Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence

Memorandum by Friends of the Earth (TYP 14)


  Friends of the Earth (FOE) is very pleased to respond to the Committee's request for evidence. FOE believes that developing an integrated and sustainable transport system is one of the greatest challenges facing the Government. For the past decade FOE has campaigned for policies to reduce traffic levels as a way of addressing all the problems—economic, environmental and social—posed by the way we travel. We believe it is worthwhile to recap why this is so, and do so before answering the Committee's questions. First, however, we present our analysis of the state of the Government's transport policy.


  In the 1997 General Election campaign, the Labour Party said that it would "reduce and then reverse traffic growth"1. In June 1997, the Deputy Prime Minister, John Prescott said: "I will have failed if in five year's time, there are not many more people using public transport and far fewer journeys by car"2. These statements were made in response to growing public concern about the environmental, economic and social effects of traffic growth. The problems leading to this public concern are, in many cases, as great now as they were when the statements were made, if not greater.

  FOE believes that the Government has back-tracked consistently from its pledges, not because of a failure of policy, but firstly because of insufficient resolve and subsequently because of a loss of nerve. In "Transport 2010", the Government moved back even further from its early vision. There now seems to be little clear direction to transport policy. The Government seems to be muddling through. This has had a knock-on effect on transport policy at local level which has become much more cautious—particularly in urban areas. However, FOE does not believe that attempts to integrate transport policy have failed. They have not been properly implemented.

  A month after being re-elected, Tony Blair laid out his Government's challenge: "our second term mission is to make real and lasting improvements in our public services" referring to education, health, police and public transport3. The Prime Minister also acknowledged the scale of the country's transport problems in his New Year message and press reports suggest transport is viewed as the Government's biggest Achilles heel4. FOE believes that the Government must use the review of Transport 2010 to re-affirm its commitment to public transport and to the integrated transport policy and deliver the resources necessary to reduce traffic levels, particularly in urban areas. The Prime Minister told Labour's 1998 conference that he would rather be right than popular. FOE believes that introducing traffic restraint policies may cause the Government initial unpopularity, but that in the end the policies will be seen to be both right and popular.



  Traffic levels have a huge impact on UK business through congestion, particularly in urban areas. Estimates from the CBI put the cost at £15 billion annually. Other estimates are higher still. The Government has made tackling this problem a key aim of Transport 2010. However research by Professor Phil Goodwin has shown that, across the full road network, even with full implementation of the plan, "the average forecast change in speed is slightly less than half a kilometre per hour (about a quarter of a mile per hour), giving a time saving, at average speeds, of 1.6 seconds per kilometre travelled"5. The time savings are greatest in London (about one minute for a six mile journey) but average speeds on rural roads and motorways will fall. But, as is shown below, full implementation of Transport 2010 in relation to urban areas is unlikely. Congestion charging and workplace car park charging on the scale envisaged are doubtful. FOE believes that the Government must reinvigorate plans to reduce traffic in urban areas if congestion is to be cut.


  The Government says that "climate change is one of the most serious threats facing the world's environment, economy and society . . . the devastating floods, droughts and storms we have seen in the UK and across the world in recent years show all too clearly how vulnerable we are to climate extremes and how devastating they can be"6. Transport is the fastest growing UK source of emissions of carbon dioxide, the main climate change gas. The Government's latest figures on climate change gases show very worrying trends for transport. Total carbon dioxide emissions in 2020 are forecast to be 3.8 per cent below those of the base year (1990). Over the same period, carbon dioxide emissions from transport are forecast to be 28.1 per cent above those of the base year. Transport's share of carbon dioxide emissions is forecast to rise from 23.8 per cent to 31.7 per cent7. The report comments that "most of the forecast increase is from road transport, resulting from a growth in incomes, a consequent rise in the levels of car ownership, greater travel and a greater demand for goods and services"8. The Government claims that it will still be able to meet its Kyoto Protocol target of a 12.5 per cent reduction in greenhouse gas emissions by 2008-12 and its unilateral target of a 20 per cent reduction in emissions of carbon dioxide from 1990 levels by 2010. This second claim, however, is disputed by Cambridge Econometrics9. Irrespective of where the truth lies in this "battle of models", it is certain that traffic reduction will make it easier for the Government to achieve its targets.

  The Government has recently proposed a new air quality standard for PM10 particulate matter of 20 µg/m3 as an annual mean10. The Government's own analysis shows that, under typical climactic conditions, and even with a package of new technological pollution-reducing measures, this target level will be exceeded alongside 1369 road links in the UK11—mostly in urban areas. FOE's analysis of this data shows that over half of these road links are in the poorest 20 per cent of council wards in the country. Short-term exposure to particulate pollution is estimated to cause up to 8,100 people to die prematurely in the UK every year, bringing forward the death maybe by months or more12. Long-term exposure to particulates is a further growing concern. In Britain's towns and cities, where the majority of the population lives, road traffic is responsible for much of the particulate pollution. It produces the majority of particulate emissions in Birmingham, Liverpool, Manchester and Newcastle, and is the largest single source in Bradford, Edinburgh, Glasgow, Leeds and Sheffield13. The threat posed by particulate pollution provides a particularly poignant justification for traffic reduction in the areas affected.

  The Government has also recently expressed its concern over levels of ground-level ozone, which are set to rise in the future14. Background levels of ozone are rising towards the level at which they could start causing damage to vegetation and crops. Although trans-boundary pollution contributes to the formation of ground-level ozone, the contribution of UK "home-grown" emissions is also very important. Ozone is not a "primary" pollutant: it is not emitted directly, but is created by a reaction between other forms of pollution such as nitrogen oxides and hydrocarbons, emitted mainly in urban areas. Road transport produces 44 per cent of UK emissions of nitrogen oxides15.

Road building

  Failure to prevent traffic growth will inevitably lead to further pressure for more road-building. The Government has already acknowledged that "we cannot build our way out of congestion with new roads"16. This is especially the case in towns and cities. Large-scale expenditure on road-building is counter-productive as it does not address long-term problems of traffic growth. Indeed, in many cases, it exacerbates the problems. And, as has been mentioned above, road-building on the scale planned by the Government would barely impact on congestion.

  The Government's road-building plans would damage some of Britain's finest wildlife sites and landscapes. The Highways Agency is currently bulldozing through the Bingley South Bog Site of Special Scientific Interest (SSSI) in West Yorkshire. The Lune Estuary SSSI, part of the Morecambe Bay Special Area for Conservation (Europe's highest wildlife designation) is under threat from Lancashire County Council's plans for a Western Bypass of Lancaster. The Dorset Downs, Heaths and Coast Area of Outstanding Natural Beauty is under threat from the A354 Dorchester to Weymouth Relief Road. Building the Brunel Link and Harnham Relief Roads in and around Salisbury will create pressure for the completion of the Salisbury bypass through building the "missing link" across the world-famous Avon watermeadows.

Social exclusion

  According to the latest figures, 28 per cent of households do not have a car17. This figure rises to 36 per cent in London and the former Metropolitan Counties18. Households without cars are also concentrated at the lower end of the income scale: the lowest levels of car ownership are in single pensioner households (26 per cent) and single parent families (42 per cent). Overall 70 per cent of the poorest 20 per cent of households do not have cars19. Only 41 per cent of women have first access to a car, meaning that in households with only one car, many women are effectively car-less.20

  The Government has forecast that, even in 2011, a quarter of households will not have access to a car, and that 45 per cent of households will have only one car. Thus, in 2011, millions of people will still rely on public transport, cycling and walking for some or all of their journeys. Yet, as traffic levels rise, life for public transport users, cyclists and pedestrians tends to get worse. As FOE's recent report on transport and social exclusion in Bradford shows, the socially-excluded suffer disproportionately from these impacts21. If bus use falls, fare revenue falls and bus companies have to cut frequencies or routes. The Government's current target for increased bus use could be met solely from patronage increases expected in London, and bus use elsewhere could fall. As traffic levels rise, cycling becomes more dangerous. And as car ownership rises, offices, factories and facilities (supermarkets, cinemas, hospitals etc) tend to be built in places convenient to reach by car. Thus people without cars face ever-greater problems. Reducing the overall use of cars and promoting the use of walking, cycling and public transport will reverse these trends and make life easier for those that cannot use private cars.


  Thus for economic, social and environmental reasons, there remains a strong case for reducing the use of cars and promoting the use of public transport, cycling and walking. This case is especially relevant to urban areas.


What assumptions should be modified or challenged?

How important are the assumptions to the outcome of the plan? What remedial action is necessary if assumptions or targets need to be changed?

  Transport 2010 was an important development in transport policy in the UK in that its shape was significantly determined by the extensive modelling carried out beforehand. Consequently the assumptions and proposed targets used in the modelling need to be critically reviewed. DTLR should also allow independent access to the model used, in the same way as the Treasury allows such access to its model of the economy. This would allow the impact of alternative sets of assumptions to be assessed.

  FOE is extremely concerned that Transport 2010 is based on the assumption that motoring costs will fall by 20 per cent over the period of the plan22. This is based on improvements in car fuel efficiency leading to a reduction in running costs per kilometre, and no real change in car ownership costs, non-fuel running costs or fuel duty. This fall in motoring costs will lead inexorably to greater car use. This runs counter to the objective of many of the targets set by the Government in Transport 2010: greater car use will make it harder to reduce road congestion; to improve air quality; to reduce greenhouse gas emissions; and to increase the use of rail, light rail and buses. This is shown by the Government's own modelling. Transport 2010 shows that, if motoring costs are kept constant rather than falling, both congestion and carbon dioxide emissions will fall by greater amounts. In particular, the CO2 savings are 50 per cent greater23.

  The Government has said that it wishes to see a "shift in the burden of tax from 'goods' to 'bads'" because it recognised that the tax system sends clear signals about economic activities that it believes should be encouraged or discouraged, such as work and pollution respectively24. Emissions of carbon dioxide and other pollutants are clearly "bads". However if fiscal measures are to play their role in delivering "a more dynamic economy and cleaner environment, to the benefit of everyone"25 then it seems perverse that motoring costs are assumed to fall while public transport fares are rising. Reversing these would instead help to create a virtuous circle with increased restraint of the least sustainable mode of transport, and additional revenue to invest in more sustainable modes.

  FOE also notes that no assumption seems to have been made on the level of bus fares outside London26

Will the expected number of congestion charging and workplace parking levy schemes be implemented, and when?

  The 10 Year Plan assumes that a central London congestion charging scheme will be in place by 2004-05, charging £5 to enter central London between 07:00 and 19:00 hours on weekdays, and that local authorities outside London introduce eight congestion charging and 12 workplace parking levy schemes in the centres of most large urban areas the size of Blackpool and above27 with all net revenues recycled into transport improvements in the urban areas concerned. It currently looks highly unlikely that these schemes will be implemented. Local authorities were asked to indicate in their provisional Local Transport Plans, submitted in 1999, if they were considering introducing such schemes. Only 12 schemes were proposed28. Furthermore, transport ministers are reported to oppose the Mayor's congestion charging plans for London29. The Government's conviction has been clearly stated: "Traffic congestion is a major problem requiring a radical solution. Road user and workplace parking charges are part of the answer".30 It must now have the courage of these convictions and give a stronger political lead.

How will the current situation in the railway industry affect the need for and provision of private and public sector finance?

  The current situation casts doubt on the hoped-for private finance materialising. This must not be allowed to stop or slow down investment in rail infrastructure. FOE believes that there needs to be a clear commitment from the Government to major funding of rail projects that will bring social, environmental and economic benefits. Government funding should be based on the use of appraisal criteria that are strongly weighted towards environmental and social sustainability, applied to both road and rail projects.

Is the balance and phasing of investment across funding areas correct?

  No. The projected spending on strategic road building is too high. FOE believes that the strategic roads budget should be reduced to approximately £500 million per year, for maintenance purposes. All proposed trunk road construction should be subjected to a rigorous multi-modal test, and a separate budget heading should be set up to fund the outcome of these, whether it be road or rail investment. Press reports suggest that the Secretary of State is proposing to "borrow" from the roads budget to put more money into the railways31. FOE believes that these "borrowings" reflect an acceptance that the balance of allocation is wrong.

  FOE is also concerned that insufficient resources have been earmarked for relieving the transport problems of the largest cities. This is where much of the congestion on the road network is found.

  FOE also has serious concerns about the phasing of funding. Following the (scheduled) completion of the CTRL and WCML schemes in 2003-04, public investment expenditure in the railways is scheduled to fall32. FOE believes that this gives entirely the wrong signals about the direction of Government policy.

How do the emerging multi-modal studies affect the 10 Year Plan?

  The incorporation of their proposals from multi-modal studies within the implementation programmes of the 10 Year Plan, will be a major challenge for transport policy:

    —  They represent a large investment not just in money but also in time and opportunity cost. The first task involves completing them to a rigorous standard.

    —  The second challenge, recognising their diverse origins and potentially diverse solutions, will involve evaluating them for a consistent approach, and then proceeding to implementation. This will create problems for public spending (as their proposals are likely to be expensive), and for implementation (if it seems easier to develop road rather than rail schemes in this country at the moment—because of complex institutional arrangements—will the final output of the studies be genuinely multi-modal?)

  This would also reinforce the tendency, which FOE can clearly discern in some multi-modal studies, for studies to bring forward substantial new road programmes which merely return transport policy and investment to the position of a decade ago.

Should the plan represent a better balance between large and small schemes, and between infrastructure, management and operations?

  Yes. FOE believes that many smaller-scale measures have a greater benefits: costs ratio than larger-scale infrastructure projects, but these schemes often do not get funded. Work on this subject is being carried out for CPRE, Sustrans, Pedestrians' Association and Transport 2000 and we refer you to its outcome. Some small-scale schemes may not appear sufficiently "sexy" for prioritisation by local authorities. To this end, we believe that the Government must take a lead through pledging itself to, say, a safe route to school for every child in the country or traffic calming on all appropriate residential roads.

Are the targets and the dates for their achievement well designed (eg is reducing congestion the right objective)?

  FOE believes that two targets in particular need attention:

    —  The congestion target has been discredited (see above) and should be reviewed.

    —  The target to increase bus use by 10 per cent is far too low and could in practice be achieved by doubling bus use in London (which some experts believe possible if the Mayor's congestion charging scheme is introduced33) despite further decline in the rest of the country. The target should be made more challenging and more in line with Government thinking. For example if bus use doubled in London and rose by 25 per cent elsewhere in the country, this would be equivalent to a 47 per cent rise in bus passenger journeys nationwide. It should be noted that the bus target is not an output of the Government's models, but was introduced "manually".

  In addition, the target to increase rail passenger kilometres by 50 per cent by 2010 looks challenging at first sight. It has been calculated, however, that this could be achieved through a lower rate of growth than has occurred over the last four years. Growth of 50 per cent over 10 years equates to an annual growth rate of 4.2 per cent, whereas the last four years have seen growth at an average of 6.3 per cent per annum34. However sustaining passenger growth at these levels will be problematic with the current inadequate investment in capacity on the network.

What other targets, if any, should be included (eg modal shift, walking, traffic levels?)

  FOE believes that targets should be set in all three areas suggested: for modal shift, walking and traffic levels. In terms of traffic targets, FOE believes that the Government should reconsider the idea of benchmark profiles for traffic levels, as suggested by the Commission for Integrated Transport35. A benchmark profile would be "a yardstick against which to measure progress . . . a specified indicative level for each year, or every two to three years, over the next 10 years" which could be set for different types of area36. These could also be aggregated into indicative national benchmark profiles. These would help guide policy and funding nationally (through the 10 Year Plan) and locally (through Local Transport Plans). They could also help determine, for example, whether planning policy needed to be strengthened.

Should a more regional approach be adopted for target setting?

  FOE believes that in some areas a national target alone is a rather blunt instrument. For example, given that an estimated 60 per cent of rail passenger journeys start or finish in London, one approach to making sure the Government's passenger growth was met would be to focus all investment into the South East. Clearly this will not happen in practice, but we hope the point is made. Regional targets for increasing rail passenger numbers would ensure a fairer distribution of investment, and could be included in new rail franchise agreements, which FOE believes should be drawn up on a regional basis. Again, CfIT's benchmark profiles provide a possible way forward.


How well does the Plan balance social and environmental policy with efficient investment?

  A top DTLR civil servant has admitted that Transport 2010 does not, in its current form, cater for the socially excluded37. The problems arise in two areas. Firstly the proposed spending on trunk roads tends to favour those with cars at the expense of those, such as the socially excluded, whose main modes of transport are buses, cycling and walking, for which smaller scale schemes are more appropriate. Secondly the lack of real solutions to traffic congestion, pollution and danger in urban areas affects the socially excluded more severely than those in more affluent households or areas (see above).

Does the Plan set out a balanced approach to all modes (eg walking)?

  One effect of the overemphasis on large schemes is that modes that are dependent on a large number of small schemes—such as walking, cycling and bus use—do not get their fair share of resources.


  1.  Although not in the manifesto itself, this appeared on the Labour Party's website and in its handbook for candidates.

  2.  The Guardian, 6 June 1997, reiterated in Parliament on 20 October 1998.

  3.  Tony Blair, speech on reform of public services, 16 July 2001.

  4.  The Guardian, 31 December 2001, reporting that the Government's transport performance had been rated by the public at minus 49 per cent.

  5.  "Running to stand still? an analysis of the 10 Year Plan for Transport", CPRE February 2001.

  6.  "Climate Change The UK Programme" Summary Document, 2000.

  7.  "UK?s Third National Communication under the United Nations Framework Convention on Climate Change" chapter 4.

  8.  "UK's Third National Communication under the United Nations Framework Convention on Climate Change" paragraph 4.9.

  9.  Cambridge Econometrics "UK Energy and the Environment" July 2001 p. 27.

  10.  "The Air Quality Strategy for England, Scotland, Wales and Northern Ireland: A consultation document on proposals for air quality objectives for particles, benzene, carbon monoxide and polycyclic aromatic hydrocarbons", September 2001, paragraph 40. The 20 µg/m3 level corresponds to the EU stage 2 limit value. A higher target (23-25 µg/m3) has been set in London, but this appears to be solely for reasons of cost-effectiveness.

  11.  "The Air Quality Strategy for England, Scotland, Wales and Northern Ireland" paragraph 94.

  12.  "The Air Quality Strategy for England, Scotland, Wales and Northern Ireland" paragraph 50.

  13.  Data from National Atmospheric Emissions Inventory.

  14.  DEFRA News Release 281/01, 10 December 2001 "Good news on cutting acid rain—new plans to protect habitats from air pollutants".

  15.  Data from National Atmospheric Emissions Inventory.

  16.  "A New Deal for Transport: Better for Everyone" paragraph 1.16.

  17.  Focus on Personal Travel, DTLR December 2001.

  18.  DTLR "Focus on Personal Travel" December 2001.

  19.  Office for National Statistics, Family Spending 1999-2000.

  20.  Focus on Personal Travel, DTLR December 2001 table 5.2.

  21.  Friends of the Earth "Environmental Justice—Mapping transport and social exclusion in Bradford" October 2001.

  22.  Transport 2010: The Background Analysis paragraph 36.

  23.  Transport 2010: The Background Analysis, Figures 13 and 14.

  24.  The Government's Statement of Intent on Environmental Taxation, 2 July 1997.

  25.  The Government's Statement of Intent on Environmental Taxation, 2 July 1997.

  26.  The only allusion to bus fares seems to be in paragraph 27 of Transport 2010: The Background Analysis, which says that there will be no increase in real terms in public transport fares in London.

  27.  Transport 2010: The Background Analysis paragraphs 61 and 64.

  28.  These were in the West Midlands, Greater Manchester, Leeds, Bristol, Nottingham, Cambridgeshire, Cheshire, Derbyshire, Hampshire, Milton Keynes, Reading and Durham.

  29.  As reported in The Guardian, 10 December 2001.

  30.  Foreword to "Breaking the Logjam: the Government's consultation paper on fighting congestion and pollution through road user and workplace parking charges" December 1998.

  31.  Financial Times, 5 December 2001.

  32.  Transport 2010 table A3.

  33.  For instance Prof David Begg, speaking at University Transport Studies Group conference, Royal Geographical Society 20 September 2001.

  34.  "A Plan for Growth? An analysis of the 10 Year Plan's perspective for rail" prepared for the Railway Forum by Dr. Rana Roy, London, March 2001.

  35.  Commission for Integrated Transport "National Road Traffic Targets", November 1999.

  36.  CfIT "National Road Traffic Targets" paragraph 17.

  37.  Willy Rickett, then head of DETR transport strategy and planning division, speaking to a conference on Local Transport Plans, organised by the County Surveyors? Society and the Local Government Association, reported in The Surveyor, 22 March 2001.

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