Memorandum by Transport 2000 (TYP 18)
INTRODUCTION
1. Transport 2000 is a campaign and research
group which works for sustainable transport policies. Its members
and funders include environmental and consumer groups, transport
operators, local authorities, charitable trusts and trade unions.
It carries out research on transport issues and promotes good
practice in transport.
2. We welcome the opportunity to comment
on the Government's 10 Year Plan for Transport. In general, we
welcome many of the commitments and the funding in the plan but
have a number of concerns:
— traffic and its growth are not seen
as issues, yet since traffic (vehicle mileage) is the basis of
transport modelling, failure to restrain growth means that, in
effect, "predict and provide" is returning to road planning;
— the plan focuses on big projects
and downplays small scale schemes, which include most measures
that promote buses, walking and cycling;
— the assumptions on congestion and
traffic growth are implausible given the slow progress and lack
of clear political support for implementing any form of traffic
management or restraint, including congestion charging and workplace
parking schemes and also bus priority;
— events since the plan, especially
on the railways, have brought some aspects and assumptions in
the plan into question;
— the plan includes provision for significant
new road construction and does not consider sufficiently the environmental
or traffic-generating impact of this;
— there is a danger that in practice
the next 10 years will see implementation mainly of big road schemes,
because of problems with implementation, political support and
funding for all other modes and projects;
— the multi-modal studies are highly
variable, have in many cases failed to consider a wide range of
options and are in some cases producing very large and expensive
programmes of new road construction.
ASSUMPTIONS
3. We would question a number of the assumptions
in the plan. First, the fuel price assumption seems below the
likely outcome. Since the plan was prepared, demand for oil has
weakened substantially, while limits on supply, from OPEC and
non-OPEC countries such as Russia, have been relaxed. Yet the
price has fallen only to just below $20 per barrel. The plan period
will see substantial reductions in North Sea oil supply, and a
consequent reliance on supply from politically and economically
unstable areas. The plan's view that the price will be at $16
a barrel by 2010 therefore seems unlikely. This matters because,
in the plan's model, cheaper oil means greater volumes of traffic
predicted and therefore a greater justification for new roads.
4. Secondly, the plan's link between economic
growth and growth in transport needs to be questioned. The last
few years have seen very small increases in traffic, down to as
little as 1-2 per cent per year, with nil growth away from the
motorway network. Yet this is has been at a time of significant
economic growth of 2-3 per cent per year. By contrast, during
the last period of sustained economic growth, in the late 1980s,
traffic grew faster than GDP. The Government seems to have done
little detailed work on this phenomenon, though the plan suggests
that factors such as rising real fuel prices (through the Government's
fuel duty escalator), road congestion and reductions in some rail
fares are likely to be involved. It is therefore clear (a) that
it is possible for Government to influence traffic growth and
(b) that it is possible to have strong economic growth without
matching growth in traffic.
5. Thirdly, the plan's assumptions on traffic
and congestion are dependent on local authorities outside London
introducing eight congestion charging schemes and 12 workplace
parking levy schemes, as well as the London congestion charging
proposals going ahead. On current levels, we believe this to be
optimistic. Transport 2000 has good links with local authorities;
at present, it appears that, apart from London, only Bristol is
firmly committed to congestion charging, with Leeds possibly interested
and smaller schemes planned for Durham and the Peak District,
and only Nottingham is committed to introducing the workplace
parking levy. Of the others which have expressed interest, Reading,
Milton Keynes and authorities in the West Midlands and Greater
Manchester have not proceeded with schemes yet, while Cambridge,
and some district councils in Essex are supportive but Cambridgeshire
and Essex, which are the highway authorities, are opposed. The
main reasons for caution are concerns about competition from neighbouring
areas without charging (for example, out of town shopping centres
and business parks), worries about local political impacts and
a perceived lack of clear Government support for the principle
of charging. The same caution applies to other traffic restraint
measures such as increased parking charges, tighter controls on
parking, pedestrian priority areas or more priority lanes for
buses and cyclists. The plan is markedly cooler and more detached
on charging than was the 1998 White Paper, leaving the decision
largely up to local authorities. Transport Ministers past and
present have made no secret of their own opposition to charging,
and the Government has failed to spell out clearly that some restrictions
on traffic growth are inevitable, and that the alternative to
charging or management of traffic is gridlock. Yet without such
political support, the charging and other measures which the plan
assumes will reduce traffic growth and congestion will simply
not happen.
6. The Sub-Committee's press notice asked
about the availability of skills and capacity. These are in short
supply across the transport sector, except possibly for big construction
projects on road and rail. There are well documented shortages
of skilled staff in railway signalling, but there is also a large
shortfall of skilled staff at a local authority level. This affects
in particular the delivery of schemes which involve significant
public consultation, including bus priority, light rail, traffic
and parking management, cycling and pedestrian priority projects.
7. Other assumptions underlying the plan,
including notably the ability of the railway industry to deliver
the growth in patronage envisaged in the plan, are clearly under
question. For all these reasons, we believe that the assumptions
in the plan will need radical revision.
IMPLEMENTATION
8. The plan's assumptions on railways have
clearly been superseded by the Hatfield crash and its aftermath,
and by the placing of Railtrack into administration. It has been
argued that very large extra sums of spending on the railways
will be needed. However, there are a number of factors in play
here, which we hope the sub-committee will be able to disentangle:
— Historic underinvestment in the upkeep
of the basic railway. This predated privatisation, but since then
there has been further underspending on basic infrastructure.
— Poor management of assets and asset
maintenance by Railtrack. The condition of the rail assets, and
hence the extent of funding needed, is unknown, as Railtrack had
not compiled an asset register and indeed had been lax about keeping
records relating to the assets.
— Poor management by Railtrack of maintenance
projects and contracts, and of upgrading projects, both minor
and major, leading to significant inflation in maintenance and
project costs.
— New requirements for funding for
safety and for disability access (though some of this is in fact
already in the 10 Year Plan).
— The extent to which private funding
for the railways will continue to be available. It is argued that
the private sector will now not invest in the railways because
of the Government's action in putting Railtrack into administration.
We believe that, on the contrary, the simpler and clearer regulatory
and finance regime planned by the Government will in principle
increase the likelihood of private sector investment, but the
construction of packages for the private sector to finance will
take time and will have to wait the restructuring of the industry
now under way.
Taken together, these factors make it difficult
to establish the real financial needs of the railways. More efficient
maintenance and project management, returning to the (substantially
more efficient) British Rail days, will tend to reduce the funding
required, but against this, the backlog of underinvestment seems
likely to require more funding. We believe that the Government
should be prepared to make more public money available to the
railways if this is necessary. In particular, new regulatory requirements
for safety should be subject to additional funding.
9. Subject to this, we believe that the
plan's emphasis on rail funding, on addressing the backlog in
road maintenance, and in funding local transport plans is correct.
We do however disagree with the plan's approach to new road construction.
Some £30 billion is allowed for this over the next 10 years;
it has been pointed out that this would amount to a larger roads
programme than that envisaged or delivered by the 1989 White Paper
"Roads for Prosperity". The Plan is extremely unspecific
about the roads envisaged for funding; indeed, the "360 miles
of motorway widening" mentioned in the summary of the plan
turns out to be a top-down figure derived from the modelling,
which requires widening of 5 per cent of the motorway network
to meet the congestion reduction target.
10. It is worth restating why we believe
that such a road programme would be wrong:
— It won't work: in congested conditions,
new roads simply fill up with traffic as people use them to make
longer commuting, shopping or leisure journeys. So we will end
up with bigger, wider traffic jams. A recent US study found that
the US cities with the most road building had the worst congestion.
The current bottlenecks will simply be replaced by new ones, as
traffic pours off the main roads into already congested towns
and cities and villages.
— It would worsen rather than solve
our transport problems: Britain is already the most car-dependent
country in Europe; road building on this scale will simply continue
and worsen this. It will also reduce the viability and funding
available for public transport and railfreight and reduce walking
and cycling (as people replace short distance trips for longer
ones by car). This will increase social exclusion for those without
access to a car.
— It would be extremely environmentally
destructive: the extra traffic will divide communities. The likely
schemes would affect large numbers of sensitive environmental
sites, take significant greenfield land and would act as huge
barriers across the country; some would affect flood plains. The
extra traffic generated and catered for by these roads will also
add to climate change, potentially overrunning the benefits from
cleaner fuels and vehicles (the plan admits that road building
will generate 0.1 million tonnes of carbon, but this ignores any
traffic generated by these roads beyond 2010).
— It would lead to large scale car-based
development: the extra roads will tend to attract new developments
around them, which the planning system will not be able to stop.
These developments will not be accessible for those without cars,
and will themselves generate extra traffic, so adding still further
to congestion and social exclusion.
11. The problems with the road investment
envisaged in the plan can be illustrated through the multi-modal
and roads based studies, from which many of the road schemes are
expected to emerge. Transport 2000 has detailed knowledge of the
multi-modal and roads-based studies. Environmental representatives
are on the steering groups of each study and we have co-ordinated
these representatives. We believe that the studies are being implemented
in a highly variable way, and are unrelated to the targets and
objectives in the 10 Year Plan. They do not, for example, look
at how the Plan's targets to reduce congestion and pollution or
to increase the use of rail, buses and cycling can be met within
those areas. There are a number of other problems with the studies:
— They don't define the problem properly:
in a number of the studies, there has been a lack of real analysis
of the causes of problems —eg where accidents happen and
how they are caused, or the origin and destination of traffic
on the roads in question. The problem has generally been defined
by many of the studies as how to cater for ever growing demands
for car and lorry traffic and movement, rather than how to improve
access or address safety and environmental issues. Traffic growth
to saturation levels (ie around or above Los Angeles levels of
car ownership and use) is, as we note below, taken as given. The
studies, and the guidance from Government on how to run them,
also tend to overplay the economic benefits of large-scale road
building and underplay the environmental and social impacts. Some
studies are still making assumptions that new transport infrastructure,
and particularly new roads, automatically have economic benefits,
despite the SACTRA [Standing Advisory Committee on Trunk Road
Assessment] report (Transport and the Economy, 1999) which concluded
that this is not necessarily the case.
— They have not considered seriously
many of the alternatives to major road building. Most studies
have included passenger rail and light rail schemes, but many
have not looked sufficiently at other options, including:
Rail freight has not been properly considered
by many of the studies, even where there is a lot of long distance
or bulk road freight. Demand management options such as tolls
on motorways and congestion charging, with the revenue raised
paying for public transport, have been seriously considered by
some studies but not others, yet where they have been looked at
appear to perform well in dealing with traffic problems. And other
options, such as employer travel plans, car sharing, safe routes
to school, cycling and walking have been ignored altogether in
most of the studies. Instead, many studies have focused on road
building. In the case of the roads-based studies particularly,
old schemes, some planned for more than 50 years, have resurfaced
in identical terms, with only cursory re-examination of the case
for them or for alternative options.
— The computer traffic models assume
growth of traffic to Los Angeles levels The Government has rejected
a national traffic reduction target, and has focused instead on
the problems from traffic, defined as congestion and pollution.
But transport modelling is still focused on traffic levels and,
in the absence of any limit on growth, some of the studies and
the models they use have reverted to using the 1997 National Road
Traffic Forecasts, which project 65 per cent growth in traffic
over the next 30 years. In effect, some studies are using this
as a prediction and are trying to provide the road space to cater
for this growth. This is the "predict and provide" philosophy,
which the Government has rejected in policy terms. The studies
also seem to ignore traffic generating effects of new roads, despite
a lot of detailed evidence that road building generates extra
traffic. In particular, the models do not seem to take account
of changes in destination (people in Nottingham shopping in Sheffield
as a result of a less crowded M1) and mode (people driving to
out of town shops rather than walking or taking buses to metro
stores or local shops)
The studies have also highlighted problems with
delivering non-road options. While many of the studies have suggested
non-road options, especially rail service improvements, we are
concerned that if delivery of these proves to be more difficult
than road schemes, supposedly balanced packages of road and public
transport schemes could be picked apart and the roads get built
while the other elements do not happen. This concern about delivery
has fed back into option identification: the Strategic Rail Authority
has downplayed possible rail options during the studies because
of the calls on its budget.
12. As a result of all these problems with
the studies, many of them are coming up with very large road schemes,
involving widening motorways to 10 or 12 lanes, upgrading of A
roads to motorway or near motorway standard, and some new construction.
Examples of options or schemes suggested include widening all
or some of the A1, M1 and M6 into 10 or 12 lanes, the widening
of the A303 in Somerset, new bypasses of Stourbridge and Wolverhampton
through the Green Belt, full dualling of the A66 across the Pennines
and new orbital roads outside the M25 in Hertfordshire and Essex.
National Parks or Areas of Outstanding Natural Beauty that could
be affected include the Blackdown Hills, Cranborne Chase, the
North Pennines and the Broads. On top of this, the Government
has yet to decide on some other trunk road schemes, including
ones in the Cotswolds and the Lake District, and we are concerned
that some of these will generate further pressure for road building
in adjacent areas. The regional assemblies or chambers, which
make recommendations on the studies, have no incentive to question
the justification for schemes, because the Government, rather
than the assemblies and their constituent authorities, will be
paying the bills.
13. This is not to oppose all road building;
we believe, and have argued on some of the studies, that some
road building is appropriate and sensible. However, the revival
of old schemes generated by the multi-modal and roads based study
process will give priority to roads in the wrong places and at
the wrong scale. One way to address at least some of these problems
would be for the £60 billion roads allocation in the 10 Year
Plan to be used for non-road options identified in the studies,
with funding for them going to the SRA or local authorities accordingly.
The Government needs to be robust in treating the studies as inputs
to policy-making, and to rejecting schemes that are badly justified
or which will be environmental destructive or socially divisive.
14. As already noted, we welcome in general
the funding devoted to local transport. However, there are problems
here too. The Plan excludes current local authority revenue spending
and grants through Revenue Support Grant. Yet, in many cases,
revenue funding for operations or extra staff may be the highest
priority and most appropriate response to transport problems.
Lack of revenue funding affects local transport in many ways.
First, as already noted, there is a shortage of skilled staff
at local authority level and this means that schemes involving
significant public consultation and staff time will be delayed
or are less likely to happen than capital intensive schemes. Second,
the capital funding or borrowing powers given to authorities by
the Government excludes many useful and necessary schemes or programmes,
and authorities then spend a lot of time trying to "capitalise"
revenue spending. By contrast, schemes of over £5 million
get separate allocations and go through a separate approval process.
This is sensible at one level, in ensuring that bigger schemes
get fully justified, but it means that authorities tend to give
more attention to these schemes. All this means that in practice,
programmes of small scale schemes, such as safe routes to school,
or small scale safety schemes, are less likely to be implemented
than big capital intensive projects. Stoke-on-Trent Council, for
example, receives four or five requests for traffic calming every
week and has a long waiting list of schemes. Yet we know that
under the Government's own cost benefit analysis many of these
schemes are very good value for money. Small scale safety schemes
have benefit:cost ratios of 7:1 or more, whereas road schemes
are funded with BCRs of 1.5:1 or even less. And, as we note below,
packages of small scale schemes may do better at dealing with
traffic problems than big projects. We would like the Government
to encourage and enable local authorities to bundle packages or
programmes of small projects together so that they can receive
appropriate funding and attention. We are also concerned that
the move towards a Single Capital Pot for local authority spending
and funding may disadvantage transport at local level, as it did
in Scotland. We would like to see the Government monitor this
to ensure that councils keep to their commitments in local transport
plans.
15. There is a particular problem with funding
for bus services, which is uncertain and in many cases simply
unavailable. Under the current system, bus funding is not even
given a separate allocation in Revenue Support Grant and has to
compete for funding in the "other services" block with
other non-statutory services such as libraries and some social
services. This comes at a time when councils are facing increases
in tender prices for supported bus services (averaging 21 per
cent in the last year, according to the Association of Transport
Co-ordinating Officers) and also pressure to support more services
as more marginal commercial services are withdrawn by bus operators.
To their credit, many local authorities have increased their funding
for bus services despite the lack of allocated grants, but the
situation is patchy. We would like to see five year revenue funding
arrangements for local authority transport, especially for bus
services, to match the Local Transport Plan capital funding arrangement
already in place. The bus strategies now required under the Transport
Act 2000 would make a good framework for such arrangements.
TARGETS
16. We are concerned about the targets adopted
in the plan. First, the congestion target has been widely criticised
(cf especially "Running to Stand Still", Dr P Goodwin
for CPRE, 2000) as being meaningless; Dr Goodwin argues that even
if the target were met, motorists would notice no difference.
Second, we believe that the plan's downplaying of traffic levels
is wrong. The Government argues that traffic per se is
not a problem; the bad side effects of traffic (congestion and
pollution) are the issues that need to be targeted. But this ignores
the effect that excessive traffic levels can have on communities
and individuals. Too much traffic divides communities and prevents
all sorts of socialising, for example informal support by friends
and neighbours for older and disabled people, and children playing
outside their houses. It also discourages walking and cycling,
especially by older people and children, leading to even more
car use for short journeys. All of this adds to social exclusion
for those living on or near roads with heavy traffic. We believe
that traffic levels are a good proxy for these "community
severance" effects. The Commission for Integrated Transport,
in its advice to Government in December 1999 on national road
traffic targets, recommended that the Government should set targets
to reduce traffic in the areas where most people live and could
aim to stabilise and ultimately reduce traffic elsewhere. The
Government has ignored this recommendation. We would therefore
like to see the Government adopt targets or benchmarks for reducing
traffic in the areas where most people live. These should be agreed
at regional level with the regional chambers/assemblies. For the
reasons already given, the Government should also develop a strategy
and targets for limiting the growth in traffic nationally, to
replace the use of the National Road Traffic Forecasts in road
planning.
17. We believe that it is possible to reduce
traffic levels. Pricing measures are one way to do this and all
the analysis suggests that they can be effective. Such pricing,
whether through congestion charging, parking charges or road tolls,
need not disadvantage travellers or the economy if the revenue
raised is recycled into other transport measures or into reducing
other charges and taxes. However, there are many other ways in
which traffic can be reduced, and, as noted in the comments on
roads and multi-modal studies, a full range of public transport
measures and improvements, involving increases in quality and
quantity of services and, in some cases, reduced fares, should
be considered. Reallocating road space to give priority to buses,
trams, cyclists and pedestrians can also be effective in improving
alternatives to car use while reducing traffic. But this is not
just about public transport and pricing—there are a wider
range of alternatives:
— employer travel plans, which include
options such as car sharing and teleworking, as well as cycling
and better bus services. Many of the country's best known companies
now have travel plans in place for their headquarters, and early
results from some of these suggest reductions in single person
car commuting of 12 per cent or more over just two years. Under
Government planning policy such plans are expected to become widespread
in the future. They can be supported by, for example, high occupancy
vehicle lanes or priority routes for cyclists and buses. Despite
the DTLR having promoted these widely, they are not treated as
mainstream in the 10 Year Plan or in individual schemes. In the
roads based studies such as Deeside Park Junctions or Blunsdon
near Swindon, where commuter traffic is a key issue, travel plans
have not even been thought about (and are apparently unknown)
by the consultants and officials.
— Safe routes to school, which include
options such as "walking buses" (making walking to school
safe and supervised) and new school bus services. In many areas,
school travel accounts for 15 per cent or more of peak hour car
traffic.
— Travel marketing, giving people personalised
travel information about public transport and other options. This
has been tried out in Perth, Australia, where it cut car traffic
by 14 per cent in an area more car-reliant than most of Britain.
— Walking and cycling could be an alternative
for many of the short car journeys that clog up local roads.
The DTLR has shown itself reluctant to model
packages of measures that might together reduce traffic. Such
packages could include public transport improvements, safe routes
to school, travel plans, area wide travelcards and bus priority
networks, paid for by increases in town centre parking charges
or road user charges. We would like to see the Government, in
revising the 10 Year Plan, seriously examine the total and cumulative
effect of such packages.
18. We have comments on other targets in
the plan:
— We support the targets for the growth
in passenger and freight rail use, but would like to see the passenger
target disaggregated to avoid an excessive focus on SE England.
We and others have suggested in evidence to the Committee's recent
rail inquiry that a 40 per cent growth in the use of rural railways
over the next 10 years is desirable and feasible.
— We believe that the bus target of
10 per cent growth is far too low; it could be met simply by growth
on current trends in London while bus use elsewhere declines.
— While we welcome the recent announcement
of a national walking strategy, in response to the Sub-Committee's
welcome report, we would like to see the Government set a target
to reverse the decline in walking, and to assess local transport
and other plans accordingly.
— We believe that additional targets
to reduce social exclusion in transport may be appropriate. The
plan's target to increase access to rural buses may be the right
approach and we hope the Government will develop this. The current
inquiry by the Social Exclusion Unit on transport should provide
the framework for this.
INTEGRATION
19. The connections between the Plan and
the Government's integrated transport policy have largely been
dealt with above. We believe that the Plan does not give enough
priority to social and environmental policy and is not integrated
enough with many other areas of Government policy, including the
promotion of welfare to work, brownfield development and social
inclusion. It downplays walking and cycling and small scale projects
at the expense of large infrastructure schemes. It significantly
backtracks on the 1998 Transport White Paper by downplaying measures
to manage demand for road transport and by ignoring the White
Paper's presumption that road building only be sanctioned once
other options had been fully tested.
CONCLUSION
20. We support many aspects of the 10 Year
Plan. However, we are concerned that some of its underlying assumptions
are unrealistic, its implied reliance on road building is undesirable,
and its downplaying of traffic levels unacceptable. There are
also problems with several of the implementation mechanisms for
the Plan. We would like to see these remedied when the Plan is
revised.
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