housing development and that Local Authorities will need to
consider future travel patterns when planning for new houses but
would urge that the need for affordable housingespecially
affordable to those living and working in the rural environmentin
rural areas must not be forgotten in this (in line with Circular
6/98 on Planning and Affordable Housing).
The White Paper states that Government will
look for improvements in delivery of an integrated transport policy
through various routes.
On a review of the Use Classes Order, we have
already responded to a consultation in this area for a new business
use class. In summary, we are concerned that a rural business
use class would seek to use traffic generation and character as
a means of control. We consider that this proposal would be difficult,
if not impossible, to implement and enforce since it is unclear
at what point traffic volume and character becomes unacceptable.
There would therefore remain an uncertainty for developers who
would not be able to plan for business growth or expansion.
On review of the General Committee Development
Order, with lack of detail, it is difficult to comment on. We
would not wish to see any proposals that would cause undue delay
to the agricultural community and that would prevent them being
able to continue to carry out small scale essential changes swiftly
and efficiently as required by the business.
On updating guidance on use of planning conditions,
we would seek to ensue that updating was in line with Circular
11/95 on the Use of Conditions in Planning Permission.
On the encouragement of incorporation of green
transport plans into planning obligations, we are unclear as to
what is meant by "a green transport plan". If this is
not to be the same as a local transport plan, then this should
be defined clearly. Any changes to planning obligations must be
in line with Circular 1/97 on Planning Obligations.
Representing a rurally based industry and persons
living in rural communities, we are particularly concerned over
the proposals relating to the introduction of legislation to allow
Local Authorities to charge road users as part of a package of
measures in a local transport plan. Whilst this is going to be
subject to a further consultation on how road user charging schemes
could operate, introduction of such charges in rural areas where
there are significant problems caused by high levels of seasonal
traffic, could present significant problems for a rurally based
industry and residents therein. The needs of rurally based businesses
must not be overlooked in utilisation of such schemes.
The NFU notes that it is intended to develop
pilot charging schemes and that full implementation will be dependent
on development of appropriate technology and studies on impact
in areas such as personal privacy and diversion onto non-tolled
roads. We note that the intention expressed in the White paper
goes beyond the intentions in proposals announced in 1992 to target
users of inter-urban motorways. Whilst it is recognised that such
an approach may be a mechanism for dealing with localised urban
congestion in specific problem areas, we believe it inappropriate
for wide scale implementation, particularly encompassing the trunk
road network, since it would impact on the needs to move freight
through and to/from such areas and would lead to diversion onto
non-tolled roads with consequential problems being generated thereon.
The NFU note the intention to introduce legislation
to enable Local Authorities to levy a new parking charge to apply
to all types of private non-residential workplace parking. We
note that non-workplace non-residential parking (e.g., at retail
sites) will not be subject to charging.
The White Paper does not give detail on implementation
of this proposal although it does promise further consultation
on how the scheme will operate. However, if the intention is to
impose charging for parking in the workplace, and, it is not focused
in urban areas where congestion is a primary problem, then the
implications for rurally based industries, including agriculture
will be signficant.
Sectors of the agricultural and horticultural
industry require significant workplace parking to be provided,
particularly the intensive horticulture sectors. Imposition of
a parking tax on such businesses will be a significant burden.
The NFU are opposed to workplace charging in rural areas on sites
such as agricultural holdings.
Application of workplace parking in the rural
environment will also be contrary to the objectives expressed
in the White Paper incentives to encourage the use of local services
and encouraging local employment. For example, farm diversification
schemes creating employment can reduce the need to travel significantly,
but will suffer if they are to be on the receiving end of both
workplace charging and/or congestion charging in rural areas.
We are also concerned over the impact of urban
charging as those obliged to take supplementary employment in
urban areas to support rural businesses.
The White Paper recognises the use of economic
instruments, such as price measures and taxation, as an important
way of influencing travel choice. Differential fuel duty is already
used in this way and it is noted that Government are looking at
ways of using taxation on vehicles to achieve similar results.
Determination of the wider environmental and
social costs resulting from transport in order to ensure that
transport users pay more accurately for them is extremely difficult.
Many reports by various organisations have over the years sought
to "internalise and apportion the external costs" of
transport arising from various sources. There are many uncertainties.
An attempt to use taxation to precisely reflect external costs
would be dangerous as a consequence of the uncertainty and variable
However, whilst external costs may not be safety
used to change overall levels of taxation of road users in particular,
improving the link between supply and demand for infrastructure
and re-balancing the tax and charging regime in transport may
improve the current system where external costs are not taken
into account at all. However, any change introduced must meet
certain key requirements:
it must be undertaken in the light
of pan-EU harmonisation of taxation and the Government must continue
to work for such harmonisation;
it must take full account of UK competitiveness
in the European and international markets;
it must not increase the overall
tax burden on business;
it must be more transparent, be enforceable
and cost efficient;
it must deliver a more consistent
and increased funding for transport;
it must not disadvantage rurally
based industries and communities unnecessarily;
it must be carefully researched before
introduction and must be consulted upon throughout industry and
the private sector, and;
it should comprise a comprehensive
package of change to enable effective targeting of charging benefit.
The NFU note that vehicle excise duty is already
subject to reform with the introduction of legislation allowing
reduced taxation for high emission standard HGVs, and, the development
of the introduction of graduated vehicle excise duty for cars.
However, whilst it has been suggested by some that vehicle excise
duty might be significantly reduced or abolished altogether with
a revenue-neutral increase in fuel duty, this would not be a simple
process. Different levels of vehicle excise duty reduction might
be needed for different categories of vehicles. Rural drivers
and businesses who necessarily have high mileages and therefore
higher fuel usage must not be disproportionately affected, and
some mechanism to ensure fiscal neutrality will have to be devised
for such users.
The White Paper notes continued support for
research into more efficient vehicle design and the use of alternative
fuels. The NFU fully support this approach. On alternative fuels,
one principal area of interest to the agricultural industry is
in the development of cleaner energy sources utilising materials
of agricultural origin. Fuels showing most promise but requiring
further development are ethanol and methanol, and fuel calls can
be derived from wood sources i.e., biomass of agricultural origin.
The introduction of the "non-food uses"
option in the EC arable setaside scheme was an important step
in developing a positive agricultural contribution in these areas.
Under the right fiscal and technical conditions, the agricultural
industry will be able to make a major contribution to the development
of a more environmental friendly transport system through a cleaner
energy route. The NFU believe it is imperative that the Government
should offer appropriate incentives to the development of cleaner
energy, such as pilot plant status for biodiesel production.
We note the system of local air quality management
and that Local Authorities have a duty to assess air quality in
their area to determine compliance with strategy objectives. We
are concerned that the Local Authority power to designate an air
quality management area will be yet another opportunity to set
up another local designation, but this time with boundaries that
are potentially undefinable. The NFU have experienced many problems
in achieving essential development due to various forms of environmental
and landscape designations, and we would be opposed to the use
of any further designations such as air quality designations to
restrict required agricultural development.
The NFU policy in respect of legislation in
relation to road traffic is that the NFU does not condone any
breach of legislation. The NFU recognise that in ensuring compliance
with relevant legislation, there is need for adequate and effective
enforcement. We therefore recognise the need to ensure that such
enforcement can be enabled. However, enforcement must be based
on a combination of capability and trust. Whilst technology can
be utilised for certain enforcement activities with a reasonable
degree of reliability, such as use of speed cameras, the need
to utilise human resources in enforcement will continue. Any proposals
to increase the role of other agencies in enforcement activity,
apart from the police, should be carefully thought through and
it is noted that Government are intending to consult on extension
of powers to be granted to other bodies for enforcement purposes.
The NFU welcome the White Paper commitment to
enforcement which respects the right of individuals but is properly
targeted on the bad driving and anti-social behaviour. To this,
the NFU would add the need to ensure that enforcement also targets
vehicle operators who by virtue of failure to comply with the
legislation put themselves in an economically advantageous position
relative to those who comply. This is particularly the case in
respect of the HGV sector and abuse of the Operator Licensing
system. We therefore welcome that the White Paper includes stated
intentions to improve co-ordination of activities between different
Enforcement Agencies and to bring forward legislation to enable
detention of illegally operated vehicles.
The NFU note that transport impact assessments
will be incorporated in the process of assessing the environmental
implications of all relevant Government policies and major location
decisions. We would wish to ensure that there is no duplication
with existing environmental appraisals which are both costly and
time consuming. Major development proposals are already subject
to environmental impact appraisals.
It is noted that environmental impact appraisals
will be enhanced in their use and that for all environmentally
sensitive sites or areas, there will be a strong presumption against
new or expanded transport infrastructure which would significantly
This does create a slight contradiction in the
White Paper in that it may fail to recognise the need for an integrated
and efficient transport system for all. How will the transport
needs of those who live in sensitive areas be addressed where
such a presumption against is in place. This is especially important
given that many of them are in remote rural areas? What will happen
to the traffic that might divert away from the sensitive areas
and possibly create problems in non-sensitive areas?
In considering integrated transport, the White
Paper does comment on rural traffic, focusing on demonstration
projects in Cumbria, Surrey and Dartmoor as examples of what might
be done. The use of appropriate traffic management on a strategic
basis is recognised and the work of the Countryside Commission
is referenced in respect of their Quiet Roads Initiative. Whilst
recognising the concerns regarding increasing traffic in rural
areas, the NFU are extremely concerned that in seeking to address
those concerns, the needs of rural industry and rural communities
will be over looked. Efficient transport services and an effective
and useable infrastructure in rural areas are central to the continuing
agricultural industry and to rural communities. Policies and practices
impacting on rural roads must recognise this. Movements of freight
and of people for business purposes is essential and as is already
being seen, measures being utilised to control traffic in rural
areas are having significant impacts on the industry. Reduced
speed limits and traffic calming measures are examples.
The NFU are particular concerned with the Countryside
Commission activities in respect of the Quiet Roads Initiative.
The proposals to make rural roads pedestrian, cycling and horse
riding predominant will significantly impact on the agricultural
The NFU notes that the White Paper recognises
the importance of goods delivery by transport systems and that
government intends to ensure sustainable goods distribution. The
NFU awaits with interest the strategy that is to be published
in order to deliver this objective.
Whilst the White Paper does cover a number of
areas in relation to freight distribution, there is an impression
that whilst the White Paper addresses the commercial dimensions
of transport policy, the main thrust of the document concentrates
on people movement and relieving congestion. The NFU is concerned
that future policies will be dominated by such concerns about
people movement and as a consequence could set frameworks that
are detrimental to commercial movements.
The NFU notes one of the few firm commitments
made in the White Paper is in respect of vehicle weights. The
NFU is disappointed with the continuing Government rejection of
44 tonne maximum permitted weight even though this was recommended
as long ago as 1980. The NFU note that one of the prime reasons
for not introducing 44 tonnes at this stage is the fear that such
a move could prejudice the objective of promoting rail freight.
The NFU continues to urge the Government to introduce 44 tonnes
across the board at the earliest opportunity.
The NFU notes that Government shares the concerns
of those, especially in the rural communities, regarding problems
caused by heavy goods vehicles. The NFU shares these concerns.
However, the NFU is concerned that in seeking to address the problems
of heavy goods vehicles travelling on unsuitable roads, the powers
given to Local Authorities to prohibit or restrict heavy goods
vehicle access will become too liberally used. There is already
evidence that Local Authorities are seeking to use their current
powers to introduce restrictions on vehicle access covering areas
rather than specific problem roads. Increasing imposition of weight
restriction on bridges on rural roads causes particular problems.
No consideration is given in some cases to the requirements for
access by frontages in roads or areas affected, nor, consideration
in respect of businesses utilising vehicles in affected areas
such as agricultural vehicles.
Determination of suitability or otherwise of
a road for use by classes of vehicles should be subjected to certain
criteria but such criteria should include the need for access
and efficient freight distribution as well as consideration of
the requirement to create a more peaceful countryside.
The NFU awaits with interest further details
on proposals under this heading.
The NFU notes that it is Government's intention
to encourage greater use of inland waterways where it is practical
and an economic option for freight transport. For agricultural
purposes, the inland waterway system faces the same problems as
the railway system in respect of lack of localised infrastructure
available to the majority of agricultural production sites in
the UK, although the unit size of the carriers on the canal system
for freight transport is more suited to individual agricultural
producers/utilisers than is the case with railways.
The NFU awaits the revised planning guidance
which will encourage more freight to be carried on the water and
Local Authority Development Plans which will be expected to consider
opportunities for new development to be served by waterways.
The NFU would raise concerns, however, about
possible impacts of upgrading and reconnecting remaining working
systems and construction of new parts of the inland waterways
on adjoining landowners.
The NFU notes that railways both nationally
and locally are not delivering their full potential as alternative
modes for goods or people transport.
The NFU believes that railways can play an important
part in the development and implementation of an integrated transport
policy provided that:
rail transport is competitive, flexible
improvements are made to rail infrastructure;
rail becomes a normal part of the
transport chain without the need for specialist equipment;
investment is made to fund loading
gauge improvements to allow, for example, the piggy back carriage
of road vehicles;
the rail freight grant system is
costs are reduced by reducing or
removing track access charges, and;
development of inter-modal transfer
systems is encouraged.
However, in respect of integrated transport
development, railways are unable to service the local needs of
the agricultural business or rurally based community in many cases
simply because of lack of infrastructure.