Memorandum by the Royal Society for the
Protection of Birds (IT 42)
THE INTEGRATED TRANSPORT WHITE PAPER
Whilst generally welcoming the Integrated Transport
White Paper the RSPB has a number of serious concerns on specific
issues relating to the conservation of biodiversity that the White
Paper does not fully address. These concerns are as follows:
One-quarter of the UK's greenhouse
gas emissions are transport-related and the transport sector is
by far the fastest growing emission sector. Significant climate
change caused by anthropogenic emissions of greenhouse gases is
likely to severely damage biodiversity leading, in some cases,
to species extinction. The White Paper recognises these facts
but does not adequately address the question of how to reduce
transport-related emissions. Neither do the "daughter"
papers issued so far.
One of the cornerstones of the integrated
transport policy described in the White Paper is the devolution
of a considerable amount of decision-making to local and regional
authorities. Although devolution may have many benefits it is
likely to make achieving quantitative international and national
targets more difficult, especially those concerning greenhouse
gas and acid rain precursor emission reductions. The Paper does
not adequately address the question of how to co-ordinate local
actions so as to achieve national and international targets.
The White Paper contains comparatively
little detail on air, sea and inland waterway transport. Whilst
appreciating that road and rail networks needed urgent consideration,
that daughter papers on the other subjects are to be anticipated
and that international sea and air travel is largely governed
by international agreement, there are a number of wildlife-related
issues in these areas that need to be addressed, some as a logical
consequence of having an integrated transport policy. The RSPB
is especially concerned about increased air travel and the rapid
growth of greenhouse gas emissions resulting from this increase.
The White Paper states that there
will be a strong presumption against transport schemes being approved
in cases where they could significantly (and adversely) affect
biodiversity. The RSPB welcomes this presumption but concerned
that it is apparently watered down, or even contradicted, by statements
in subsequent daughter papers on road appraisal.
The RSPB welcomes the opportunity to contribute
to this inquiry. The White Paper represents a significant step
away from the unsustainable "predict and provide" policy
on roads and towards a more environmentally benign policy based
on a mix of transport modes, including cycling and walking.
However, the RSPB has a number of reservations
about specific aspects of the new policy, the more significant
of which are outlined here. In particular, the RSPB considers
that the White Paper and its "daughter papers" do not
adequately address the problem of climate change and the damage
that this will do to wildlife.
This submission first outlines the RSPB's general
concerns about transport policy and its effects on biodiversity
(Section 2). There then follow sections on specific concerns about
the devolution of decision-making (3.1), transport by air, sea
and inland waterways (3.2), the new appraisal system (3.3) and
the use of economic instruments (3.4).
2. The RSBP's concerns about transport
The RSPB is concerned about transport policy
because of the damage that transport systems can, and usually
do, cause to wildlife and their habitat. This damage has two main
The first cause is the construction and use
of transport facilities such as roads, ports and airports. Whilst
digging habitat up and burying it under concrete or tarmac is
obviously destructive, it is often the routine use of constructed
facilities that is more damaging in the long term. For example,
local air pollution can harm flora and fauna at a considerable
distance from roads. The same is true of noise. RSPB studies indicate
that many birds species, including the rare bitterns and stone
curlews, are apparently very sensitive to traffic noise and will
not nest anywhere near motorways. Mitigation measures such as
creating nature reserves in the margins of roads are thus laudable
in their intent but often limited in their effectiveness.
The second cause of damage to biodiversity is
more insidious and derives indirectly from burning fossil fuels
and, indeed, some other forms of burning. Of particular concern
in terms of their impacts on wildlife are the greenhouse gas emissions
that lead to climate change and the emissions that lead to acid
rain. Acid rain, for example, tends to destroy heather and hence
the wildlife that lives upon it.
All forms of transport that use fossil fuels
emit greenhouse gases and usually acid rain precursors. The transport
sector, especially road and air, currently accounts for about
a quarter of UK greenhouse gas emissions. Both the sector and
emissions from it are growing rapidly whilst emissions from the
other main sectors are more or less stable or declining. Any strategy
to mitigate climate change must therefore not just curtail emissions
from transport but cut them.
Climate change caused by greenhouse gases already
appears to have had adverse effects on species far from the UK
such as the Adelie penguin and the keel-billed toucan. At home,
according to the recent review of the potential effects of climate
change in the UK (prepared for the Department of the Environment
in 1996), a one degree Celsius increase in temperature may significantly
alter the species composition in about half of the statutory protected
areas in the UK.
Given that the same document anticipates that,
on average, the UK will be 0.9 of a degree warmer by the 2020s
than the average for the years 1961 to 1990, and 1.6 of a degree
warmer by the 2050s, the prospects for wildlife do not look good,
even assuming complete compliance with the Kyoto Protocol by all
nations which will, by itself, do almost nothing to limit climate
change; it is merely a first step.
A common misconception is that wildlife and
their habitat will simply move north as climate change occurs.
This is extremely unlikely for many species. Not only is the rate
of northward shift of climate in the UK likely to be too fast
for some species (averaging about 5 to 8 km per year SE to NW)
but a significant number of birds and animals are dependent on
habitat that cannot move from place to place, if only for reasons
of geology. The chalk downland habitat of parts of southern England
will not simply travel north along "safe corridors",
settling down temporarily in the sandstone regions of Yorkshire
and the granite-based areas of the Highlands. The same is true
of much waterfowl habitat in the related context of sea level
rise. Many species thus face extinction.
It is in the context of these concerns that
the RSPB makes this submission. The Transport White Paper and
its "daughter papers" published so far herald a welcome
change in the direction of thinking about transport. They recognise
all of the RSPB's main concerns in principle but they often either
do not go far enough in addressing them or are too vague. Above
all, the Government needs to grasp the nettle of how to cut transport-related
greenhouse gas emissions hard, and soon. The White Paper merely
aims to "reduce road traffic growth".
3.1 Regional and local planning
Both the Integrated Transport White Paper and
Review of Trunk Roads lay great store by local and regional plans
for transport. Many more decisions concerning roads will in future
be made at the sub-national level.
The RSPB welcomes the devolution of decisions
to regional and local levels. However, it is disappointing that
the White Paper does not provide more detail on how this will
be implemented. The revised PPG13 on transport and PPG11 on Regional
Planning Guidance must provide more detailed guidance for local
authorities and Regional Planning Conferences (RPCs). In particular,
this guidance should specify that local authorities and RPCs should
carry out a Strategic Environmental Assessment (SEA) of their
transport strategies. The Government is committed to SEA as a
tool to help integrated environmental considerations into decision-making,
and this should be reflected in the guidance.
The guidance should also require local authorities
and RPCs to set indicators and targets in their transport strategies,
including on biodiversity. In particular, they should set out
how they will contribute to international and national targets
such as emission reduction targets for greenhouse gases and acid
rain precursors. This is important to ensure that the Government
can deliver the emission reductions that the UK is legally obliged
to make under international agreements such as the UN Framework
Convention on Climate Change and its Kyoto Protocol (and the EU
Council decision on burden sharing) and the Protocols to the UN
ECE agreement on Long Range Transboundary Air Pollution (LRTAP).
The role of the Secretary of State in finally approving RPG will
be critical to ensure that these requirements are implemented
consistently between regions.
We welcome the criteria approach to decision-making
at the regional level/(paragraph 4.53). These should be wider
sustainability criteria, including biodiversity. In particular,
we believe that there should be a cut off for decisions, where
significant adverse impacts on biodiversity interests are likely,
so that those proposals are automatically ruled out (see our comments
on Appraisals in section 3.3). Government must also ensure that
RPCs that they will be pressured by local authorities to include
Whilst the devolution of decision-making is
welcome, we remain concerned that local authorities and RPCs will
require additional resourcing in order to carry out these increased
responsibilities satisfactorily. We believe that the Government
should address these resourcing issues as a matter of urgency,
if its objectives for integrated transport and regional planning
are to be met.
We recognise the important role of the Regional
Development Agencies in influencing the development of integrated
transport strategies (paragraph 4.58). We are concerned however,
that the guidance on the relationship between the RDAs' Regional
Economical Strategies (RES), RPG and regional transport strategies
is not stronger. In particular, we believe that the RDAs should
work within the context of RPG, and help to deliver the objectives
of RPG. Without this, there is a danger that the economic development
and infrastructure needs in the RES could cut across or conflict
with RPG objectives. We have proposed a Regional Sustainability
Strategy for each region, to help integrate the different strategies
for the regions, and to avoid potential conflicts or duplication
of effort. We also suggest that the RDAs should adopt the sustainability
criteria in RPG for new development as suggested above.
3.2 Air, sea and inland waterways
The RSPB is concerned that the White Paper goes
into comparatively little detail on air, sea and inland waterway
transport. Whilst the RSPB appreciates that road and rail networks
needed urgent consideration, that daughter papers are to be anticipated
and that international sea and air travel is largely governed
by international rules and guidelines, there a number of wildlife-related
issues in these areas that need to be addressed, some as a logical
consequence of having an integrated transport policy.
The first of these issues is, again, how to
cut emissions and the second concerns direct impacts. The key
area in terms of emissions is air transport which is growing fast
and is thus an area of considerable concern, especially as the
"bunker fuels" used for international air (and sea)
transport are not counted into national greenhouses gas inventories
and hence emission reduction targets. Also, bunker fuels are duty
free and this encourages rather then discourages their use.
Successive UK Governments have a good record
in trying to get bunker fuel emissions attributed equitably and
the RSPB is encouraged to see that the White Paper expresses a
commitment to continuing to press for tighter worldwide standards
on emissions, the potential application of worldwide environmental
levies and lifting the tax exemption on aviation fuels, either
via ICAO or outside it. However, if significant emission reductions
are to be achieved, especially in the case of greenhouse gases,
the projected increase aviation related emissions needs to be
curtailed, or rather cut, soon. The White Paper does not really
address this issue other than, by implication, via the possible
application of fuel taxes.
As in the case of road transport, cutting emissions
significantly will be hard to achieve politically, at both the
domestic and international levels. Nevertheless, there are, at
least initially, a number of potential win-win options that the
Government could pursue as part of an integrated transport policy.
Notable amongst these is to encourage less air and more rail travel,
both within the UK and via the Channel Tunnel rail link to Europe.
Increased air travel also, of course, tends
to imply providing more or bigger airports, or both, and the means
of travelling to and from them by road or rail. This is likely
to mean more direct impacts on wildlife habitat and certainly
means more emissions from ground based vehicles. The RSPB thus
welcomes the intent expressed in the White Paper to make more
efficient use of existing airports and to provide improved public
transport access to them.
The same concerns about damage to biodiversity
apply to the greater use of ports and inland waterways proposed
in outline by the White paper. Whilst welcome in terms of the
overall transport-related emission reductions that waterborne
transport can offer, its development may pose severe problems
for wildlife, especially in terms of loss of birdlife habitat,
unless improved appraisal guidelines are employed. (The next section
thus deals with this topic in more detail.)
Generally, however, the RSPB welcomes the intent
expressed in the White Paper to make greater use of shipping of
all types, coupled with the tightening up of controls on waterborne
discharges. Indeed, we feel that the Paper might have gone further
than it does in terms of the volume of freight that it envisages
being transferred from road to water.
The RSPB is pleased to see that the White Paper
clearly states that " . . . there will be a strong presumption
against new or expanded transport infrastructure which would significantly
affect such [environmentally sensitive areas or] sites or important
species, habitats or landscapes." However, the Society is
less enthusiastic about some of the more detailed guidance on
appraisals given in the allied, daughter documents on the trunk
roads review: "Guidance on the New Approach to Appraisal"
and "Understanding the New Approach to Appraisal".
In particular, having developed a basically
sound set of appraisal criteria, it seems a pity to state that
"it is for decision makers to make judgments about the relative
value to be put on the individual criteria" (in Understanding
the New Approach). This would seem to leave it open to the new
devolved decision makers to ignore the aforementioned strong presumption
against site of special national or international importance.
Similarly contradictory comments appear in the Guidance on the
New Approach to Appraisal.
It is hard to envisage any circumstances which
would justify a local or regional authority authorising a new
transport facility (or substantially amending an old one) that
would damage a site protected by an international treaty or, indeed,
by national legislation. It is thus essential that the "strong
presumption" clause in the White Paper is systematically
observed, or strengthened to an imperative, throughout any daughter
papers concerning the appraisal of any mode of transport.
Despite these reservations, the new appraisal
framework represents an improvement on the previous approach.
In particular, there is less emphasis on the monetary valuation
of costs and benefits, and clearer presentation of impacts (such
as biodiversity impacts) which cannot be expressed in money terms.
However, the relationship between the summarised results for each
road scheme and ministerial decisions is still far from clear.
More explanation of the reasons for particular decisions would
be helpful. Also there is a need for more consultation (in advance
of decisions) on the scores for each criteriathe latest
scores involved no external (non-Governmental) consultation.
The RSPB supports the plans to apply the new
approach to all forms of transportto establish a "level
playing field" between different modes (see paragraph 1.13
of the Guidance).
3.4 Economic instruments
The RSPB agrees that economic instruments are
an important way of influencing travel choice (paragraph 4.118).
We particularly welcome the reduced vehicle excise duty for cleaner
cars. (We developed detailed reform proposals on this with the
Institute for European Environmental Policy in 1996.) However
it is disappointing that the White Paper does not include any
commitment to reform of the company car tax systemit merely
refers to an on-going Inland Revenue review.
Transport, Energy and Climate Change Policy Officer