Memorandum by Safe Speed (RP 42)
ROAD PRICING
ABOUT SAFE
SPEED
Over the last three and a half years Safe Speed
have spent thousands of hours examining road use and road administration.
A fresh approach and very detailed analysis at the system level
has revealed many facts and useful observations that are apparently
not widely known.
1. INTRODUCTION
1.1 Road pricing has a surprising number
of advocates. Great claims are made for reducing congestion, but
we cannot find justification for the claims. Road pricing is flawed,
pointless, expensive, inefficient, regressive and intrusive. There
is a severe lack of critical thinking behind the schemes under
discussion, and major effects are not even discussed.
1.2 We refer extensively to the "positioning"
report: "Feasibility study of road pricing in the UK—Report"
(Henceforth "the report")
2. FLAWED
2.1 The dream is that we can reduce congestion
by ensuring that roads are more expensive to use when they are
likely to be congested. But the proponents have apparently forgotten
that "time is money", and that congestion always costs
time. Adding a monetary penalty to the use of congested roads
simply makes a small addition to a pre-existing regulatory influence—that
congested roads use extra time.
2.2 When we plan journeys, in most cases
the first question is: "Have I got time?" The question:
"Can I afford the journey?" is far lower down the list.
2.3 The report says: "More Londoners
think they would drive more often if there was less congestion
than people in other regions." Why is that? Clearly it is
a statement about the high value of time. Londoners are warning
us that if there's less congestion they will travel more. It is
a warning about the strength of the self-regulating properties
of congestion. Too much congestion and people choose not to travel
or make alternative arrangements. With little congestion they
will travel more and increase the levels of congestion. Journey
time is the primary regulator.
2.4 The report suggests that congestion
has an associated cost. Of course it does. That cost comes from
lost time. Since much of the lost time accrues to businesses,
and since businesses have a strong interest in controlling their
costs, it should be obvious that we already have a powerful regulatory
system in place based on congestion. Businesses make choices based
on efficient transport, which may often include choosing a location
away from congested town centres.
2.5 In its only reference to the value of
time, the report contains: "4.22 . . .For example, the modelling
assumes that road users will value their time more highly in the
future than they do now." We are astonished to see this,
with the clear implication that the value of road users' time
is considered. We assume that the "national transport model"
considerably undervalues time, or fails to model the full range
of real world time management choices that people are already
making.
2.6 London provides very clear evidence
of these self regulation effects. Over the last couple of decades,
overall traffic growth in London has been tiny compared with the
country as a whole. This is because congestion reached the level
where it influenced traffic growth by time constraint decades
ago.
2.7 In summary, implementing a road pricing
scheme based on congestion will simply add slightly to existing
pressures experienced by all groups of road users to avoid congestion.
It will not and cannot be expected to make a fundamental difference.
2.8 Before we embark on a system of road
pricing we must fully and properly evaluate the self regulation
of congestion via the mechanism of increased journey time discouraging
journeys. There is great evidence of such mechanisms operating
in London, where traffic growth has been far below national traffic
growth over 30 years.
3. REGRESSIVE
3.1 Road pricing will have a far greater
effect on poor people than rich people. In fact rich people really
will not be affected at all, while poor people may find themselves
unable to afford to travel. Clearly this in unacceptable. It might
be argued that road fuel tax is also regressive, but at least
the less well off have the opportunity to select more economical
vehicles and this goes some way towards reducing the effect.
4. EXPENSIVE
4.1 Any practical system of road pricing
will be massively expensive to install and operate. Clearly there
would need to be very compelling, very certain and long-term sustained
benefits before we should decide to embark on such a scheme.
5. INTRUSIVE
5.1 Most imaginable schemes involve considerable
invasions of privacy. The charging authority would have data on
vehicle movements, while normally in this country we expect to
be able to move freely without being tracked, monitored and recorded.
6. ERROR AND
BREAKDOWNS
6.1 All technical systems experience breakdowns,
so obviously there will have to be provisions for system breakdowns.
One particular important area is to consider what happens when
the equipment on an individual vehicle breaks down. How will it
be possible to know what charges should apply to the use of the
vehicle? It might be suggested that a vehicle without a working
data gathering system should be automatically disabled, but this
would bring serious problems. For example:
— Areas of poor position signal would
accumulate disabled vehicles.
— The broadcast parts of the system
would become a terrorist target, since all motor transport would
be disabled if the system was disabled.
7. FRAUD AND
ABUSE
7.1 Equipment installed in individual vehicles
would be very vulnerable to unauthorised modifications, induced
failures, or deliberate disconnection.
7.2. If instead we follow the London congestion
charge model with ANPR, there will obviously be people who would
use false or stolen registrations to avoid payment. This could
become widespread and contribute to loss of control of the entire
vehicle registration process.
7.3 Schemes of Electronic Vehicle Identification
(EVI) would be vulnerable to tampering, jamming, cloning and simple
destruction. And how would a road user know if his EVI tag was
working or not? Even if he did know, he would very likely be happy
to turn a blind eye for as long as possible.
7.4 With a satellite positioning based system
data gathered in the vehicle regarding the vehicle's movements
must be "uploaded" to central administration by some
means. The most likely technology would be cellular telephone
link, with a data burst sent once a day, once a week or once a
month. What would happen if the cellular link failed? Especially
what would happen if the cellular link was caused to fail?
7.5 We must not underestimate the skill
and the effort that would be applied to defrauding the road pricing
system. With complex technology there will be a huge range of
ways in which the technology could be undermined or defeated.
8. INFORMATION
FROM PATHFINDER
SCHEMES
8.1 We are concerned about the quality and
independence of analysis of pathfinder schemes. For example, it
is not acceptable that results of the London Congestion Charge
are analysed mainly by its implementers. We need properly independent
information to make the right judgements.
9. SHORT LIVED
BENEFIT
9.1 Since we have seen that simple logical
analysis reveals that the main reasons for avoiding congestion
has always been and will always be the time spent wasted in congested
conditions. It follows that the proposed system of road pricing
may only have a short term effect, but a long term cost. Consider
this idealised graph illustrating the effects of a road pricing
scheme on traffic nearing saturation limits on a busy town centre:
9.2 At time "20" a system of roads
pricing is introduced, and a short term benefit appears. However
by time "60" we have returned to the path that would
have been followed if the road pricing scheme had not been introduced.
But, and it is a very big but, now we have the massive overhead
of the road pricing infrastructure absorbing national resources
for no benefit whatsoever.
10. KNOWING THE
CHARGE
10.1 A particular major difficulty, that
has not been discussed in the report, is how would a road user
know what charges he would encounter before he makes his journey
decision. We might assume initially that most road users are regulars
on the route, but regulars are the hardest to discourage with
pricing.
10.2 Those that do not travel a route regularly
may be the easiest to discourage, but how would they estimate
in advance what the charge would be? They may get an unpleasant
bill at the end of the month, but that forms no part of the discouragement
to travel in congested places for the month that it applies. A
proportion would undoubtedly use a web site to pre-calculate their
journey cost. But most people simply would not bother.
10.3 Displaying the charge at the roadside
would be horrendously expensive and completely ineffective because
the folk seeing the charge for a congested road would already
be incurring it.
10.4 Assuming a satellite based system it
would be quite impossible to transmit pricing data for display
inside the vehicle because of the huge number of charging zones.
Local storage of data on board vehicles would work, especially
if integrated with satellite navigation, but once a road user
has got into their vehicle and started on the trip they are unlikely
to change their plans for a few pounds of extra charges. And the
data in the vehicle would need to be very regularly updated to
reflect the latest charges.
10.5 The problem of being unable to know
the charge at the time of planning the journey would make rapidly
varied charges reflecting temporary local conditions completely
pointless.
10.6 We conclude that knowing the charge
in good time to avoid incurring the charge would be a very significant
problem. Millions of road users would simply pay the bill and
moan without ever knowing where and when the larger charges accumulated.
11. CARBON TAX
11.1 It has been suggested that road pricing
might have a role to play as a "carbon tax" intended
to manage atmospheric emissions of carbon dioxide. Non technical
people fail to appreciate that fuel duty is a perfect carbon tax
because virtually every carbon atom in fuel purchased ends up
as atmospheric carbon dioxide. There is absolutely no possibility
that roads pricing can approach the accuracy of fuel duty in terms
of providing a carbon tax.
12. CONCLUSION
12.1 We applaud any idea that will genuinely
improve transport efficiency, while preserving individuals' rights
to transport choice. On present information road pricing will
not achieve its stated objectives and it will be extremely costly
and technically difficult to implement.
12.2 We recommend extreme caution with this
huge public project. It appears doomed to fail on presently available
data. It is especially worrying that obvious and serious problems
are not even being discussed.
November 2004
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