Further memorandum by CPRE (RP 06A)
ROAD PRICING
INTRODUCTION
1. The Campaign to Protect Rural England
(CPRE) welcomes the opportunity to contribute to the Select Committee's
inquiry into road pricing. We have already submitted evidence
on the M6 Expressway, which details our opposition to that concept.
This evidence focuses on the broader issues which the Committee
raises in the terms of reference for its Road Pricing inquiry,
but should be read in conjunction with our earlier specific evidence.
2. Rising traffic levels create significant
problems for the quality of life of both urban and rural communities.
Emissions from the transport sector represents a major challenge
to the Government's aspirations to tackle climate change. And
the congestion which results from the incremental rise in traffic
volume is a driver for much road building which threatens to scar
the countryside and erode rural tranquillity. CPRE therefore welcomes
the renewed emphasis which is now being placed on road pricing.
3. We have long advocated the use of demand
management measures, such as charging and parking levies, as an
important part of an integrated sustainable transport policy.
There is growing recognition that we cannot simply build our way
out of the problems of traffic growth and congestion. This is
based not only on an appreciation of the significant environmental
damage which would result to landscapes and wildlife, but also
because experience has shown that adding new capacity through
widened or new roads frequently induces traffic, and therefore
does not work in narrow transport terms either.
We also recognise that we cannot
simply build our way out of the problems we face. It would be
environmentally irresponsible—and would not work.
Prime Minister, Tony Blair MP, 2004
4. Reducing the need to travel through effective
land use policies is important, as is investing in alternatives
like public transport. There is considerable unrealised potential
in both these areas. But they are unlikely to be enough on their
own. Indeed, such measures could very well be undermined by the
falling costs (in real terms) of motoring. CPRE believes, therefore,
that national road user charging has an important role to play
in helping manage the spiralling demand for travel. We welcome
the opportunity to contribute to the national debate.
POLICY OBJECTIVES
OF ROAD
PRICING
5. Before addressing the specific questions
of which roads should be priced, and the details of any scheme,
CPRE believes it is important to gain consensus on the policy
objectives which are to underpin road pricing. We do not believe
that a consensus yet exists and hope that the Committee's inquiry
may address this issue. While the Government commissioned Feasibility
Study was given a number of objectives, we believe the national
debate needs to consider whether these embrace the range of issues
which arise. CPRE would highlight the need for road pricing to:
— reduce both traffic levels overall
and people's experience of congestion;
— demonstrate that it will lead to
substantial reductions in greenhouse gas emissions from transport;
and
— be undertaken in such a way as to
reinforce, rather than undermine spatial planning objectives.
6. The Government's Feasibility Study, the
CFIT report Paying for road use which predates it, and
work by the Independent Transport Commission all rely on work
undertaken by the Institute of Leeds (ITS)— Surface Transport
Costs and Charges: GB. This is considered to be the most comprehensive
work on the subject of evaluating externalities in transport appraisal.
CPRE is concerned that some of its conclusions, however, have
been overlooked by transport commentators with potentially serious
consequences. The ITS Leeds study concluded, for example, that
motorists do not currently pay for all the costs they impose on
the environment and society. There are also important effects
from traffic (for example severance of communities, impact on
the character of the countryside and water pollution) which are
not counted. If road pricing is restricted only to internalising
the costs of what can easily be measured, however spuriously,
then the importance of these other issues will be underplayed.
We urge the Committee to consider how these less tangible effects
of traffic might be accounted for in road pricing.
7. The ITS report is now six years old,
and we believe it will be important to examine the work to ensure
the values used within it remain valid. We are aware, for example,
that Defra is undertaking a review of the costs of carbon as part
of preparation for the Clime Change Programme review. It is hoped
that such work will feed directly into the Department for Transport's
thinking on road pricing.
Congestion or road user charging: urban, or urban
and rural?
8. Behind all the analysis on externalities,
the key question remains which is what is road pricing for? CPRE
is concerned that the Government is too narrowly focused on congestion
reduction in its thinking on road pricing. This has meant that
the modelling, analysis, and assessment of desirable outcomes
neglect other important issues worthy of consideration. The reluctance
of the Government to address rising traffic levels through fuel
duty has exacerbated this problem.
9. CPRE is concerned that the focus on current
and forecast levels of traffic and congestion is leading to short-term
solutions being advanced. The strategy seems to be to use a number
of means to spread traffic levels temporally and geographically
in order to tackle congestion. Thus, measures are proposed for
encouraging motorists to travel off-peak and to avoid congested
motorways and urban areas. While this seems attractive at a superficial
level, CPRE is concerned that the longer-term implications of
such an approach are not being properly considered.
CPRE fears Government policy could
transform today's acute problem of congestion into tomorrow's
chronic problem of too much traffic on the roads, affecting more
people, throughout the day.
10. We fear that Government policy could
simply turn an acute problem (of too much traffic leading to congestion
on specific parts of the network at particular times of day) into
a chronic one which afflicts a wider area and more people for
more parts of the day. The latter problem would in all likelihood
be even harder to address.
11. Various studies have suggested that
prices on rural roads should fall, on the basis that congestion
is largely limited to honeypot tourist sites. CPRE believes that
this risks threatening the character and tranquillity of the countryside,
further reinforcing car dependency and potentially undermining
public transport provision in rural areas. While supporting the
principle of charging, therefore, CPRE would be concerned if the
design of any specific scheme led to a flood of additional traffic
to the countryside. The inadequacy with which this issue is addressed
is illustrated by the fact that the Government's Feasibility Study
simply examines the effect of pricing on (a) all roads, (b) urban
roads, and (c) inter-urban roads. It does not set out the effect
for rural roads specifically, or distinguish between motorists
travelling in the moors of Northumberland, from those in the suburbs
of Surrey. The study explains that " . . . urban roads would
be priced at a higher rate than rural ones, because it is in urban
areas that congestion is worst" (paragraph 4.26). CPRE does
not dispute this statement, or the need to tackle congestion,
but believes that rural traffic management issues currently represent
a serious blind spot in Government thinking. A failure to embrace
them as part of thinking on road pricing could store up considerable
problems for the future and seriously damage the character of
the countryside.
12. In order to avoid this situation it
will be necessary to consider (a) the magnitude of a charge relative
to existing prices, and (b) the relative difference in charges
for urban and rural routes. Careful analysis will need to be undertaken
to ensure the charges set do not have perverse environmental effects
on the countryside. We have not seen much evidence of these issues
being addressed. We hope the Committee will investigate how work
on road pricing will be "rural proofed". This should
include using the Government's definition of urban/ rural areas
in its analysis rather than the very broad definitions for rural
roads currently used. To help avoid perverse effects, CPRE believes
road pricing should be based on a standard rate per vehicle km
to address the effects of traffic and journey length on the environment,
with supplements being payable to cover congestion.
13. If charges were rigidly set around reducing
congestion, and therefore lower or exempt on rural roads, we fear
this would create an economic incentive to locate business premises
in more rural locations, undermining the urban renaissance. This
would conflict with policies in the Urban and Rural White Paper
and planning policy (as set out in Planning Policy Guidance note
13: Transport). The Commission for Integrated Transport
in Paying for Road Use 2002 identified the effects on land
use as an area in need of further work. The Government's Feasibility
Study, however, simply concludes, "we have learned that the
long-term effects of pricing schemes, for example, on land use,
are very difficult to predict". We believe this points to
the need for more urgent work to be undertaken, and for safeguards
to be put in place to ensure future road pricing does not undermine
efforts to deliver an urban renaissance.
A failure to appreciate the long-term
implications of road pricing for land use changes could have a
profound effect on the overall success of any scheme. We hope
that the Committee will wish to explore this issue during the
course of its inquiry.
14. A further difficulty is that a focus
on alleviating congestion as the primary focus of road pricing
also assumes that there is a consensus on how to measure congestion.
The recent Transport White Paper indicated that the Government
has still not identified a suitable measure for inter-urban congestion.
And work undertaken previously by Professor Phil Goodwin for CPRE
(in Running to Stand Still, 2001) indicated the discrepancy
between technical measures of congestion and the reality of people's
experiences on the road network. Achieving consensus on this will
be necessary for future progress.
PRICING ALL
OR SECTIONS
OF THE
ROAD NETWORK
15. CPRE believes the ultimate objective
should be to introduce national road user charging covering all
roads. This would overcome issues around boundaries and diversion,
assist in delivering compatibility and consistency of approach,
and ensure particular authorities were not able to "opt out"
of charging schemes. CPRE foresees a number of dangers of focusing
too heavily on local road pricing:
— central Government may prefer to
see the hard political battles fought out locally and so lose
its nerve in introducing a national scheme;
— numerous debates around local road
pricing are likely to be inefficient, consuming energy discussing
issues which could more easily be resolved through a national
scheme (eg cross-boundary issues, use of IT);
— the temptation to undertake monitoring
of pilot local schemes could put back further the start date for
the introduction of any national scheme;
— it could lead to a focus on tackling
individual congestion hot spots rather than the systemic problem
of rising traffic levels across the country; and
— it could generate problems of traffic
diversion, damaging rural areas, unless carefully implemented.
16. Nevertheless, as the earliest which
national road user charging could be introduced is in 2014, action
is urgently needed today to address traffic and congestion problems
and we welcome the emphasis in the Draft Guidance on Local Transport
Plans on traffic authorities promoting demand management measures.
Because of the dangers of diversion, CPRE hopes that priority
will be given to developing area-wide charges, rather than tolls
for individual sections of road. We also believe this should be
focused on tackling existing roads, not as an excuse for a large
new road building program on the lines of the M6 Expressway.
THE ROLE
OF LOCAL
HIGHWAY AUTHORITIES
IN INTRODUCING
ROAD PRICING
17. CPRE believes local highway authorities
have an important role to play in helping develop road pricing
and hopes authorities will include measures in their second round
Local Transport Plans. We are not optimistic, however, that sufficient
numbers of authorities will include demand management policies
in their LTPs. In part, this is because of the concerns which
authorities hold that this will make them less competitive against
their neighbours. Despite evidence showing that charging and roadspace
reallocation schemes can improve the liveability of areas, this
concern remains a serious obstacle. A critical mass of willing
authorities is needed to break through this barrier. Yet, many
authorities may in fact slow their plans on introducing charges
because of the prospect of a national scheme being introduced.
CPRE has witnessed a number of authorities who have been reluctant,
for example, to introduce Quiet Lanes (despite interest in the
measure) because of the lack of national Regulations. This scenario
should not be replicated for road pricing.
It is essential that the introduction
of road pricing does not stall as central Government and local
highway authorities vie to be the last to introduce it.
18. It is inevitable that local charging
schemes will encounter some difficulties over the effect in the
charged area compared to neighbouring authorities. There is a
critical role, therefore, for Regional Planning Bodies to provide
the necessary strategic input into such debates. The potential
for this is greater through the introduction of spatial planning
with its increased emphasis on managing existing land and resources
rather than just change of land use.
19. We are concerned that to date, however,
regional assemblies have tended to focus on identifying wish lists
of infrastructure schemes, rather than demand management measures.
This is illustrated in the East of England Draft Regional Strategy
2004, where 37 new road building proposals either have already
been committed to or supported in accompanying strategies. "Area-wide
road charging" is included as "under investigation"
(along with approximately 21 other road proposals). Interestingly,
the lead body for implementing this mechanism is not the local
highway authorities, or the Highways Agency, but the Department
for Transport. If road pricing is to take off in the next five
to ten years it will be necessary for the DfT to provide a clear
timetable towards national implementation, and to send stronger
signals to regional assemblies over their role in delivering demand
management measures rather than lots of new infrastructure.
20. While central Government is encouraging
local highway authorities to introduce road pricing for local
roads, the same is not true of Highways Agency schemes. The "Orbit"
Multi-Modal Study considered, for example, the M25 corridor and
recommended widening the existing motorway, accompanied by charging.
While the Government has given priority to M25 widening, as part
of the Targeted Programme of Improvements, CPRE is disappointed
that it has not proposed area-wide charging. This represents an
inconsistency of approach, and CPRE urges the Committee to address
this issue during the course of its inquiry.
THE TRANSITION
TO NATIONAL
ROAD USER
CHARGING
21. The transition from local schemes to
a national road user charging scheme is important, and needs careful
forward planning. We believe the DfT can assist by:
— setting out an indicative timetable,
with incremental steps to illustrate when road pricing will be
introduced on a national basis;
— ensuring that IT systems are compatible
or can be easily amended in order to support national charging;
— engaging local and regional stakeholders
in the development of the national charging scheme so that practical
experience can be shared; and
— support local authorities who are
developing interim cordon charging schemes.
OTHER MEASURES
TO REDUCE
CONGESTION MORE
EFFECTIVELY
22. CPRE believes road pricing has an important
role to play in future transport policy, but that it can only
ever be one part of a wider strategy. Action needs to be taken
now to manage existing levels of traffic and congestion. But it
is essential that decisions made in the future do not exacerbate
the situation.
Tackling congestion is as much about
what not to do, as what to do. Decisions made today on planning
and transport infrastructure could have a profound effect in influencing
future transport trends which road pricing would need to address.
23. We highlight the following important
factors in determining future traffic growth:
Road building: while additional
capacity might, in some instances, provide short term benefits,
the damage to the countryside is lasting. The Government has also
recognised that providing new capacity will not deliver long-term
benefits in terms of alleviating congestion. For this reason,
it would not be sensible to see road pricing as a measure for
"locking in" the benefits of new road building. Such
an approach ignores the wider effects of new infrastructure, and
the potential traffic problems created elsewhere on the transport
network.
"We will not address
the long-term risk of higher congestion just by adding new capacity
even if it is tolled" Transport White Paper, 2004.
Housing development: as
has already been recognised by the ODPM Select Committee in their
8th report, the Government's Communities Plan threatens to generate
significant additional traffic. The implications on the trunk
and other road network from the house building proposals in the
Barker Report on housing supply, have not been quantified. Implemented
this level of house building would generate significant additional
traffic, much of it in areas already experiencing congestion.
Fuel duty: decisions over
future fuel duty will, in the interim, send important signals
to motorists. CPRE has been concerned that short-term rises in
the price of oil has led the Government to stall increases in
fuel duty, and there seems little motivation to arrest the decline
in motoring costs. Indeed, we understand that the Transport White
Paper continues to be predicated on a scenario of falling motoring
costs.
24. There are a variety of ways in which
action can be taken to deal with existing congestion problems.
The DfT's paper, Smarter Choices: Changing the Way we Travel
2004, highlights the significant potential which "soft
factors" can play in reducing congestion. These can be delivered
more quickly and at less environmental and financial cost. We
believe these should be central to the Government's transport
strategy. However, as the report notes, "those experienced
in the implementation of soft factors locally usually emphasise
that success depends on some or all of such supportive policies
as reallocation of road capacity . . . congestion charging or
other traffic restraint . . .". It would be dangerous, therefore,
to promote the "smarter" choices agenda in absence of
specific demand management measures. They should be seen as complementary
to road pricing.
25. The recent National Audit Office report,
Tackling congestion by making better use of England's Motorways
and Trunk Roads, includes a number of recommendations for
improving the management of the existing road network. While some
of these raise important safety issues (eg using hard shoulders)
or environmental concerns (eg redirecting vehicles away from congested
trunk roads onto other possibly less suitable roads), the report
provides a strong case for the Highways Agency to prioritise its
management functions over road building.
CPRE
November 2004
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