Memorandum from the British Council for
Offices (IT 27)
THE INTEGRATED TRANSPORT WHITE PAPER
1. THE BRITISH
The BCO is an organisation that includes in
its broad membership business space users, developers, architects,
consultants, builders and others. The BCO strives to improve the
design and specification of business space to enhance its performance
and its efficiency in use.
2. A NEW DEAL
The White Paper is a wide-ranging review of
the problems and challenges of creating an integrated transport
system. It includes some sensible objectives but the statements
of objectives appear to be stronger than the proposed means of
implementation or the development of sensible and affordable solutions.
The format of the document makes it difficult to analyse the impact
of the proposals as many of the ideas are still subject to further
detail being published and subsequent public consultation. The
success or failure of these initiatives is therefore dependent
upon the scale of cost, the burden of regulation and the extent
It is encouraging that the White Paper does
not outlaw the use of the car but it does discourage use and will
make use more expensive.
In reviewing the White Paper and its consequent
implementation, it is important that certain basic principles
are adhered to:
(a) There needs to be certainty in the measures
(b) Within these measures, there needs to
be flexibility in their applicability to take account of differing
urban and rural conditions and of different localities.
(c) Authorities mandated to implement the
measures should adopt consistency of application.
3. There is a claim that Government is supported
in these measures by popular opinion and that people want more
choice of options.
The White Paper sets out the options; but there
remains a credibility gap as to whether many of these options
do offer a realistic option for many people. People may not wish
to exercise their choice of options if one of the choices were
to be deprivation of mobility, particularly if deprivation also
resulted in loss of employment and added cost.
4. Paragraph 1.22 fairly states the primary
objectives of an integrated transport policy, namely:
" integration within and between
different types of transportso that each contributes its
full potential and people can move easily between them;
integration with the environmentso
that our transport choices support a better environment;
integration with land use planningat
national, regional and local level, so that transport and planning
work together to support more sustainable travel choices and reduce
the need to travel;
integration with our policies for
education, health and wealth creationso that transport
helps to make a fairer, more inclusive society."
These are worthy objectives but the question
is can they be implemented in a way that maintains economic activity,
the improvement of job opportunities, and does not add cost.
There is an implied fragmentation of responsibility
in the management and implementation of policies. This could well
result in an under-achievement of objectives.
5. PUBLIC TRANSPORT
5.1 Paragraph 2.20 states the objectives for
a "New Deal for Transport" as follows:
" improve reliability for journeys
in all modes, helping to support business and economic growth;
improve links with international
support regeneration and the vitality
of urban and rural areas;
make more efficient use of the transport
promote more sustainable UK transport
Can these objectives be applied?
5.2 Whilst buses need some priority in coping
with traffic, the biggest drawback to bus travel is infrequency
of service, unreliable scheduling of timetables and lack of interchange.
It is clear that, if Government proposals are to work, there has
to be a greater focus upon real service improvements rather than
merely improving the flow of information. The general perception
of public transport is that the service is frequently poor both
in terms of reliability and of safety. Providers must demonstrate
5.3 If there is to be significant growth in
the provision of public transport with increased services, can
the systems attract the necessary staff to man them to ensure
improved services and reliability? Already public transport is
subject to cancellation and delay due to shortages of key staff.
There will also need to be significant increased investment.
5.4 In trying to attract more freight to the
railways, it is important to remember that 70 per cent of freight
trips are for distances of less than 50 kilometres.
5.5 The proposed Strategic Rail Authority must
be given real powers to stimulate new thinking in terms of investment
and operations. But they should also be under a duty to consider
new routes to embrace new locations and cross-regional routes.
5.6 The White Paper rightly focuses on the fact
that many people use cars for very short journeys and suggests
that more people could walk or cycle (Paragraph 2.45). This is
a simplistic assumption that overlooks many other travel considerations
and factors, principally a lack of good reliable public transport.
5.7 In summary, the proposals made in the White
Paper are full of promises but there is little substance directed
(a) investment in new and better equipment,
(b) remedying poor timetables and scheduling,
(c) the consideration of orbital traffic
(d) the consideration of reliable, predictable
and safe services.
It must be remembered that all public transport
services have to respond to customer need and not to the operators'
6. TRAFFIC MANAGEMENT
6.1 The White Paper places great emphasis upon
traffic management, particularly Local Traffic Plans which are
administered by local authorities. Whilst congestion can be expensive
to business, exclusion and limitation of access could be worse.
6.2 Traffic management schemes when organised
by local authorities are likely to respond more to parochial and
NIMBY principles whereas in practice they should be governed by
sound pragmatic judgements of need based upon properly argued
case research which ensures a balance of opportunity and does
not necessarily deprive segments of the population of the choices
which they find necessary and to which they are accustomed.
6.3 Where traffic management schemes are prepared
by local authorities, there is a risk of isolationist thoughts
and a failure to recognise the interdependence of one community
on another to assure a co-ordinated flow of people travelling
to and from work and to ensure that there is an ability for road
users to make cross-route journeys.
6.4 The design and implementation of traffic
management systems will impose a very considerable burden upon
local authorities, many of whom are already struggling to fulfil
the statutory duties imposed upon them. Not only will the burden
be one of skills availability and resource but also one of competence.
6.5 Traffic management policies are likely to
be created without the same degree of scrutiny and accountability
that is devoted to other development and planning policies. There
may also be a risk that different local authorities will impose
differential judgmental standards, thus introducing competitive
pressures as between different authorities.
6.6 The process of challenging the imposition
of schemes, independent review and subsequent determination will
also lead to delays, uncertainty and cost. There needs to be a
clear process of review and perhaps the involvement of emerging
regional agencies to harmonise policies as between neighbouring
6.7 The White Paper tends to make the simplistic
assumption that town centres are almost entirely governed by retail
considerations and ignores other employment. The proposals are
very much directed towards the problems of major conurbations
and relate less to lesser towns and rural needs. But the problem
is that all local authorities will seek to apply the principles
regardless of the differences that exist across the country and
as between differing communities.
6.8 If licensing the number of car-parking spaces
is to be implemented as a means of reduction, where will the surplus
cars go? They will be parked indiscriminately on verges, landscaping
and in side-streets, all contributing to increased road safety
risks and environmental damage. It is better to face reality and
accept that the use of good, well laid out parking at the workplace
should be maintained.
6.9 In proposing additional bus lanes, it must
be remembered that where they are not necessary or where the roads
are too narrow, the dedication of new bus lanes can and will increase
congestion on the remaining road surface.
6.10 There is reference to the need to de-trunk
some roads. If this happens, it is important that local authorities
should be provided with adequate additional funding to fulfil
their future management responsibilities. Furthermore, before
such roads are handed over, the trunk road network improvements
should be completed. The recent announcements on the roads programme
has clarified the future of some of these gaps but many needed
improvements have been cancelled.
7. LOCAL ACTION
7.1 Local authorities are likely to be charged
with substantial responsibilities under the White Paper. If they
are responsible for drawing up traffic management and transport
plans, one has to question:
(a) Whether they are competent.
(b) Whether they fairly represent all interests.
(c) Whether their narrow boundaries lead
to a focus which will be disadvantageous to people from wider
employment catchment areas, and
(d) Whether they adopt too parochial an approach.
7.2 Under Paragraph 4.94, it is arguable that
the plans to improve public transport and related traffic management
by charging road users to reduce congestion will hit those least
able to afford such charges and will be against the interests
of rural communities.
7.3 To impose charges on the use of motorways
and other main roads will drive traffic onto less suitable roads.
7.4 Work-place parking charges will be a tax
on jobs and will result in added cost to business. The White paper
is ambiguous as to whether or not work-place parking charges will
be imposed on all employment-generated parking spaces. Will there
be exemptions and, if so, what activities and interests will be
exempt, i.e., will government, hospitals, universities, schools,
etc., be liable to the same charges? If they are not charged,
the logic of reducing congestion will be defeated. If they are
charged, who will fund the parking charges?
7.5 The licensing of parking spaces might well
work in town centres but it will not work in edge-of-town locations,
many of which are inadequately served by public transport. It
will result in hazardous parking by car users on landscaping,
verges, side-roads, etc., which will inevitably result in increased
road safety risks.
7.6 These views are reinforced by comments from
the AA who said:
"People would simply find somewhere to park
in side streets. It is just not a solution. It is also unfair
and prejudicial against people in rural areas."
7.7 It is a tax which is likely to be discriminatory
and its consequences could be perverse as it will be a tax on
7.8 We are concerned by paragraph 4.76 which
seems to suggest that Ministers are seeking to implement their
objectives by stealth without the endorsement of legislation properly
debated and enacted by Parliament. Interim non-statutory measures
may lack the necessary levels of public accountability.
8. PLANNING ISSUES
8.1 There are a number of references in the
White Paper about the need to amend and intensify planning guidance
in terms of transportation. It is important that these measures
be scrutinised when available to ascertain their relevance to
maintaining a level playing-field and to ensure that the changes
do not further inhibit good development which is needed to maintain
and sustain Britain's economic prosperity and trade competitiveness.
It is also important to sustain the maintenance of good job opportunities
in a rapidly changing world.
8.2 We believe that the White Paper's proposals
may well be a handicap to the Government's intentions to encourage
urban regeneration and the use of brownfield sites.
8.3 Paragraph 4.175 suggests that there will
be a wider use of planning obligations to advance the objectives
of integrated transport policies. There should be no extension
of the well-established principles of planning gain until there
has been a full review of the wider issues of the use and application
of planning obligations.
8.4 It is noted that the DETR will be issuing
consultation papers on changes to a number of relevant Planning
Policy Guidance notes. We will reserve comment on these until
such time as they are published.
9.1 We include as Appendix A
a paper on the implication of the White Paper written by Mr Simon
Ricketts of S J Berwin and Co, Solicitors. Mr Ricketts is a member
of the BCO Planning Legislation Committee. His paper builds upon
many of the issues discussed above and raises a number of other
BCO Planning Legislation Committee
23 September 1998
7 Not printed. Back