Memorandum by Sustrans (WP 02)
SUMMARY
Sustrans welcomes the Public Health White Paper
"Choosing health: Making healthy choices easier". We
see it as a significant step towards a future in which government
funds are used to promote health and well-being right across the
population, rather than treating people after they have become
unwell.
We do however have real concerns about the delivery
process, based on the white paper itself and what we have seen
to date of the developing plans for its delivery. In a nutshell,
our concerns are:
that responsibility for delivery
of the white paper as a whole may be pushed out to the local-level
bodies of the NHS, to be executed through their local strategic
partnerships, but without adequate support, performance management
or resources from the top of the partner sectors; and
that the physical activity element
may be narrowed down to sport and recreation, and so largely devolved
to the Department of Culture, Media and Sport (DCMS) and the sport
sector.
We strongly urge that the other government departments
whose programmes influence public health and in particular physical
activity should step forward and ensure that both are central,
measured objectives in all their work. These departments include:
Department for Transport (DfT)
Department for Education and Skills
(DfES)
Office of the Deputy Prime Minister
(ODPM)
Department of Trade and Industry
(DTI)
Department of Work and Pensions (DWP)
Department for Environment, Food
and Rural Affairs (DEFRA)
Department for International Development
DfID)
As well as the Department of Health
(DH) and DCMS.
COMMENT
1. Sustrans is a practical transport charity,
which works to change the environment so that sustainable, physically
active ways of travelling are more accessible. Sustrans has over
25 years experience in creating environments for physical activity,
such as the National Cycle Network (NCN) programme, and changing
the transport culture to make it possible, as with Safe Routes
to Schools (SRS).
2. We work in partnership with the DH, DfT,
DfES, ODPM and others, national and regional agencies, community
groups, schools and business, and also with international bodies.
Our programme helps to deliver on government's policies and strategies
in areas including public health, communities, regeneration and
quality of life, and climate change.
3. Our comments below are restricted to
our areas of expertisetransport, planning, physical activity
and communitiesin consideration both of the white paper
itself and of its potential for effective implementation.
4. Over the last two years, we have worked
closely with government departments and a wide range of bodies,
to assist with the development of the Public Health White Paper
and associated policies, such as the DfT's excellent "Walking
and cycling: an action plan". In our view, the inter-sectoral
and cross-government collaboration which informed the development
of the white paper was its greatest strength; this gives reason
for optimism regarding delivery.
5. Our response to the white paper itself
is a positive one. It seems to build on the powerful arguments
advanced both by Derek Wanless and by reports from your own committee,
and to recognise two central facts:
that both public health and economic
arguments make it imperative to move from a "national sickness
service" to a health promotion service
and that only through a joint commitment
across many sectors of government and society can the big public
health issues be addressed with any real impact.
6. We are pleased to see a number of references
to the importance of the environment in determining people's levels
of physical activity, in terms of transport choice and also other
lifestyle choices. The white paper refers to the role of various
delivery partners in creating a more activity-friendly environment,
and we support this.
7. We specifically welcome the recognition
of Sustrans' flagship project, the National Cycle Network, as
playing a public health role. Since we reported to your obesity
inquiry, the NCN has grown by a third and usage has doubled to
over 125 million walking and cycling trips per annum in 2003.[3]
The 2004 results will be published in Spring; this year the NCN
will reach 10,000 miles in length, and we expect usage to grow
still further.
8. The DfT has made a one-off investment
this year, in a programme of links to schools from the NCN, in
partnership with local authorities. We expect these new local
routes to create new walking and cycling trips across the whole
community, not just for the school journey. The reference to this
investment in the white paper gives the impression of a multi-year
programme, which could eventually address thousands of schools.
We urge that DfT should continue the investment in this way, and
that the other relevant departments and sectors, notably DfES,
ODPM and DH, should support it.
9. You have asked contributors to consider
whether the proposals within the white paper will enable the achievement
of public health goals, be appropriate, be effective and be good
value. Here, we find ourselves unable to respond, because in our
sectors the white paper does not list sufficient detailed proposals.
It lists a number of examples of interventions which, in the main,
we support.
10. Our most significant concern is that
the white paper does not specify how other government departments
and agencies will assume their responsibilities for improving
public health. This deficiency has been yet more marked in the
first stages of the process towards delivery, which has disproportionately
focused on the role of local NHS bodies, working through local
strategic partnerships. The NHS at local level will doubtless
play a very significant role in improving public health in many
of its facets. However, it is most unlikely to be able to bring
about significant and sustained change in areas such as the choice
of active travel or the active use and enjoyment of community
space, unless supported by national policies and programmes. The
relevant government departments will need to create new legislation,
new guidance, new performance management targets, and new or expanded
financial commitments.
11. While other government departments,
such as the DfT, have lead responsibility each in their own area,
there is a need for clear statements of commitment as to their
relationship with the DHfor example, in sharing funding
flows and performance management.
12. Therefore, to address your third area
of interest, while we have no qualms about the quality and authority
of the existing public health infrastructure and mechanisms, we
note that these pre-date the multi-disciplinary approach to public
health which pertains today. To address the issues of public health
today, a number of sectors must act, jointly and severally, from
government down to the local level. We address below areas of
activity for each.
13. ODPM, planning bodies and professionals
and local government need to address the location and accessibility
of services and the removal of barriers to physically active travel.
People need access to key services including healthcare, shops,
work, schools and social activities.[4]
The location of services where access is only easy by car promotes
a sedentary lifestyle and helps to `lock in' car dependence. This
also worsens social exclusion.
14. Measures should be taken by the above,
with DfT and the transport sector, to make the street environment
safer and more pleasant for pedestrians and cyclists and a place
for children to play. The development of Home Zones in residential
areas and other such urban redesign should be made a priority.
The perception of traffic risk is a major impediment to cycling,
in particular, for many people, and our failure as a society significantly
to reduce the incidence of death and injury among cyclists and
pedestrians suggests that the individual risk assessment is well
founded.
15. The HO and police forces should move
to more complete and stringent enforcement of traffic laws, reducing
the danger andas importantthe threatening nature
of the road environment, which suppress walking and cycling. Illegal
and inappropriate speed, drink driving and the use of mobile phones,
pavement parking and a still widespread disregard of vulnerable
road users combine to dissuade all but the hardiest from cycling,
in particular.[5]
16. In this context we very warmly welcome
the excellent new Roads Policing Strategy statement by the Association
of Chief Police Officers, the DfT and the HO.[6]
We urge the three bodies to do all in their power to deliver on
it, and in addition we recommend a communication programme, to
address the often negative and ill-informed media treatment of
measures to improve enforcement and save lives.
17. The HO and police forces should continue
and redouble their offensives against other forms of anti-social
behaviour, which deter many people from using public space. Please
note that the public themselves identify speeding traffic as the
anti-social behaviour that most affects them, and inconsiderate
parking as their number two concern.[7]
18. Since you considered similar issues
in your obesity inquiry, the DfT has abandoned the targets in
the National Cycling Strategy for increased cycling levels in
the UK. The failure of successive administrations to commit adequate
resources to their achievement has meant that the targets are
now unlikely to be met. However, levels of cycling in comparable
European countries are significantly higher than in the UK,[8]
and there seems no real reason to doubt that we could match them.
The National Cycling Strategy Board has assembled a detailed plan
to address the promotion of cycling at a national level.[9]
We recommend that the DfT should adopt and fund this programme,
reintroduce national cycling targets, and performance manage its
agencies and local government on their achievement, and that the
remainder of the transport sector should assist.
19. Similarly for walking, we urge the DfT
to set targets for walking growth, and work with the rest of the
transport sector to meet them.
20. In both of these cases, the targets
should be integrated with the public health targets to increase
levels of physical activity.
21. The above, and particularly a planned
programme to increase levels of walking, will require improvement
to the current systems and methods used to measure travel choices.
We are presently working with statisticians at DfT and other bodies
to address this question and, we expect, to introduce more robust
and accurate methodologies to monitor and evaluate walking and
cycling. DfT and others should give this priority.
22. We do welcome the awareness of public
health in the new Local Transport Plan guidance to local highways
authorities from DfT, which states "many Local Strategic
Partnerships identify public health outcomes as key local priorities
and LTPs should contain evidence that authorities are reflecting
such"[10].
We agree: the LTPs should contain this evidence, and the DfT should
take care to reward highway authorities which do so, and prompt
thosewhich do not.
23. We strongly welcome the commitment to
build on the DfT's Sustainable Travel Towns pilots, but recommend
a much stronger follow up to these pilots than the "guidance"
proposed in the white paper. The failure of the DfT and DH to
ensure the inclusion of strong health promotion elements in the
three pilot towns is a sad missed opportunity, which will undoubtedly
mean that the beneficial outcomes identified by the Health Impact
Assessment will be less than they could have been. This should
now be addressed by at least one intensive "healthy travel
town" intervention, involving significant change to the physical
environment as well as behavioural measures, which should be co-funded
by the two departments.
24. There are currently a number of incentives
to unnecessary use of sedentary forms of travel, such as financial
support for car use, free car parking etc. It is still, unfortunately,
quite conventional for a hospital or school to provide free or
subsidised car parking for staff or visitors, while offering no
comparable benefit to people who travel actively. The costs of
this to the business may not be identified, no management decision
may ever have been taken, and no one may have considered how inequitable
or unhealthy is the situation. This problem needs to be addressed,
across the sectors of DfT / transport, DTI / industry, DfES /
education, and of course the NHS should without delay put its
own house in order.
25. In this context we strongly welcome
two commitments in the white paper:
the consultancy service to be provided
to government departments by Sport England, on becoming "active
workplaces"; it is most important that this should include
active travel to work, and that it should be rolled out to all
government buildingsnational, regional and local; and
the commitment to support the Sustainable
Development Commission's "Healthy Futures" programme,
which should if fully implemented tackle the current unintentional
promotion of motor travel by the NHS.
26. We recognise and admire the initiatives
taken by the DfES and education sector, including those in collaboration
with the DfT and transport bodies, to promote physical activity
and health in schools, including active travel initiatives. We
urge these partners to redouble their efforts and to expand these
activity initiatives into further education.
27. The white paper contains a number of
references to the importance of sport; in principle we support
this, but we are concerned that physical activity and sport are
often treated as though they were interchangeable terms. Sport,
in fact, despite having significantly higher profile and greater
resources than other forms of physical activity, accounts for
less than 10% of the activity enjoyed by the one third of the
UK population currently physically active (see graphic below).
It may be less attractive than other activities, such as walking
or gardening, to the currently sedentary,[11]
where the greatest health gain through physical activity is achievable.[12]
The contribution of the various types of activity and their relative
importance should be clearly recognised and stated.

28. In this context therefore, we are seriously
concerned by hints that the promotion of physical activity may
be devolved to the DCMS and the sport sector. We strongly urge
the DH and other government departments to each assume the responsibilities
of their sectors for public healthboth physical activity
and areas such as pollution reduction.
29. In the areas of transport and physical
activity, as in a number of others outside our field, there are
clear shared objectives with sustainability, emissions reduction
and the battle against global climate change. Climate change,
in particular, carries very significant public health risks for
UK residents and the rest of the world. We therefore urge that
the DEFRA and environment sector should work more closely with
those now active in public health to achieve on these shared agendas.
30. We are concerned that legislative and
taxation avenues seem to have been under-emphasised. We would
urge that the Treasury review the tax regime on motoring and fuels,
which have seen the real cost of motoring fall consistently over
past decades. We also recommend that consideration be given to
positive fiscal incentives to healthy behaviourfor example,
schemes by employers to promote active commuting.
31. In the area of regulatory impact, we
welcome the commitment to "build health into all future legislation
by including health as a component in regulatory impact assessment".
We trust this will include health impacts of legislation on transport
and land use, traffic law, motoring and fuel taxes etc. These
include traffic danger, local air pollution, accessibility of
services by physically active travel modes, subsidy to sedentary
modes, and so on.
32. Many of the trends in public health
are international, and the UK has responsibilities with regard
to public health beyond our shores. We urge that the DfID should
incorporate public health impacts and measures more clearly into
its work, and that the international aid and liaison sectors should
give increased priority to considerations such as minimising air
pollution and climate change emissions.
33. One concern we feel we should raise,
across all sectors, relates to the scale of national implementation.
Derek Wanless said "After many years of reviews and government
policy documents, with little change on the ground, the key challenge
now is delivery and implementation, not further discussion".[13]
We feel that the time for local pilots and the selection of certain
PCTs as "spearheads" may simply delay the delivery of
the many benefits promised by the white paper, and so we urge
full-scale implementation, by all relevant sectors, and a high
level of investment; we believe that simple cost-benefit calculations
can justify much more than the £1 billion figure currently
mooted.
34. We look forward to clarification of
the New Burdens Doctrine, and urge that it be made as strong and
progressive as possible. Not only should local authorities be
reimbursed for additional expenditure incurred in promoting public
health, but those authorities which most actively take the lead
should be rewarded with bonuses.
35. Across all sectors, a good example (including
cycling and walking) should be set by political, administrative
and business leaders.
36. Active, on-going promotion is needed
of healthy and active behaviour, using promotional and media campaigns
and individualised marketing interventions.
37. Intensive and transparent health impact
assessment should be demanded on all transport and major land-use
proposals and policies. All new projects should demonstrate real
health benefits, taking into account not only their effect on
pollution levels, traffic danger etc, but also their impact on
the habits and lifestyle of affected people, both travellers and
neighbours.
38. Sustrans wishes the committee well in
its deliberations and would be happy to give oral evidence, or
to provide any additional information required, in whatever form.
January 2005
3 National Cycle Network Route User Monitoring Report
to end 2003, Sustrans, 2004. Back
4
Making the Connection: Final Report on Transport and Social Exclusion,
Social Exclusion Unit, 2003. Back
5
House of Commons Transport, Local Government and the Regions
Committee: Ninth Report of Session 2001-02, Vol 1, on Road Traffic
Speed. Back
6
Roads Policing Strategy, Association of Chief Police Officers,
DfT and Home Office, 2005. Back
7
Perceptions and Experience of Anti-Social Behaviour: Findings
from the 2003-04 British Crime Survey, Home Office Online Report,
2004. Back
8
National Cycling Strategy, Department of Transport, 1996. Back
9
Bike for the Future, National Cycling Strategy Board, 2004. Back
10
Full Guidance on Local Transport Plans: Second edition, Department
for Transport, 2004. Back
11
Active travel as physical activity promotion, Sustrans, 2004. Back
12
Changes in Physical Fitness and All-cause Mortality: a prospective
study of healthy and unhealthy men, Blair et al, Journal
of the American Medical Association 273, 1995. Back
13
Securing Good Health for the Whole Population, Derek Wanless,
2004. Back
|