Memorandum by the London Planning Advisory
Committee (IT 36)
INTEGRATED TRANSPORT WHITE PAPER
The London Planning Advisory Committee (LPAC)
is the Boroughs' statutory planning committee for London. It was
set up in 1986 by the Act which abolished the Greater London Council.
Its main role is to give Londoners, through their Borough representatives,
a say in the overall planning of London. It does this by:
advising Government and Boroughs
on strategic planning matters and major development proposals;
representing London in the regional
planning of the South East; and,
advising Government on parking policy.
Over the last decade, LPAC has forged a London-wide
consensus on land use and transport policies, and their implementation.
LPAC policy is expressed in formal "Advice" to Government
and the Boroughs. LPAC's "1994 Advice", based on two
years of London-wide participation, is the most authoritative
and comprehensive strategy for London's future development, setting
out integrated land use, transport and environmental policies.
The transport strategy in LPAC's 1994 Advice is built around three
Reduce the amount of travel.
Restrain traffic, especially the
Improve public transport.
This has been developed further since 1994,
especially in LPAC's 1996 Integrated Transport Programme for London.
The proposed Greater London Authority (GLA)
will take over the functions of both LPAC and the Government Office
for London with regard to strategic planning. As a result, LAPC's
experience and expertise will be transferred to the GLA and the
The broad structure of this submission was agreed
by the full LPAC committee at its meeting held on 22 September
LPAC welcomes the Government's Integrated Transport
White Paper as a significant policy document which sets out a
comprehensive framework for dealing with transport policy in an
integrated way and fills the void that had been in existence for
a number of years. However, much of what is set out is still rather
vague and it is being left to the proposed supporting "daughter"
documents to set out the detail.
LPAC has seven key concerns that it wishes to
raise, as follows:
1. The fact that the need for better land
use and transport interaction is not carried through the document.
2. Whether Regional Planning Conferences
will have the resources, skills and necessary government advice
to prepare regional transport strategies.
3. The lack of clear timetable for the necessary
legislation to implement road user charging and parking levies,
and concern that the parking levies are not being extended to
include non-workplace parking.
4. The failure to recognise the importance
of the national rail network to London.
5. Concern that airports policy is still
dominated by a "predict and provide" approach.
6. Welcome to the Trunk Roads Review and
new appraisal approach to major transport investment, but concern
about the proposed M25 schemes.
7. Concern about the lack of a clear indication
that the timescale and resources necessary to implement the White
Paper's approach will be forthcoming.
Detailed comments on each of these seven points
are set out below.
LPAC's response to the Government's consultation
document, "Developing an Integrated Transport Policy",
stressed the need to integrate transport strategy with other areas
of public policy and particularly of the need for a fully integrated
land use and transport strategy. This is because transport is
not an end in itself, but is only an enabler. One of the essential
objectives of an integrated transport policy must be to make both
development and transport itself more sustainable. To achieve
this objective, proper integration of land use and transport planning
is a vital pre-requisite of an integrated transport policy.
Whilst the White Paper talks about the integration
of transport with land use (paragraph 1.22) and acknowledges that
"land use planning plays a central role in delivering sustainable
development, complementing and contributing to the success of
other measures such as economic instruments" (paragraph 4.156),
this thought is not carried over into the majority of the White
Paper, where transport too often appears to be dealt with as a
self contained activity and integration sought in terms of transport
provision rather than throughout the whole gamut of public policy.
Much will need to be done in the proposed revisions to planning
policy guidance (PPGs) to deliver true land use and transport
integration, and indicate how transport will support wider planning
and sustainability objectives. In many ways this is similar to
the position on the Greater London Authority (GLA) White Paper
which proposes a strong transport executive body (Transport for
London) to oversee transport provision in London, but does not
really address the need for a holistic approach which brings together
land use and transport planning with environmental and regeneration
The White Paper continues the welcome recent
trend of placing transport planning firmly within the wider planning
context, as is evidenced by the Supplement to PPG13 which provided
for trunk road proposals to be considered as part of, and in the
context of, regional planning advice. In particular, Regional
Planning Conferences are to develop regional transport strategies;
although it is also to be noted that the guidance on what should
be included in those strategies is purely in terms of transport
rather than what transport can contribute to the achievement of
wider planning objectives. These regional transport strategies
should then set a context for both the transport aspects of development
plans and the new Local Transport Plans, and for decisions on
major investment proposals, including trunk road schemes.
The White Paper, in keeping with the Government's
intention of giving greater political status to the regions, places
considerable responsibilities on the Regional Planning Conferences.
It fails to recognise, however, that, judging from the experience
of the South East, the Conferences do not necessarily have the
authority (from and with) their constituent membership or the
financial, technical and administrative resources to assess, formulate,
present and deliver a comprehensive transport strategy. Regional
Planning Conferences will also need clear guidance on how to carry
out these new responsibilities, including advice from Government
on the methodologies necessary to assess public transport accessibility
and determine regional transport priorities. As a result, further
consideration of their role must include options that address
these issues so that Regional Planning Conferences are put on
a much firmer footing.
LPAC has long recognised the need for mechanisms
to manage demand (the "sticks") as well as those which
promote alternatives to the car (the "carrots") and,
hence, welcomes the proposals for powers for local authorities
to charge road users and/or set levies for workplace parking.
These will also have the added benefit of raising additional finance
to improve alternatives to the car. However, LPAC is concerned
that no clear timetable is set out for the necessary legislation
for this or for the Strategic Rail Authority. In London, these
powers will be vested in the Greater London Authority (GLA) and
it is essential that they are available in time for its expected
inception in April 2000.
LPAC is also concerned that non-workplace parking
(i.e., for customers and visitors to retail and leisure facilities,
hospitals, schools, etc.) appears to have been excluded from the
parking levy legislation. These types of trip are the ones experiencing
most growth and dispersal, and are also the types of trip where
the provision of large out-of-centre car parks has encouraged
increasing car dependency. Whilst new developments can be guided
to more appropriate "central" locations that can also
be well served by walking, cycling and public transport and more
restrictive parking standards can also be used to reduce car dependence,
there is much existing development that is unsustainable and whose
travel patterns needs to be influenced. As such, the parking levy
legislation should be drawn as widely as possible to allow the
inclusion of non-workplace parking so that the GLA is able to
consider whether such measures are required in London as part
of the development of an integrated land use and transport strategy
early in 2000.
LPAC's main concern about the current organisation
of the rail industry (expressed in "An Integrated Transport
Programme for London?", 1996) is that the decision making
process in respect of infrastructure investment and service provision
no longer takes account of planning and the wider objectives of
public policysomething that is essential to achieve integration
in its broadest sense. This concern is heightened by the Integrated
Transport White Paper which presents rail only in terms of its
national function. In London, rail is not only a vital part of
the regional transport system, bringing people into London to
work, shop and for leisure purposes, it is also part of local
transport with over half of all rail journeys starting and finishing
in London. For example, local passenger services like those on
the North and South London Lines and the Gospel Oak/Barking Line
provide the most effective means of orbital public transport travel
in the areas of London they serve.
In order to rectify the situation, the new Strategic
Rail Authority (SRA) should have a statutory duty to take account
of planning policy and considerations. Investment in the national
road network is being increasingly put in the context of regional
planning and so should investment in the national rail network.
If local government, at regional and local level, is given the
responsibility of formulating transport strategies, it must be
given the means of influencing those whose actions will play a
major part in determining whether those strategies are implemented.
The White Paper talks of the SRA working "closely with local
and national organisations, including local authorities, Regional
Planning Conferences, Regional Development Agencies, . . . "
(paragraph 4.14). How this should be done must be spelt out clearly.
In London, the Greater London Authority (GLA) must have a clearly
defined and real influence with the SRA, and through it with Railtrack
and the train operating companies. The GLA must have a real say
in investment decisions and service provision, the latter including
a role in the negotiation and determination of franchises. Without
this, the GLA will not be able to deliver an integrated transport
strategy for London.
The White Paper's commitment to the preparation
of a UK Airports Policy looking some 30 years ahead is welcome.
LPAC has long advocated the formulation of such a long term, national
aviation strategy. For too long the planning of airport capacity
(both terminal and runway) has been subject to decisions based
on short term expediency. The implementation of a long term strategy
will allow its integration with surface access proposals, regional
development strategies and the broader objectives to be achieved
from transport's integration with other areas of public policy.
The recognition of London's airports as one system is welcome.
This should lead to a lessening of the over emphasis often given
to Heathrow which leads to transport, environment and development
impacts which are counter to broader planning objectives.
However, it is disappointing that the White
Paper makes no reference to moving away from the "predict
and provide" approach which has now been applied to the provision
for air travel for many years. In other areas, notably the highway
programme, where the increasing demand for travel has had impacts
that are unacceptable in both environmental and economic terms,
this principle has been abandoned. The White Paper's emphasis
on regional airports and surface access considerations are welcome,
but they alone will not be sufficient to ensure that airport policy
contributes towards sustainability rather than working against
The outcome of this review, which is a related
document to the White Paper, is broadly welcome. It continues
the trend of placing highway investment decision making within
the context of regional planning policy and regional development.
Particularly welcome is the new appraisal framework. Not only
does this allow a wider range of consequences to be taken into
account, and increasingly for those factors to be quantified,
when assessing proposals, but it provides an assessment framework
which is intended to be applied across modes. This was something
LPAC's "1996 Integrated Transport Programme for London?"
considered was essential to gain best value for money from investment
in transport and to ensure that that investment was contributing
as fully as possible to wider planning and sustainability objectives.
Whilst the Trunk Roads Review generally seems
to be in keeping with the White Paper and its objectives, the
decision to go ahead with the further widening of the M25 between
junctions 12 and 15 is more of a throw back to the previous approach.
Here, the Government's approach seems to be that the conditions
for road traffic are so critical over this section of the M25,
that it cannot wait for the kinds of approaches being taken elsewhere
in the review to have effect because of the time they take. This
is to reject the solutions being put forward elsewhere in the
roads review because, in this case, they are not considered to
be effective enough. This does not foster confidence in the new
approach in those areas where it is to be applied, where undoubtedly
some people will see the problems they face as being just as great
as those on this section of the M25. Here, an integrated approach
is not being taken to the solution of a transport problem and,
since a significant proportion of the traffic on the M25 over
this section is related to Heathrow Airport, this also seems to
indicate that an integrated approach is not being taken to the
issue of airport development and the surface access requirements
In policy terms the White Paper sets out the
intention of making considerable change, with much of the detail
of how that change is to be effected to follow in forthcoming,
complementary publications from government. What the White Paper
fails to give an indication of is the timescale it anticipates
for its policies, and different parts of those policies, to be
implemented. Many of the policy changes need to be backed by legislation
and/or changes to planning policy guidance which together will
form the broad national framework within which policies will be
implemented at the local level. Local authorities, and other interested
parties such as business and providers in the rail industry, need
an outline programme as to what is expected of them by what date
and what powers are going to be available to them to achieve it.
As important as the knowing what the framework and mechanisms
for policy implementation will be, is to know what resources will
be available. This is particularly so in local government which
is increasingly taking on board responsibilities from Central
Government for transport and related matters, e.g., the provisions
of the 1995 Environment Act in respect of air quality, and the
requirements of the 1997 and 1998 Road Traffic Reduction Acts,
without any indication of additional sources of funding. LPAC's
advisory 1996 Integrated Transport Programme for London sets out
a broad indication of the level of resources needed in London.
In London, the need for these timescale and
resource issues to be dealt with quickly is acute. The Greater
London Authority (GLA) is expected to come into effect in April
2000. Much is expected of it, including the preparation of an
Integrated Transport Strategy, which will be the main instrument
of pursing many of the policies sought in the White Paper, to
be delivered largely via a new, multi-modal transport agency,
Transport for London. The need for the new Mayor for London and
the GLA to have, from the outset, the power to introduce congestion
charging and charges for private non-residential parking space
is referred to above, but more generally, the rest of the implementation
framework, including the resources that will be available, needs
determining quickly. As such, a firm timescale for the implementation
of the White Paper's proposals is urgently needed.
LPAC welcomes the Integrated Transport White
Paper and believes that it provides a firm basis on which to develop
an integrated transport policy. Our main concern is that it is
still weak on the link between land use and transport planning.
We are also concerned about the lack of detail on how the approach
will actually be implemented and the lack of a clear timetable
for the urgently needed legislation.
23 September 1998