Memorandum by The Royal Society for the
Protection of Birds (RP 37)
ROAD PRICING: SHOULD ALL ROADS BE TOLL ROADS?
EXECUTIVE SUMMARY
(i) In this memorandum, the RSPB outlines
the key political, environmental and technological issues we believe
that the Government needs to address before introducing a road-pricing
mechanism. We also discuss other mechanisms that could be introduced
to reduce both congestion and emissions of greenhouse gases from
transport.
(ii) The RSPB is broadly in favour of a
national road pricing mechanism to help in ensuring that road
transport fully covers the costs of road transport infrastructure
and maintenance and meets its external costs. However, road pricing
is not an especially good instrument for dealing with greenhouse
gas emissions from transport and, therefore, should not be used
to replace fuel duty or vehicle excise duty. Reduction of greenhouse
gas emissions is an urgent priority and should be the key objective
of national transport policy.
(iii) Although public acceptability is important,
the current lack of it should not be used as a reason to avoid
establishing a road pricing system. We believe the Government
must do more to educate people on the impacts of travel choice
on the environment and society. More working examples of road-user
charging, like the London congestion charge, will help with this
process.
(iv) Some countries appear to be moving
faster than the UK to set up charging systems. The UK Government
should monitor these schemes and, if they prove successful, should
aim to establish a national road pricing system well before the
2014 date suggested by the road pricing feasibility study. There
is neither political, economic nor technical justification for
such a long delay.
(v) The RSPB is in favour of a significant
proportion of any revenue raised from road pricing being ring-fenced
for improvements to sustainable transport networks. This will
help to ensure that there are suitable alternatives to the use
of private motor vehicles which will bring about greater public
acceptability of the scheme.
(vi) There are a number of other measures
which could also help to reduce congestion, these include, better
land-use planning to reduce the need to travel, use of information
technology, school and workplace travel plans and workplace charging
levies.
INTRODUCTION
1. The RSPB is Europe's largest wildlife
charity with over one million members. We manage one of the largest
conservation estates in the UK with 188 nature reserves, covering
more than 127,000 hectares. The RSPB is part of the BirdLife International
partnership, a global alliance of independent national conservation
organisations working in more than 100 countries worldwide.
2. The RSPB considers that human-induced
climate change poses the biggest long-term threat to global biodiversity.
We therefore support policies and measures that reduce the anthropogenic
greenhouse gas emissions that cause climate change. The RSPB endorses
the UK Government's aim to cut emissions by 60% by 2050, an aim
that the UK should try hard to overachieve. In the United Kingdom,
26% of carbon dioxide emissions can be attributed to road transport,[61]
and this percentage is rising.
3. Transport can have a number of other
direct effects on birds, biodiversity, and the environment, including
direct land take, habitat fragmentation, noise, motion and light
disturbance, bird and animal strike and local air pollution. Each
of these effects is important. Together, they mean that sustainable
transport policy is of great significance for birds, biodiversity
and the wider environment, as well as for delivering social and
economic benefits.
KEY ISSUES
FOR ROAD-USER
CHARGING
Government transport policy
4. Over recent years, the emphasis of Government
road transport policy has been on tackling congestion. However,
the RSPB believes that this emphasis should change to reducing
the amount of greenhouse gas emissions from road transport.
5. Over 25% of carbon dioxide emissions
in the UK can be attributed to road transport and this contribution
continues to grow. This trend must be reversed if the UK is to
reduce its carbon dioxide emissions by 60% by 2050 as set out
in the Energy White Paper. In our view, climate change is a much
greater concern than congestion and should be the primary focus
of transport policy. The Government must, therefore, make a shift
in emphasis on transport policy if it is to convince the public
that the need to tackle climate change is urgent.
Road-user charging and other transport taxes
6. The RSPB is broadly in favour of the
concept of national road-user charging. However, road-user charging
must be seen as only one element of a suite of economic instruments
that should be used to internalise the external costs of road
transport. Careful consideration needs to be given to how road-user
charging would complement the other economic instruments, such
as fuel duty and vehicle excise duty. The RSPB is concerned by
the implication of the road pricing feasibility study[62]
that other transport taxes may be reduced or even abandoned completely
if national road pricing were to be introduced.
7. Road-user charging is not an effective
economic instrument for tackling the greenhouse gas emissions
from transport. Indeed, by reducing congestion, and increasing
the efficiency with which roads are used, there is the risk that
overall traffic volumes might grow. However, road pricing could
be used as a mechanism for internalising other externalities such
as road maintenance costs, congestion, accidents, direct environmental
impacts and air quality, and so on.
8. As stated above, the RSPB believes tackling
greenhouse gas emissions from transport should be treated as a
matter of urgency. This can be most effectively achieved by introducing
a fuel duty system which is based upon the well-to-wheel, or more
properly well to tank, carbon emissions of different types of
fuel.
9. A fuel duty rated in direct proportion
to "well to wheel" (full life cycle) carbon emissions
would mean that fuels that resulted in less carbon emissions for
any given drive train would have a lower rate of duty. Well-to-wheel
CO2 emissions not only account for the exhaust emissions created
from driving the car but also the emissions created in the production
and distribution of the fuel. Therefore, the Government should
develop differential rates of fuel duty for alternative fuels
based on well-to-wheel CO2 emissions. If fuel duty were applied
on this basis it is likely that petrol would have the highest
duty, followed by Liquefied Petroleum Gas (LPG), then diesel,
then Compressed Natural Gas (CNG). The lowest duty would be applied
to biofuels and other low carbon options, such as, renewable hydrogen.[63]
10. Vehicle Excise Duty (VED) could also
be an effective mechanism to encourage consumers to purchase fuel-efficient
vehicles. The RSPB has been supportive of the Government in establishing
a VED system that is related to the CO2 emissions of the vehicle.
However, we believe that the difference between the annual tax
levied on the most efficient vehicles (currently £55) and
least efficient vehicles (currently £165) is wholly insufficient
to affect consumer decisions on the type of car to purchase. This
is supported by the fact that, for the first time, the average
engine size of new private passenger cars is larger than the average
engine size of new company cars. According to the Environmental
Audit Committee, in its recent report on Budget and Energy 2004
(Tenth report of session 2003-04),
"The Government's own evaluation of the
current VED scheme shows that current differentials are insufficient
to prompt behavioural changes. The Government should increase
them radically as part of a coherent strategy to promote low-carbon
transport."
The RSPB concurs that VED differentials should
be radically increased.
11. The conclusion must be, therefore, that
road-user charging can help to ensure road transport meets the
direct costs of road provision and its external costs. A charge
should not be used to replace other economic instruments, such
as fuel duty and VED, which are more effective at tackling greenhouse
gas emissions-the issue which should be given the highest priority.
PUBLIC ACCEPTABILITY
OF ROAD-USER
CHARGING
12. The Feasibility Study on Road Pricing
in the UK stated that public acceptability is key to the successful
implementation of road pricing. The RSPB agrees that public acceptability
is important and desirable but, as schemes such as the London
congestion charge have shown, acceptability by the majority of
the public is not absolutely essential prior to the establishment
of the scheme. Available evidence from the London congestion charge
has suggested that initial opposition to the scheme has dwindled
following its introduction. If the Government believes that road-user
charging is an important instrument to ensure road transport meets
its costs to society, perceived lack of public acceptability should
not be used as a reason to delay its introduction.
13. The Government should, in general, undertake
a much higher level of public education on the impacts of transport
on society and the environment than it currently does. This will
not only help with the introduction of new schemes, such as road-user
pricing, but will also help people to understand the importance
of other economic instruments like fuel duty. In itself, public
education may help to achieve a certain level of modal shift or,
at least, make people think twice before using their private motor
vehicles.
14. To help with gaining public acceptability
for road-user charging it would also be useful to have more examples
in operation across the UK. The RSPB has advocated the introduction
of congestion charges in major urban areas for some time. This
could be done in advance of the introduction of a national road-pricing
scheme. Tolls could also be introduced on the most congested parts
of the motorway and trunk road network (although the RSPB does
not agree with providing additional, tolled capacity such as the
M6 Toll). A greater number of examples would increase public acceptability
as well as reducing congestion hotspots. However, this approach
may also have the disadvantage of diverting traffic onto more
environmentally sensitive non-toll roads. The RSPB believes that
local authorities, which cover urban areas with a population of
more than 100,000, should be required to undertake a feasibility
study and impact assessment for the introduction of congestion
charging along with other measures, such as, workplace parking
levies.
15. In order to ensure that any isolated
road-charging schemes, established by local authorities, are compatible
with a future national road pricing system, the Government should,
as a matter of urgency, develop and issue guidance for local authorities
on how to set up a local congestion charge. This would ensure
a degree of standardisation that would minimise disruption at
a later date.
TECHNOLOGICAL AND
ADMINISTRATIVE ISSUES
16. A satellite tracking based system with
positioning systems fitted as standard in all road vehicles would
provide the best mechanism for road-user charging. This would
enable charging for use of all roads. These systems are already
available. The German government intend to introduce a lorry road-user
charging system at the beginning of 2006 which will be based upon
satellite tracking systems. The level of success of this scheme
should be scrutinised by the UK Government. Should the scheme
prove successful, it would demonstrate that the main barrier to
introducing a national road-user charging system would not be
the existence of appropriate technology but, rather, how quickly
the technology could be incorporated into the vehicle fleet. If
the system in Germany proves successful, the RSPB sees no reason
why a national road-pricing system could not be introduced considerably
earlier than the 2014 date suggested in the road-pricing feasibility
study.
17. The RSPB would prefer a system where
vehicles are charged for the use of all roads. If this were not
the case, there is a serious risk that traffic would choose to
use smaller, non-charged, more environmentally sensitive roads
in order to avoid paying a charge. This would be of particular
concern with Heavy Goods Vehicles. The system should be designed
to reduce congestion by reducing the overall volume of traffic
rather than dissipating the existing traffic over a wider area
of the road network, or even increasing overall volumes.
18. Another factor that needs to be given
careful consideration is how revenue that is generated by a road-user
charge will be used. The RSPB already advocates that a significant
proportion of revenue raised from fuel duty should be ring-fenced
to improve public transport systems. The same would be true for
revenue raised from road-user charging. Such a system would help
to gain greater public acceptability for the scheme. Lack of suitable
alternatives is frequently cited as a reason for using private
motor vehicles. This is particularly the case in rural communities.
If, as we believe should be the case, the Government introduces
a system whereby all roads are charged, including rural roads,
there must be public transport alternatives available.
19. We do not recommend that revenue from
road-user charging should be reserved for the road sector in particular
rather than the transport sector as a whole. This would effectively
be using revenues from external cost pricing to contribute to
the development of the cause of the externality, thereby subsidising
and exacerbating the problems associated with road usage.
OTHER MEASURES
WHICH COULD
REDUCE CONGESTION
MORE EFFECTIVELY
20. By far the best method for minimising
congestion is to reduce the need to travel. This can primarily
be brought about by effective sustainable land-use planning to
ensure that housing developments are located close to employment,
education and leisure opportunities. This would minimise the need
to commute to work, would reduce the number of vehicles making
the "school-run" and would reduce the length of journeys
made for shopping. The RSPB is generally supportive of PPG13 which
provides local authorities with guidance on effective land-use
planning to minimise vehicle journeys.
21. The use of information technology could
prove to be a significant measure in combating congestion. Home
working and shopping has the potential to considerably reduce
the volume of traffic on the roads. The Government should work
closely with information technology companies to further the take-up
of broadband.
22. The school run is a continuing source
of congestion in urban areas. The RSPB supports measures which
enable and encourage children to walk and cycle to school. The
Government should continue to provide funding to local authorities
to facilitate this process.
23. As stated above, the RSPB believes that
a well-to-wheel carbon-based fuel tax is the most appropriate
economic instrument for reducing greenhouse gas emissions from
road transport. Such a tax should reduce the number and length
of vehicle journeys and encourage more people to use public transport,
which will also have the added benefit of reducing congestion.
24. The Transport Act 2000 provides local
authorities with the powers to establish workplace parking levies.
To date, the RSPB is not aware that any local authorities have
used these powers. The Government should do more to encourage
local authorities to set up such schemes. They will encourage
commuters to use public transport services which in turn will
reduce urban congestion.
25. As stated previously, key to the success
of any scheme to reduce congestion and to reduce greenhouse gas
emissions is the presence of a suitable alternative. The Government
and local authorities must do much more to improve public transport
systems at a local, regional and national level.
November 2004
61 Transport Statistics Great Britain 2004 Edition.
Department for Transport. 2004. Back
62
Feasibility Study of Road Pricing in the UK. A report to the
Secretary of State. Steering group. 2004. Back
63
Tomorrow's Low Carbon Cars. IPPR. Julie Foley. 2003. Back
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