Select Committee on Environmental Audit Written Evidence

Memorandum submitted by English Nature and the Landscape, Access and Recreation Division of the Countryside Agency


  A new organisation, Natural England, is being created (from 1 October 2006) with responsibility to conserve and enhance the value and beauty of England's natural environment and promote access, recreation, and public well-being for the benefit of today's and future generations.

  The creation of the new organisation, Natural England, has already begun, with English Nature (EN), the Landscape, Access and Recreation division of the Countryside Agency (LAR), and the Rural Development Service (RDS) working together as partners. Since April 2005, this partnership has been working together to deliver joint outcomes and pave the way for Natural England, whilst continuing to deliver their separate and respective statutory duties:

    —    English Nature is the independent Government agency that champions the conservation of wildlife and geology throughout England;

    —    The Rural Development Service is the largest deliverer of the England Rural Development Programme and a range of advisory and regulatory rural services; and

    —    The aim of the Countryside Agency's Landscape, Access and Recreation division is to help everyone respect, protect and enjoy the countryside.

  This submission has been produced jointly by English Nature and the Countryside Agency's Landscape, Access and Recreation division who are now working with the Rural Development Service to create Natural England, a new agency for people, places and nature. On this occasion, the Rural Development Service has not contributed to this joint submission.


    —    English Nature and the Countryside Agency welcome this inquiry and the Environmental Audit Committee's stated intention to put climate change at the centre of its work.

    —    The Government is not on schedule to meet its own domestic carbon dioxide reduction target and is heading for a 14% rather than a 20% reduction by 2010, as acknowledged by the Department for Transport (DfT) in its Annual Report for 2005. From a transport perspective, fiscal measures, the Renewable Transport Fuels Obligation (RTFO) and other technologies will help deliver some carbon savings but the challenge for DfT is that the growth in vehicle numbers and the distance people are travelling (by road and air) mean that any improvements will be negated by these trends.

    —    Climate change must be a central concern of transport policy but a coherent DfT strategy doesn't appear to be in place. All of the policies being pursued should serve to help deliver DfT's agreed priorities and objectives but those serving to meet an increasing demand for travel are working against carbon reduction rather than for it.

    —    Work to deliver DfT's PSA target for climate change appears to receive a disproportionately small amount of the department's overall expenditure. "Minimising the impact of transport on the environment" only receives 0.5% of the administration resources and expenditure for 2005-06.

    —    Examples of measures that DfT could introduce by 2010 include auditing the Transport Innovation Fund (TIF) and Community Infrastructure Fund (CIF) schemes to ensure that they do not generate high levels of emissions and rolling out the sustainable towns initiative to a larger number of towns. By 2020 DfT could introduce road user charging regimes to address emissions through the charging methodology or through revenue raising to offset effects on emissions. It could also ensure that any new motorway widening is accompanied by measures to "lock in" the benefits.

    —    DfT must build on its work to date and implement a more stringent and wide-ranging package of measures to further reduce carbon emissions over the next decade. These include fiscal policies, alternative fuels, modal shift, smarter choices, better information, regional strategies and measures to tackle emissions from aviation.


  English Nature and the Countryside Agency welcome this inquiry and the opportunity to submit views. We support the Environmental Audit Committee's stated commitment to put climate change "at the centre of its work". Climate change is a critical policy issue at a global scale because it poses potentially catastrophic threats to the natural environment in all its forms and will have major economic and social consequences too. Transport is a significant contributor to carbon dioxide emissions and is also responsible for the emission of a variety of other greenhouse gases including methane, nitrous oxide and hydrofluorocarbons.

  The transport sector is the second largest source of greenhouse gases in the UK and its emissions are rising. Carbon dioxide emissions rose by 8% for road transport between 1990 and 2003 and are projected to rise by a further 9% by 2010. There has been a 35% increase in carbon dioxide emissions from domestic air transport between 1990 and 2002. These increases are counter to total UK greenhouse gas emissions which have fallen by 14% between 1990 and 2003. Transport does not compare well with most other sectors, many of which have achieved significant reductions. For example, carbon dioxide emissions between 1990 and 2002 fell by 16% for the business sector, 29% for the public sector and 17% for the industrial sector. The projections for transport's emissions in the medium to longer term are potentially even more pessimistic. One recent report for DfT indicated that transport emissions of carbon dioxide will rise by 35% between 1990 and 2030 under the "business as usual" scenario. It is vital therefore that measures are taken to curb transport's significant and increasing contribution to climate change.

  We recognise that:

  1.  The Government, through DfT, has shown commitment to addressing some of the negative environmental impacts from transport and greenhouse gas emissions; and

  2.  existing policy measures have helped to achieve some levelling off of emissions despite increases in traffic flows. However, trends such as increased car ownership, the preference for larger, more polluting cars and increased distance travelled are outweighing the gains from cleaner technology and thus are exacerbating the challenge for the UK Government.


  As is well recorded and noted above, the transport sector is the second largest source of carbon dioxide emissions in the UK and in 2003 was responsible for 23% of total domestic emissions. It is also well-known that aviation is the fastest growing source of carbon dioxide. Although not a focus for this inquiry this is an issue which requires urgent attention and a shift in the current policy position and framework. The review of the Air Transport White Paper later in 2006 provides an opportunity to do this.

  Total UK greenhouse gas emissions in 2003 were some 14% below 1990 levels and are forecast to fall to around 21% of 1990 levels by 2010. The UK is therefore on course to meet its Kyoto commitment to reduce greenhouse gas emissions by 12.5% between 2008-12. These reductions have been mainly driven by restructuring the energy sector and pollution control measures in the industrial sector and have occurred despite an increase in emissions from the transport sector. The Government, however, is not on target to meet its own domestic target of a 20% reduction in carbon dioxide emissions by 2010 as acknowledged by DfT in its Annual Report for 2005.

  Fiscal measures, the RTFO, the fuel efficiency labelling scheme for cars and new vehicle technologies will help alleviate the problem but the challenge for DfT is that:

  1.  The number of vehicles on the roads is growing with half a million being added to the existing pool of 26 million vehicles every year; and

  2.  People are using their vehicles more.

  This growth in vehicle numbers and the increase in the distance people are travelling by car and aeroplane means that any improvements which can be made will be negated by these trends. It is of concern that motorists are choosing to buy larger, less fuel-efficient vehicles even though much greener cars are now available in the market place. An important issue therefore is the need to influence consumers' choices, behaviour and ultimately their lifestyles.


  Climate change must be a central concern of transport policy for the reasons outlined above but it is not apparent from DfT's "Delivering better transport—Priorities for 2005-06 to 2007-08" that a coherent strategy for tackling emissions is in place. Ideally, climate change reduction should be an overarching policy objective which can be taken forward through a variety of policy measures. As presented, it is lost within a cluster of objectives which include "minimising the impact of transport on the environment".

  All of the policies being pursued should serve to help deliver the agreed priorities and objectives. This is not the case, however, as the policies to meet an increasing demand for travel are working against carbon reduction rather than working for it. For example, chapter 4 of DfT's current Business Plan includes a priority to deliver growth in the aviation sector and specifically to support the construction of a second runway at Stansted by 2012. Airport expansion must be curbed as this is incompatible with the UK's commitment to reduce carbon dioxide emissions.

  The expansion of the road building programme since the 10 Year Transport Plan is also incompatible with the UK's commitment to reduce carbon dioxide. The 1994 SACTRA report on trunk roads and the generation of traffic concluded that building new roads generate additional traffic—a conclusion borne out by the 2005 Movement Study of the Newbury bypass (prepared by Atkins consultants for West Berkshire Council) which shows town centre peak flow traffic levels returning to pre-bypass levels. Transport policy should be aiming to minimise the provision of new roadspace, and where it is provided, lock in the benefits in order to reduce traffic generation. The current feasibility study into a tolled motorway to be built parallel to the M6 between Manchester and Birmingham (the M6 Expressway) is an example of a scheme that is being investigated by DfT, despite the concerns of all four statutory environmental bodies that the scheme will cause significant traffic generation, and therefore increase emissions, as well as the other environmental impacts from construction and use.

  The recent rejection of three light rail schemes and the lack of plans to expand the rail network may also undermine other policy attempts to encourage modal shift and reduce reliance on private vehicles. The issue of cost increases for major schemes is significant and must be dealt with to ensure value for money across both public transport and road building schemes. However, a strong commitment to supporting public transport schemes, combined with strict conditions regarding the approval of road schemes will encourage local authorities and regional bodies to favour public transport over road building.

  The recent VIBAT study shows that technology is unlikely to reduce transport emissions unaided and that changes to travel behaviour can make a significant contribution. We would support an increased commitment to changing travel behaviour because the impacts of increased reliance on cars, longer journeys and increasing expectations of mobility will have other unsustainable consequences for the environment, even if vehicles and construction are switched to low or no emission models. Changing travel behaviour will reduce congestion and the need for additional road capacity and car parking, reduce the severance and visual intrusion caused by traffic and could improve human health and well-being if levels of walking and cycling are increased.


  On paper it would appear as though DfT's PSA Objective three (which includes a target to reduce greenhouse gas and carbon emissions) receives a disproportionately small amount of the department's overall expenditure. In fact, we were surprised to discover that the objective of "minimising the impact of transport on the environment" only receives 0.5% of the department's administration resources and expenditure for 2005-06. Given that there is a specific PSA target to reduce greenhouse gases we would have expected there to have been a ring-fenced budget allocated for this work alone. It is also apparent that the level of expenditure has not grown markedly and for 2006-07 and 2007-08 is less than it was in 2002-03. We would also prefer to see the main objective reframed around reducing the need to travel rather than balancing the need to travel with other quality of life, safety and environmental considerations.


  Slower traffic growth and continued fuel efficiency improvements are expected to produce a fall in road traffic carbon dioxide emissions of around 5% between 2010 and 2015 with further falls thereafter, so there is some prospect of the situation improving. However, other short-term actions will be required to ensure delivery of the PSA target by 2010 and beyond. Solutions which could deliver more immediate gains include measures to manage the transport infrastructure more efficiently through technologies such as variable speed limits, dedicated lanes, ramp metering and hard shoulder running. A more radical reform of vehicle taxation policies and the further introduction of incentives for cleaner, low carbon vehicles could reap immediate benefits.

Examples of measures that could be introduced (or maintained) by 2010:

    —    Publication (and firm application) of DfT's revised guidance on the appraisal of major local transport schemes. This would ensure that public transport schemes, demand management and non-motorised options are fully investigated before local authorities apply for funding to build new roads.

    —    Firm upholding by DfT of its commitment to a presumption against building new or expanded roads in environmentally sensitive areas, such as AONBs, National Parks or SSSIs. DfT could lead the way by scaling down or cancelling planned trunk road schemes in sensitive areas and supporting the implementation of alternative options for improving safety and reducing congestion on the routes involved.

    —    Audit the TIF and CIF schemes to ensure that those that receive DfT funding are not generating high levels of emissions.

    —    Focus on policies and funding that will expand the rail network, and review the regulation, provision and funding of rural bus services which are subject to severe cuts due to rises in tender prices, and work with local authorities and commercial and community bus operators to introduce a system that enables effective networks to operate.

    —    Encourage local authorities and regional planning bodies to greatly improve walking and cycling and public transport access in preparation for the introduction of road user charging.

    —    Roll out the sustainable travel towns initiative to a larger number of towns.

Examples of measures that could be introduced by 2020:

    —    Introduce road user charging that also addresses emissions either through the charging methodology or through revenue-raising that can be used to offset effects on emissions and support the provision of alternative modes.

    —    Implement the Government's policy of ensuring that any new motorway widening that does go ahead is accompanied by measures to "lock in" the benefits in order to prevent new roadspace generating additional journeys.

  Demand management is probably the key policy tool. Road pricing should be used to tackle pollution as well as congestion and can deliver other objectives as well including those relating to safety, social inclusion, encouragement of smarter measures and better management of the road network. Road user charging schemes should be designed to address carbon dioxide emissions and should be targeted at areas where traffic growth is highest. The revenues generated should be used to invest in more environmentally sustainable forms of transport and greener fuels. Ideally, these investments are needed in advance of any charging regimes being introduced so that users have more choice about the ways they travel. We recognise that further research and modelling are required and would urge that this includes an assessment of the potential environmental costs and benefits of any scheme or schemes.


  A combination of policy measures need to be pursued with vigour if transport's contribution to climate change is to be reduced. These include fiscal incentives, improving fuel efficiency and introducing alternative fuels, modal shift, "smarter" measures and information. In particular, we believe there is a need to ensure that consumers are aware of the link between transport and climate change and the availability of cleaner vehicles, and that they have an understanding of the basis of the fiscal measures.

  Fiscal measures: We advocate a gradual rise in the real cost of fuel (to reverse the falling cost of motoring), the use of revenue from fuel tax increases to encourage more environmentally sustainable transport systems and a commitment to the introduction of national road user charging within 10 years. Although the reform of Vehicle Excise Duty (VED) to encourage more fuel-efficient cars was a step in the right direction it is now clear that its impact on reducing emissions has not been significant. We suggest a more steeply graduated VED system with more bands and bigger gaps between them linked to a labelling system giving clear information to car buyers. We would also support a graduated purchase tax scheme with purchase taxes on vehicles with high fuel consumption balanced by grants or rebates for the least polluting vehicles. The pay-as-you drive insurance schemes being developed by Norwich Union appear to offer potential and could be expanded.

  Improving fuel efficiency and the use of alternative fuels: Progress with making cars more fuel efficient has not been as rapid in the UK as in many other EU Member States. The reasons why the UK is lagging behind must be understood and acted upon by DfT. The production of renewable transport fuels, such as biofuels, could make a contribution towards UK fuel security and limiting increases in carbon dioxide emissions from transport. However, they will not in themselves make a significant contribution towards this aim while total consumption of transport fuel is still increasing in the UK. The production of renewable fuels, while ameliorating emissions, could have major impacts on land use patterns and crop management with consequent implications for biodiversity, landscape character and water resources in the UK and internationally. We advocate therefore policies that promote environmentally sustainable production and/or the use of biomass and waste materials to produce renewable transport fuels provided that they can be demonstrated to reduce greenhouse gas emissions and are managed in ways that protect and enhance biodiversity and landscape character. We recommend further work on an accreditation scheme for biofuel production and consideration of the wider issue of the potential importation of renewable fuels from abroad with the consequential loss of habitat and increase in fuel miles.

  Modal shift: This requires a combination of complementary measures aimed at encouraging a modal shift and delivering behavioural change. Key to this will be making alternatives, such as rail travel, more reliable, affordable, coherent and accessible. Projects such as a new high-speed rail line from north to south should be revisited to examine the potential to replace internal flights and long distance use of the motorways. There is a need though to ensure that the emissions from passenger transport are addressed and to look for opportunities for doing this. For example, the review of bus subsidies provides an opportunity to identify incentives to operators. Other key measures include: land use planning to reduce journey distances; the creation of safer routes for cycling and walking, and more investment in the necessary infrastructure.

  Smarter choices: People need to be encouraged and helped to make smarter choices about the way they travel. Behavioural change beyond a shift between motorised modes is required. Research undertaken by DfT in 2004 estimated that nationally traffic could be cut by 11% (and up to 21% in the peak period), if an intensive "smarter choices" programme was developed over a period of about 10 years. A package of measures is needed which combine "soft" measures (eg travel plans, car clubs, personalised journey planning, teleworking) with "hard" traffic restraint measures (eg reallocating road capacity) in order that space "freed up" doesn't attract more car use by others ie the benefits need to be "locked in".

  Better information: A key element is the provision to the public of better information. There is an urgent need to inform the travelling public of the nature of the transport and climate change problem and the need to change their behaviour. Ideas to encourage more awareness (and an appropriate behavioural response) include: further developing green labelling schemes for vehicles; introducing a more steeply graduated system for VED (and Purchase Tax) and more information on how these are calculated; promoting more environmentally-friendly driving; labelling petrol pumps with health warnings that fuel use contributes to climate change; and providing more "real-time" information for public transport users. These need to form part of a wider campaign to provide people with better information on sustainable travel options.

  Regional strategies: It will also be important for action to be taken at a regional level. Regional bodies should be given a strong steer to set climate change and road traffic reduction targets in their regional and sub-regional strategies. They should also be encouraged to pursue a range of other measures and the allocation of more resources to non-motorised transport modes ie "softer/smarter" measures.

  Aviation: Forecasts suggest that by 2030 aviation could account for 25% of the UKs total carbon dioxide emissions and for this reason it is imperative that the aviation industry takes its share of responsibility for reducing emissions. We welcome the Government's commitment to pursuing the inclusion of intra-EU aviation into the next round of the European Union Emissions Trading Scheme. In the meantime, an Air Passenger Duty should be considered. The various tax exemptions and subsidies should be removed and fuel should be taxed for internal flights in order to create greater equity across transport modes. A number of improvements to operational practices and air traffic management techniques should be pursued to reduce fuel use. These include more efficient routing of flights, greater use of meteorological information, changes in flight altitude and less "stacking" of aircraft over airports. Slot allocation preference should be given to airlines with clear and robust environmental policies and aircraft which exceed the statutory minimum standards for noise and emissions. As mentioned earlier, there should also be investment in new high-speed inter-city rail links to reduce the demand for shorter-haul internal flights, increase consumer choice, and enhance integration with other surface access modes.


  Department for Transport (2004), The Future of Transport: A network for 2030 White Paper.

  Department for Transport (2005), Annual Report for 2004-05 and Delivering better transport: priorities for 2005-06 to 2007-08.

  Department for Transport (2005), Visioning and Backcasting for UK transport policy (VIBAT), Horizons Research Programme 2004-05.

  Department for Transport (2006), Looking over the horizon, Bartlett School of Planning, UCL and Halcrow Group.

  DETR (1994), Trunk roads and the generation of traffic, The Standing Advisory Committee on Trunk Road Assessment.

February 2006

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