Memorandum submitted by English Nature
and the Landscape, Access and Recreation Division of the Countryside
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
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.
3. GENERAL COMMENTS
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.
4. WHAT PROGRESS
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
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
5. IS THE
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 transportPriorities
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
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 traffica 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
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.
6. DOES THE
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.
7. WHAT REALISTICALLY
BY 2010 AND
2020 IN TERMS
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
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.
8. WHAT SPECIFIC
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
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
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
Department for Transport (2005), Visioning and
Backcasting for UK transport policy (VIBAT), Horizons Research
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.