APPENDIX 2
Memorandum submitted by the Friends of
the Lake District
SUMMARY
1. Our experience within Cumbria has been:
— Serious underfunding of revenue
funded work.
— Poor integration between capital
and revenue spending.
— Bias towards new roads, with
consequent substantial expenditure on working up road based solutions,
and inadequate investigation of demand management solutions.
— Department for Transport (DfT)
guidance resulting in an unduly narrow vision, particularly over
the potential role of speed management.
— DfT guidance giving somewhat
ambiguous advice on addressing quality of life issues, with consequent
failure of the Local Transport Plan (LTP) to address impacts of
its approach and proposals on the landscape, on biodiversity and
on carbon emissions.
— Scheme development work across
the range required, but very limited delivery, particularly on
projects that would encourage modal shift.
— While the first LTP put demand
management seriously on the agenda, in the second LTP challenging
demand management targets have been replaced by distinctly unambitious
ones, or none at all. In addition, a lack of clarity on the scale
of actions required by many policies and on the outcomes envisaged,
together with a confusing and potentially conflicting amalgam
of demand led and demand management stances, suggesting a lack
of a clear long-term vision.
— Annual progress reports (APRs)
are too number based and are a poor basis for judging the quality
of performance on the ground. However, DfT assessments of plans
and performance have been perceptive and fair.
— Work travel plans are poorly
developed and will have no measurable impact on modal shift unless
work is expanded considerably.
REASON FOR
OUR INTEREST
2. The Friends of the Lake District is a
charity founded in 1934 that works to conserve the natural beauty
of the Lake District and the county of Cumbria as a whole. Transport
policies and activities have major impacts on the quality and
integrity of our landscapes, hence our interest in the Local Transport
Plan (LTP) process.
3. We base our observations on Cumbria both
as it is the focus of our work and because we are not familiar
with Local Transport Plans elsewhere. However, from discussions
with other parties, we believe experience elsewhere to be not
dissimilar.
FUNDING ISSUES
Balance between revenue and capital funding
4. This is a crucial issue. The LTP process
replaced the former Transport Policies and Programmes that had
become essentially an annual bidding process for capital spending
approval. As a key purpose of LTPs continues to be to establish
the capital investment programme, they retain a bias towards capital
schemes. But increasingly the key LTP themes require relatively
soft measures for their achievement, often a well-integrated mix
of revenue and small-scale capital schemes. Achieving this frequently
seems next to impossible under current local government funding
arrangements, with local authority revenue budgets under much
pressure. Local authorities are reluctant to allocate sufficient
sums to new initiatives or areas of work for them to have a real
impact.
5. Cumbria is no doubt typical of rural
authorities. In relation to transport measures it finds itself
relatively capital rich and revenue poor. While it complains that
capital settlements are inadequate to support large infrastructure
projects that do not reach the "Major scheme" threshold
of £5 million, we understand that capital budgets are supporting
maintenance work that in times past would have been funded from
revenue budgets. While we appreciate that for some kinds of maintenance
work the appropriate classification may be arguable and flexible,
we believe the current trend is symptomatic of a serious underlying
problem.
6. The development of key measures in Cumbria
has relied heavily on external revenue funding, funding that is
often short-term. For example, the demand responsive "Rural
Wheels" public transport initiative has been dependent on
Countryside Agency support and will need to secure substantial
additional resources if it is to be developed further. Work on
school travel plan development made more rapid progress once additional
DfES/DfT grant became available. Work travel plan development
languished until a co-ordinator was appointed in 2004, but only
for two days a week. Saving threatened rural bus services causes
much heart searching and is achieved through savings on equally
vital areas such as public transport information and promotion,
but funding bus stops (a capital item) is not a problem.
7. But even if revenue budgets were less
tight, we believe there would still be a tendency to see capital
schemes as more capable of delivering final solutions. Revenue
funded solutions almost invariably need ongoing commitments. Moreover,
the relationship between soft measures and outcomes is notoriously
difficult to monitor. It is not particularly easy to persuade
local politicians to spend money on what may be seen essentially
as an act of faith. If integrated measures are to be delivered,
means must be found of securing budgets that are flexible as between
capital and revenue expenditure.
8. We suspect that the annual basis on which
capital grant is paid and performance monitored is an incentive
to spend it on stand-alone measures that are apparently quicker
and easier to implement in the short term.
9. The entirely separate funding arrangements
for rail infrastructure results in a further lack of integration—as
in the case of the Windermere Branch line. In Cumbria, first LTP
increasing the capacity of this strategically important access
to the Lake District National Park was a priority scheme, but
in the second Plan, it is relegated to a mere expression of a
wish because rail authorities have other priorities. After many
years of discussion Cumbria's achievements have been limited to
some enhancements of Windermere station forecourt.
10. Finally, we note that the rewards for
good performance relate solely to capital grant settlement when
the more immediate priority is for more revenue funding.
Resources wasted on schemes that do not get approval
11. The second Cumbria LTP contains references
to the need for 14 new road schemes including a number of bypasses
to relieve congestion (in spite of an absence of evidence of serious
ongoing congestion) and facilitate economic development. This
shows lack of conviction that demand management is a viable option
and a return to seeing road building as the solution to congestion—contrary
to the stance of the 2004 White Paper. For Kendal, the traffic
stabilisation targets in the first LTP have been removed and the
Council is developing a Kendal Northern Releif Road (KNRR) as
its priority Major Scheme. Several hundred thousand pounds has
already been spent on preparatory studies, in spite of the scheme's
failure to score highly under the council's own scoring system
or for the council's approach to apparently meet the requirements
set out in DfT's Transport Analysis Guidance in Tag Unit 1.4.
It is also only in the third quartile of Regional Strategy priorities
when even the first quartile is unlikely to be fully funded. Furthermore,
the Council's consultants, Capita Symonds, reported in 2003 that
the new road would result in relatively small reductions in town
centre traffic. Demand management alternatives have yet to be
properly tested. We believe this to be a scheme that stands little
chance of receiving DfT funding approval, yet the council persists
in pursuing it.
12. While we appreciate that some preparatory
work is necessary before a scheme can be properly evaluated, perhaps
at that stage Major Schemes should be required to be submitted
for an initial funding appraisal (with call-in powers if necessary),
so that it can be made clear if a scheme is unacceptable in principle.
PLANNING ISSUES
Departmental Guidance
13. DfT guidance is very much about the
transport planning process and target setting. It says a good
deal about issues to address but rather less about outcomes and
the need for clear links between policies actions and outcomes.
It is weak on advice about reducing the need to travel and modal
shift. In Cumbria, Part 3 of the guidance clearly very much influenced
the structure and content and emphases of the second LTP. The
traditional themes of reducing congestion and reducing accidents
are very much to the fore in the Plan. Reducing the need to travel
and securing modal shift are not.
14. When consulted on the draft Plan we
argued for an overall speed strategy designed to deliver a range
of outcomes, something which is not found in the guidance. So
the Plan treats speed control only as a potential mechanism to
use in pursuance of road safety aims. This often results in speed
limits, with a resulting plethora of signs and clutter, continuing
to be installed on an ad hoc and often confusing basis.
15. Indeed, the stance of DfT on this issue
has been particularly unhelpful. When Cumbria County Council's
agents, Capita Symonds, consulted DfT on the possibility of a
speed restricted zone in part of the Lake District National Park
(a proposal in the first LTP), referring to precedents in the
New Forest and Dartmoor, the response was that that the Department
did not see those schemes as a precedent to be repeated. Yet as
the Committee's own report Road Traffic Speed (2001) said:
"Road traffic speed in both urban and rural
areas inhibits walking and cycling and so makes people less physically
active. It reduces quality of life... in the country too villages
are severed and country lanes, once enjoyed by those taking a
stroll, or riding a horse or bicycle, are now dominated by traffic
travelling at high speed".
16. Speed reduction is essential to improving
safety, enhancing the quality of the local environment, encouraging
walking and cycling and promoting the public enjoyment of the
National Park. We believe it to be an essential requirement of
the Government's LTP priority of addressing wider quality of life
issues.
17. The "Other Quality of Life Issues
in the Guidance" were clearly noted in Cumbria's Plan and
some reference made early in the Plan to the adverse impacts of
transport on CO2 emissions and on countryside character, but there
was scant reference to environmental issues in the subsequent
policies and supporting text. We are concerned that this was partly
because the DfT guidance rather plays down the importance of "Other
Quality of Life Issues". While included in priority outcomes
they are relegated to an "other" category the list of
which is said not to be exhaustive (by implication merely illustrative).
The statement is made that DfT does not expect authorities to
treat them as key priorities or for them to determine the prioritisation
of LTP schemes and priorities. When climate change is the greatest
threat facing mankind and protecting our finest landscapes is
a key plank of government policy such a stance is singularly unhelpful.
A requirement for plans to set out how climate change, landscape
protection etc considerations had determined key priorities and
projects would have been somewhat more helpful and we believe
in Cumbria's case may have resulted in a more clearly environmentally
sustainable approach.
How well have LTPs delivered?
18. Our experience has been that delivery
has been patchy. In Cumbria the Council has struggled to maintain
rural accessibility—to maintain existing bus services and
to introduce more demand responsive services. To give it credit,
it has tried to be innovative, eg through the emerging smart card
ticketing scheme, which hopefully will provide the basis for developing
additional incentives to use public transport, and the demand
responsive Rural Wheels scheme. In a rural County like Cumbria
the cost-effectiveness of support for many scheduled rural bus
services is questionable given the very low patronage, but without
more resources being put into promoting modal shift (and that
must include securing lower fares and measures to discourage car
use) this situation will continue. The system of rural bus subsidy
grant is perhaps too inflexible to secure the most effective use
of limited resources. Nationally in recent decades, there has
been many innovative local public transport initiatives, generally
dependent on external funding, eg from the Countryside Agency
or Rural Bus Challenge Fund, but rarely the resources to replicate
or even continue them. Local transport plans have not changed
that.
19. New cycling facilities look decidedly
piecemeal, and until progress has been made in developing more
continuous routes and networks will have limited impact. In our
view, the council has not been sufficiently vigorous in pursuing
cycle route network development, instead concentrating on a few
specific proposals, but it has also come up against strong public
opposition both to giving cycles any priority on road space and
to shared use with pedestrians. Some work on travel plans involving
large employers in the main urban areas did get underway, but
languished for several years prior to the appointment of a travel
plan co-ordinator. However, capital has continued to be available
for small-scale safety schemes, some of which have adverse effects
on rural road character. As the main black spots have been dealt
with, we believe this is an area of expenditure with diminishing
returns and that putting comparable sums into public education
(which of course would be revenue expenditure) might have more
widely beneficial results.
20. One area that concerns us is the amount
of effort and expenditure that has gone into project development
work that never reaches the stage of delivering results. While
technical considerations, public opposition, budgetary constraints
etc given as reasons, we wonder whether another reason is also
the fact that project development work is contracted out to Capita
Symonds with consequent less close supervision and less regular
review of what is often challenging work than would be the case
if the work was undertaken in house or through contracts that
maintained a closer working relationship with council staff. We
are also concerned that the current arrangements fail to develop
an imaginative approach to finding solutions.
Second round of plans
21. While Cumbria's Provisional Local Transport
Plan 2006 to 2011 was clearly written with the Government's Transport
Strategy and its LTP guidance in mind, it seems decidedly weak
in terms of its ambitions (except in respect of new road schemes).
No doubt budgetary issues and political will have been important
factors, but we believe the LTP process and the DfTs own guidance
have not always helped. The new plan abandons traffic reduction
and stabilisation targets for all areas except Carlisle. Targets
for public transport and cycle use are reduced to tiny increases
on the pretext that previous targets were "unrealistically
aspirational". Such targets are of course much more likely
to be achieved, but their achievement will have no significant
effect on traffic conditions.
22. It is easy to see, and to sympathise
with, Cumbria's predicament. The target of simply preventing further
decline in public transport patronage, would, on current trends,
be seen as significant achievement. Meeting the target of having
a mere 6% of employees covered by work travel plans by the end
of the plan period would still represent significant progress
in plan preparation. But neither would result in traffic reduction,
merely put a small deflection in the upward trend. At the same
time, ambitions for new bypasses, if realised, would release suppressed
demand, resulting in additional motor vehicle trips. It is hard
to see that the White Paper objective of making walking and cycling
a real alternative for local trips being fulfilled to any serious
degree.
23. The first LTP has resulted in demand
management becoming more clearly part of the agenda. However,
work on it needs to be stepped up by an order of magnitude if
it is to be at the core of future delivery rather than merely
tinkering at the edges. Furthermore, priorities, the scale of
action intended under many of the policies and the outcomes envisaged,
are not specified.
Performance management regime
24. Our perception of the assessment by
GONW of Cumbria's performance is that it has been perceptive and
fair. For example, the assessment of the second LTP identified
the lack of evidence that the environmental impact of the Plan's
schemes and policies had been fully considered. Other areas for
improvement included:
— A clearer indication of how
alternatives to future major schemes will be considered.
— Consideration of how to improve
transport outcomes through the use of revenue budgets.
25. However, when we look back at the all
too slight progress made on developing demand management measures
under the first LTP and the reduced ambitions regarding their
outcome in the second we are a little concerned that ambitions
are being tailored to those which can be more easily met in order
to achieve higher scores for delivery.
26. Cumbria's second LTP has a lack of reference
to policies and actions to reduce the need to travel, a key Government
objective reflected particularly in the ODPM's planning policy
guidance. The Plan also states that "...there are inevitable
needs to travel long distances and high dependency on cars and
lorries for travel and transport. This makes the need to accommodate
traffic essential". This suggests a continuing demand-led
perspective. Moreover, while relevant policies would not necessarily
be in a transport plan, it would be helpful to know how they and
the transport policies are integrated, or indeed whether they
are integrated, and what steps the council intends to take to
promote their integration. Such demonstration ought to be a criterion
on which the effectiveness of LTPs are judged.
27. We do not believe the Annual Progress
Reports give adequate transparency and rigour in assessing performance.
They give a flavour of the processes underway rather than the
anticipated outcomes. The scale of activity and stage schemes
are at is not always clear, and as the individual schemes achieved
are rarely identified it is not possible to judge the quality
of the achievements. Year to year changes in numerical indicators
can be misleading in the absence of real insight into what is
happening on the ground. Furthermore, particularly where behavioural
change is being promoted it may take many years for the consequences
of measures to be fully felt.
28. We understand DfT intend moving to assessments
every two years and a strong focus on the delivery of outcome
related targets. We further understand that environmental performance
will become a key assessment criterion. We very much agree with
those changes. However, we note that the rewards for delivery,
and penalties for non-delivery, affect only capital budgets. We
would suggest that if such a system of penalty and reward has
merit there needs to be some mechanism by which it can influence
revenue budgets.
Balance between infrastructure projects and travel
plan initiatives
29. We believe there is a major and serious
imbalance. The systematic development and implementation of travel
plans is perhaps the most vital part of demand management. Travel
plan development needs considerable and ongoing support, both
to stimulate plan preparation and ensure quality outcomes. Employers
and employees need to see that this is the case. With reference
to the Cumbria example above, assuming that the 6% target is met,
and if the plans influenced 10% of the journeys concerned, that
would represent a mere 0.6% of work related journeys. Ambitions
in these areas need to be stepped up an order of magnitude if
significant modal shift is to be achieved. And that will require
a considerable increase in revenue funding, together with capital
funding in due course once the necessary infrastructure improvements
to make travel plans fully effective have been identified.
30. The proposed capital allocations of
around £300,000 for travel plan implementation and £700,000
a year for pedestrian and cycle route development will enable
projects to be spread only thinly on the ground, or concentrated
in very few areas, and not give the rapid progress needed on a
scale that would make a real difference to travel behaviour.
CONCLUSION
31. The introduction of LTPs, or something
like them, was necessary in order to deliver the Government's
1998 (and later, 2004) Transport White Paper objectives. However,
while they have made progress it is disappointing that in Cumbria
the second round plan appears in many respect to be a step backwards.
The new transport agenda is a challenging one requiring a much
greater shift in resources, including revenue resources, to deliver
than the system seems capable of. Expenditure priorities need
to be changed considerably in favour of demand management measures
for real change to be effected.
24 April 2006
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