Memorandum by English Nature (TYP 46)
1. INTRODUCTION
1.1 English Nature is the statutory body
that champions the conservation and enhancement of the wildlife
and natural features of England. We do this by:
— advising—Government, other
agencies, local authorities, interest groups, business, communities,
individuals;
— regulating—activities affecting
the special nature conservation sites in England;
— enabling—helping others to
manage land for nature conservation through grants, projects and
information;
— enthusing—advocating nature
conservation for all and biodiversity as a key test of sustainable
development.
1.2 In fulfilling our statutory duties,
we:
— establish and manage National Nature
Reserves (NNRs);
— notify and safeguard Sites of Special
Scientific Interest (SSSIs);
— advocate to government departments
and others effective policies for nature conservation;
— disseminate guidance and advice about
nature conservation;
— promote research relevant to nature
conservation.
1.3 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues.
2. GENERAL COMMENTS
ON THE
10 YEAR PLAN
2.1 English Nature welcomes the opportunity
to provide the Transport Sub-committee with comments on Transport:
2010, the 10 Year Plan announced by the Government in July 2000.
The plan was an important milestone in establishing the direction,
scope and planned level of resources to be allocated to the delivery
mechanisms contained in the 1998 White Paper on integrated transport.
English Nature's interest is in ensuring that the Government's
transport policy takes full account of biodiversity and geological
conservation considerations.
2.2 With this inquiry our particular interest
lies in three of the topic areas identified in the Press Notice
for the inquiry, namely Implementation, Targets and Integrated
transport policy. We use these three sub-headings for our more
detailed comments provided under sections 3, 4 and 5 below.
2.3 In overall terms English Nature is supportive
of the aims and much of the content of the 10 Year Investment
Plan. In particular, we were pleased to see commitments to:
— the NATA/GOMMMS appraisal methodology;
— the early involvement of the statutory
bodies in the development of policies, programmes and schemes;
— the protection of environmentally
sensitive sites;
— the use of delivery mechanisms such
as Local Transport Plans and the Multi-Modal Studies rather than
a straightforward announcement of road schemes;
— an integrated approach with a significant
shift towards public transport.
2.4 We believe that the £180 billion
earmarked for transport investment under the plan should provide
sufficient resources for more imaginative, integrated solutions
to transport problems to be delivered with benefits for the travelling
public, communities and the natural environment. Recent and more
welcome examples of more environmentally sensitive solutions include
the proposed use of tunnels at locations with high quality natural
environments, such as at Hindhead in Surrey and at Stonehenge
in Wiltshire. The preferred route for the A30 at Indian Queens
in Cornwall (which currently passes through Goss Moor National
Nature Reserve) is another example of a more sustainable solution
to a transport problem and one we have been promoting as an example
of good practice.
3. IMPLEMENTATION
3.1 There have undoubtedly been problems
with delivering the plan and our comments about implementation
relate mainly to Multi-Modal Studies and to rail issues. We view
the Multi-Modal Studies as having a crucial role to play in finding
more environmentally-sustainable solutions to transport-related
problems. We are monitoring progress with the studies in order
to ensure that we have sufficient involvement as a statutory body
and that biodiversity considerations are being taken fully into
account in the appraisal process. The evidence so far is that
the situation is improving and that following some initial difficulties
we are now being properly consulted at a local level by those
managing and participating in the studies. We would still recommend
that the consultants for the studies are required to consult English
Nature's local teams on a regular basis throughout the life of
each study. There are still some teething problems with the appraisal
process and our perception is that there needs to be a greater
degree of quality control at the centre (ie within DTLR) in order
to ensure consistent application of the GOMMMS appraisal guidance
across all of the studies.
3.2 Another key issue is the recent and
on-going crisis in the rail industry. At present the absence of
a clear plan for future railway infrastructure and investment
and, in particular, a clear funding route for rail schemes means
that the Multi-Modal Studies and Local Transport Plans could end
up emphasising road solutions and thus blocking the desired shift
towards public transport provision. We believe that regional and
local authorities need the ability to secure dedicated funding
to deliver the rail component of a balanced transport investment
programme in order to avoid a situation where there is pressure
for "quick fixes" through road investment. This could
lead directly and indirectly to loss and damage to nature conservation
sites as outlined in our Position Statement on transport which
is annexed to this submission. Railtrack are a key player in the
inland transport sector from a biodiversity perspective as they
have an interest in over 150 Sites of Special Scientific Interest.
English Nature would like to see any successor to Railtrack appoint
an Environmental Director and be given a duty to promote sustainable
development and protection and enhancement of the natural environment.
4. TARGETS
4.1 There is a lack of defined targets and
a lack of clarity over their relationship with the Government's
own quality of life sustainable development indicators as a means
of measuring progress. In addition, we would support the views
of bodies such as Transport 2000 that the Government should set
targets for reducing traffic levels in areas where people live
and stabilising levels elsewhere. At the same time some of the
targets need to be more ambitious eg for growth in bus usage and
walking and cycling. A wholesale review of the targets is necessary
in view of the fact that many of the forecasts eg for funding,
passenger and traffic growth are now out-of-date and need to be
revised in the light of experience and changed circumstances.
4.2 We believe the targets must be able
to demonstrate that Transport: 2010 can sustain economic growth
whilst reducing overall transport growth, particularly road mileage,
through a package of measures including shifts to other forms
of transport, integrated land use planning, financial instruments
and the use of new technologies.
5. INTEGRATED
TRANSPORT POLICY
5.1 Integrated transport requires not just
integration between different transport modes but integration
across different levels of decision-making, integration between
transport and land-use planning and integration between environmental
and other policy objectives. We believe that there is much still
to be done in this respect and would encourage the use of the
regional institutions to integrate the spatial requirements of
the various sectors including transport. Again the integration
of decision-making over rail investment is required by Multi-Modal
Studies and Local Transport Plans.
5.2 The 10 year plan does contain a clear
statement that there will be a strong presumption against environmentally
damaging schemes and we are pleased that the Government appears
to be adhering to this commitment. The evidence is provided by
the decision to reject the two bypasses as part of the package
of measures for the Hastings Multi-Modal Study and the most recent
Local Transport Plan financial settlement announced in December
2001 in which 50 per cent of the major road proposals put forward
by local highway authorities were rejected whilst some other more
sensitive schemes were approved.
6. CONCLUSIONS
AND RECOMMENDATIONS
6.1 We understand that the Government is
committed to carrying out a review of the 10 Year Plan during
2002 and we would recommend that this should include a review
of the targets and the NATA/GOMMMS appraisal processes and be
undertaken in a consultative fashion rather than behind closed
doors within central Government.
6.2 Large-scale transport investment could
result in environmental degradation and a loss of biodiversity
even where more environmentally sound forms of transport, such
as cycle and rail networks, are being put in place. Wherever possible
we wish to work with the necessary stakeholders to avoid this
but, as an absolute minimum, we would wish to see the avoidance
of damage to special sites and protected species and, at best,
imaginative solutions to transport problems which integrate environmental
gain and biodiversity enhancements.
Environmental Impacts Team
English Nature
Peterborough
11 January 2002
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