APPENDIX 19
Memorandum submitted by CTC
1. INTRODUCTION
1.1 CTC is the UK's national cyclists' organisation.
Founded in 1878, it has 70,000 members and supporters, provides
a range of information and legal services to cyclists, organises
cycling events, and represents the interests of cyclists and cycling
on issues of public policy.
1.2 CTC believes that cycling has a wide
range of benefits in many different areas of policy. These include
improved health, independent mobility for all (including children,
older people, lower income groups etc) and local economic benefits
(in urban and rural areas alike), as well as reductions in the
adverse effects of motorised travel (eg congestion, road danger,
pollutant and greenhouse emissions, noise, community severance
and the spatial pressures for increased road and parking capacity
in both urban and rural areas).
1.3 CTC campaigns for the promotion of cycling
at national, regional and local level. Our interests cover not
only the role of cycling in transport policy (including road safety,
highway planning design, influencing travel behaviour, and integration
with public transport), but also how cycling fits in with other
areas of policy: health, environment, education, traffic law and
enforcement, taxation, land-use planning and development, regeneration,
countryside access and tourism.
1.4 In addition to its professional campaigns
team who lobby at national level, CTC's local volunteer "Right
to Ride" (RtR) campaigners are active in influencing the
policies and actions of local highway and planning authorities,
as well as other key players: schools, employers, health authorities,
retailers, public transport providers etc. In recent years, CTC
has held training events for its local campaigners (run jointly
with other environmental campaigning groups) on influencing Local
Transport Plans.
1.5 CTC runs a national "Local Authority
Benchmarking" programme, a peer-review process through which
local authorities can learn from one another's successes, as well
as enabling both them and ourselves to identify and spread best
practice in delivering local cycling strategies. After three initial
national-scale Benchmarking projects run with charitable funding,
the Government has since 2003 funded CTC to run Benchmarking on
a regional basis, originally in conjunction with the former English
Regions Cycling Development Team (ERCDT). Over 70 local authorities
have now participated in the programme. CTC has documented around
300 examples of "best practice" as identified by Benchmarking
participants themselves; these can be downloaded as case studies
from the CTC website (www.ctc.org.uk: click on "CTC Benchmarking
and Action Learning").
1.6 In recent months, Cycling England (the
body now charged with delivering the National Cycling Strategy)
has appointed CTC's Benchmarking Project Manager, Tony Russell,
to co-ordinate the provision of advice for local authorities wishing
to incorporate cycling into their Local Transport Plans.
1.7 CTC was closely involved in the formulation
of the National Cycling Strategy in 1996 and, more recently, the
setting up of Cycling England. CTC was closely involved in the
preparation of the Walking and Cycling Action Plans for both England
and Wales, and has also had input to recent White Papers on transport,
public health and physical activity. CTC sits on the Government's
Road Safety Advisory Panel and the Highways Agency's National
Road User Committees at national and at regional level. CTC provides
support to the All Party Parliamentary Cycling Group of pro-cycling
parliamentarians. Recent parliamentary activity has focused on
legislation relating to Traffic Management, Road Safety and Rights
of Way, as well as Private Bills concerning transport in London
and the London "Crossrail" scheme.
1.8 CTC has also been closely involved in
the development of a new National Standard for Cycle Training,
aimed at improving the training provided for cyclists and would-be
cyclists of all ages. It aims not only to provide basic cycling
competence but to give people the confidence and skills to handle
real-life traffic conditions. The National Standard was launched
by former Transport Minister Charlotte Atkins MP in 2005, and
early evidence suggests that training to the National Standard
is highly effective in encouraging more people to cycle more often,
as well as increasing their confidence and safety when doing so.
1
2. LOCAL TRANSPORT
PLANS: GENERAL
COMMENTS
General comments
2.1 This inquiry comes shortly after non-London
English highway authorities have submitted their final second-round
Local Transport Plans (LTP2). With little reporting so far on
the national picture on LTP2, and none on the final versions of
LTP2, it is hard to present definitive conclusions about how the
quality of LTP2 submissions compares with LTP1. Clearly only time
will tell how the two LTP periods will compare in terms of actual
delivery of policy and programmes.
2.2 Nevertheless, we do feel that it is
possible to comment on the LTP2 process itself, notably the guidance
on both LTPs themselves and the associated Accessibility Planning
process. We also provide some tentative comments about our perceptions
so far of what is happening in the actual LTP submissions. These
observations are based partly on initial feedback from our local
volunteer Right-to-Ride (RtR) representatives, partly on what
we have gathered from local authority officers themselves through
our Local Authority Benchmarking workshops.
2.3 Overall, we feel that the LTP2 process
is a grave disappointment compared with LTP1 five years ago. Two
years ago, CTC attended a stakeholders' workshop run by transport
consultants Atkins as part of their project to provide feedback
to Government on the LTP process. Not only did we report being
generally happy with the LTP process, but feedback from other
stakeholders was almost entirely positive as well. Certainly there
was no call for the radical changes which later appeared in LTP2.
2.4 The differences, we feel, are largely
down to the LTP2 guidance itself. In particular, its four key
objectives, whilst laudable in themselves, are so broadly defined
and open to multiple interpretations; hence they give no clear
direction or co-ordination to the delivery of transport policy
at the local level. As regards cycling, it is from clear in the
guidance that Government policy sees it as anything more than
an optional extra—fine for those local authorities who want
to do it, but its omission would not be seriously frowned on.
This implicit message comes across particularly from the acceptance
of 0% growth in cycling as a "satisfactory" LTP target.
2.5 This same sense that cycling is a relatively
low priority is also apparent from the lack of references to other
aspects of good cycle policy and planning—we cite specific
examples below. When we met the Department for Transport (DfT)
lead official for LTPs and mentioned the early feedback from our
own local campaigners suggesting that these elements were now
being omitted from many LTP2s, he too expressed concern that what
he thought was established good practice now seemed to have been
so quickly forgotten.
Process, timescales and consultation
2.6 During our various dealings with them,
local authority officers themselves have pointed to the late publication
of the Local Transport Plan guidance as having caused serious
problems. It is clear that, in some authorities at least, the
resulting pressure on timescales have led not only to poor internal
liaison, but also to inadequate public consultation.
2.7 Our Benchmarking workshop feedback also
indicates that some cycling officers have had little or (in some
cases) no involvement in the development of LTP2 submissions.
This may be due either to the tightness of the timescales, or
to the lack of any specific requirement to refer to established
elements of good cycling planning (which would have prompted the
LTP team to seek input from the cycling officer), or the wider
sense (among local authority politicians and senior managers alike)
that cycling is not that important an element in the LTP2 process.
2.8 Feedback from out local RtR campaigners
suggests that they too have had a lot less input into LTP2 compared
with LTP1. The explanations are likely to be similar.
Weak objectives: omission of climate change and
health
2.9 Our single biggest concern about the
LTP process relates to the failure of the LTP guidance to refer
to climate change as a central objective of transport policy.
Given the emphasis which the Prime Minister has placed on the
importance of tackling climate change, and the fact that the Department
for Transport is signed up to the Government's Public Service
Agreement (PSA) on climate change, we find it hard to understand
this failure to stress its importance as a policy objective of
local transport planning.
2.10 The four objectives which were set
in the LTP guidance—congestion, accessibility, air quality
and safety—are all laudable; one would find it hard to disagree
with them. However they are not at all clearly defined, and Government's
determination to provide "non-prescriptive" guidance
means that there is little to indicate how local authorities should
aim to meet these objectives. The encouragement of cycling (as
part of a wider sustainable transport policy) could, of course,
contribute extremely cost-effectively to meeting all four of them.
However, the guidance would also allow local authorities with
little interest in cycling to argue that, for instance, their
proposals for local bypasses would remove congestion and pollution
from town centres, promote accessibility (by increasing traffic
speeds) and, if sufficient pedestrian barriers were provided,
they could also put a tick in the box against safety as well.
Despite the evident need for co-ordination of local transport
policy delivery, the LTP system is doing little to provide the
common sense of direction which is so badly needed.
2.11 As regards cycling specifically, the
LTP objectives provide a framework in which an authority which
was already keen to promote cycling could certainly make a good
policy case for doing so. However the guidance is of little help
to the local cycle campaigner seeking to persuade an otherwise
disinterested local authority that cycling was important to the
fulfilment of the Government's national policy objectives.
2.12 We were particularly dismayed that
the LTP guidance referred to health merely among the "other
quality of life" issues. At a time of rising concern, both
within Government and elsewhere, about physical inactivity, heart
disease and obesity, we feel that the potential contribution of
LTP cycling (and indeed walking) policies in tackling these issues
was insufficiently recognised.
Weak targets: 0% growth in cycling is a "satisfactory"
minimum target
2.13 As already indicated, the message that
cycling has been seriously de-prioritised since LTP1 emerges most
clearly in the guidance's reference to "no reduction in cycle
use" as a "satisfactory" minimum target for LTPs.
This was a bitter contrast with LTP1, which had included the then
current national target to treble cycle use between 2000 and 2010.
Whilst it is now accepted that this was unrealistic, it was still
preferable to a 0% target, as this aspirational target at least
indicated that there was a political impetus to achieve a step-change
in levels of cycle use. Some cycling officers have commented to
us in the course of Local Authority Benchmarking workshops that
this unambitious advice on target-setting has weakened their ability
to argue the case for cycling within their own authorities. It
has had a similar effect on not only the morale of local cycle
campaigners, but also the credibility of their arguments in the
eyes of local authorities.
2.14 Although we do not yet know what targets
have been set in final LTP2s, a report by transport consultants
Atkins2 surveyed a sample of 67 (out of 83) draft LTP2s. It found
that 78% of English local authorities contained a cycling target;
however, 10 of these authorities had set a 0% growth target, and
a further four authorities have set targets for 10% growth or
less. Most authorities (over 40%) are in the 11-20% bracket, with
only eight seeking a doubling or tripling—a far cry from
the widespread of such targets in LTP1.
Strategic Environmental Assessment (SEA)
2.15 A new report from the Countryside Agency
and English Nature3 suggests that few authorities are using the
process of Strategic Environmental Assessment (SEA) as a tool
for genuinely appraising and comparing policy options. Many are
instead "going through the motions" with the aim of
showing how their pre-determined policy choices meet Government
objectives, rather than using SEA as intended to weigh up the
performance of alternative policy options in a genuinely open-minded
way. In particular, we are not aware of authorities using SEA
to determine what impact their LTP policies (or any alternative
options they might have considered) will have on climate change,
nor any sign that Government is at all concerned about this very
serious failing.
Virtual omission of cycling from Accessibility
Planning
2.16 An important difference between LTP1
and LTP2 is the inclusion of Accessibility Planning as an adjunct
to the LTP process itself. CTC strongly supports the principle
of promoting accessibility for all, and notes that cycling is
a mode of transport which is widely available to people of all
ages and income levels. A point which is not widely recognised
is that many people with physical or other disabilities are able
to cycle even though they may have serious difficulties walking
and/or may be unable to drive.
2.17 When the draft Accessibility Planning
guidance was published, CTC was acutely critical of the almost
total failure to mention cycling, let alone to suggest a way in
which accessibility by cycle might be measured. In response, the
Government did acknowledge that this was a serious omission; however,
in the limited time available between the draft and final guidance,
they were unable to do much more than to add a few mentions of
cycling to indicate that it should indeed form part of local authorities'
Accessibility Strategies. Feedback from our local RtR campaigners
and our Local Authority Benchmarking process suggests that few
if any authorities have attempted to apply the recommended Accessibility
Planning process to cycling. This would require local authorities
to examine the barriers to cycle accessibility and then identify
and prioritise the most beneficial improvements. However, given
that the final Accessibility Planning guidance still lacks any
advice on how to do this, it would hardly be surprising if local
authorities have not even begun to do so.
2.18 The omission stems from a failure to
consider the factors which "make or break" cycle accessibility.
When it comes to public transport planning, these factors are
primarily the availability, frequency and cost of bus and other
public transport services. By contrast, the key factors affecting
accessibility for cycling (and indeed for walking), the presence
of absence of "routes" but the presence or absence fast
or busy major roads or junctions.
2.19 In an attempt to help overcome this
omission, CTC has begun to develop a methodology for assessing
the "cyclability" of any given road, based on readily
available data (traffic volumes, speeds, speed limits, safety
record and road width). We are keen to work up this methodology
in conjunction with DfT so that it can be made available to local
authorities to assist in the delivery of their Accessibility Strategies.
Speed policy
2.20 We feel the LTP guidance gave insufficient
emphasis to importance of speed policy—in terms of both
the setting and enforcement of speed limits—in achieving
wider policy objectives. Speed policy is important not only for
road safety, but can also help encourage people to switch to more
sustainable transport modes, thereby helping to achieve environmental,
health and quality of life objectives as well.
Good practices not specified
2.21 As noted previously, there are a number
of recognised elements of good practice in delivering cycling,
most of which were mentioned in the LTP1 guidance, but which were
omitted from LTP2 guidance. Our feedback so far suggests that,
as a consequence, adoption of these good practices in LTP2 submissions
is a lot less widespread than in LTP1. They include:
— Cycling Strategies—the LTP2
guidance spells out the legal obligation on local authorities
to adopt a bus strategy. However, in contrast to the LTP1 guidance,
it says nothing about developing a local Cycling Strategy. In
practice, many of the authorities taking part in CTC's Local Authority
Benchmarking programme do have Cycling Strategies, although many
of them only recognise the need for this as a result of participating
in the Benchmarking programme itself. We wonder how many authorities
who have not taken part in Benchmarking currently have an active
Cycling Strategy.
— Adherence to existing or planned
Guidance on Cycle Friendly Infrastructure, notably the forthcoming
Local Transport Notes on walking and cycling, and the Manual for
Streets (nb the draft Local Transport Note LTN 1/04 is particularly
important, as it sets out a "Hierarchy of Provision"
for walking and cycling which could help eliminate much of the
inappropriate provision of poorly designed "shared-use"
cycle facilities which so anger cyclists and pedestrians alike).
— A Hierarchy of Road Users—many
LTP1s included a statement that, in planning or designing schemes,
the needs of different road user groups would be considered in
a priority order, with pedestrians first, and cyclists close behind.
Initial feedback suggests such hierarchies are much less common
in LTP2.
— Cycle Audit and Cycle Review procedures—these
are systematic procedures for considering the needs of cyclists
in the planning of new highway or traffic management schemes (Cycle
Audit) or to identify ways of improving the "cycle-friendliness"
of the existing highway network (Cycle Review).
— The provision of Cycle Training to
the National Standard—as noted in our introduction, there
is good evidence that cycle training is a highly cost-effective
way not only to encourage more people to cycle more often, but
also boost their safety and confidence when doing so.
— Integration of cycling with public
transport—this combination provides a door-to-door alternative
to the private car for longer-distance journeys, providing benefits
for individuals, public transport operators and public policy
alike. Many authorities do in fact have partnerships with rail
operators to provide good cycle access to, and parking facilities
at, stations and interchanges. However, other initiatives to promote
combined cycle/PT journeys, such as cycle racks on buses, are
far less widespread, despite being inexpensive and straightforward
to implement, and highly beneficial where provided.
— Cycle-friendly road maintenance—in
a previous submission to this Select Committee, CTC has identified
the many ways in which cyclists suffer disproportionately from
poor road maintenance. Feedback from our local authority Benchmarking
suggests that few authorities have grasped what is required to
ensure that the needs of cyclists are reflected in their adopted
maintenance standards and procedures.
— Commitments to enforce cycle lanes
and other cycle facilities—the Traffic Management Act 2004
contains new powers which, once implemented, will enable local
authorities to take enforcement action not only against infringements
not only of bus lanes, but also cycle lanes and other cycle facilities.
So far we are not aware of local authorities having made commitments
to use these powers when available.
— Promotion of cycling for recreation
and tourism—a new report from the Countryside Agency and
English Nature shows that some authorities' LTPs do recognise
the health, social and economic benefits of promoting cycling
as a means to access the countryside, however this recognition
seems to be patchy.
— The provision of a coherent bridleway
and byway network for off-road cycling—CTC welcomes the
requirement for LTPS to include information about progress on
Rights of Way Improvement Plans (RoWIPs). Committee members may
be aware that CTC has recently lobbied successfully to ensure
that the new category of "restricted byway" can be claimed
on the basis of evidence of past use by cycles. In common with
the British Horse Society (BHS), we are keen to see the development
of a coherent byway and bridleway network which enables people
to enjoy the countryside by cycle, and we are encouraged that
the Department for Environment, Food and Rural Affairs (DEFRA)
strongly supports the promotion of non-motorised access to the
countryside. However, it is too early at this stage to tell how
far the LTP process will help in delivering this objective.
— Investment in improved monitoring
of cycle use, particularly for school and work-related travel.
Feedback from our Local Authority Benchmarking programme tells
us that local authority officers face real difficulties (particularly
shire counties) in obtaining reliable measures of cycle use. We
regret that the weak advice in the LTP2 guidance on target-setting
and monitoring was a missed opportunity to help move things forward.
LTP performance management and Annual Progress
Reports (APRs)
2.22 During a meeting between CTC and DfT
officials, they acknowledged that inadequate resources had been
put into Regional Government Office (GO) scrutiny of LTP1 and
particularly the subsequent Annual Progress Reports. Regrettably,
we do not see any evidence that this position has changed.
2.23 In particular, there appears to be
a lack of any consideration by DfT of the degree to which the
LTP system as a whole is contributing to national policy objectives.
We wonder, for instance, if DfT has carried out (or intends to
carry out) any consideration of the collective impact of LTPs
on greenhouse emissions from transport, or on cycle use at the
national level.
2.24 As regards Government scrutiny of individual
LTPs, we still await a full analysis of LTP2, however it not at
all clear whether or not LTP policies which support cycling are
being (or will be) rewarded by more favourable funding settlements.
2.25 There has been little involvement by
the Government Offices in the Local Authority Benchmarking process,
a missed opportunity for them to pick up on what is happening
on cycling in their regions. More generally, Benchmarking participants
have cited a lack of effective information flow between local
authorities and Government Offices as a factor which can make
it difficult for local authority staff to feel confident about
whether they are focussing on the right priorities, or even whether
the GO staff who are responsible for appraising their efforts
know what they have or have not managed to deliver.
2.26 During LTP1, there was at least some
compensation for this lack of GO scrutiny as far as cycling was
concerned, in that local authorities were then being assessed
by the former English Regions Cycling Development Team (ERCDT),
who were then reporting back to Government via the (also disbanded)
National Cycling Strategy Board (NCSB). The ERCDT was able to
report a significant improvement in local authority performance
between their first and second assessments (carried out in 2003
and 2004 respectively), 4 and this was clearly due on large measure
to the support they gained from the joint efforts of CTC and ERCDT
in providing them with support, including through the Local Authority
Benchmarking process which complemented the ERCDT assessments.
2.27 Even then, it is not clear how much
weight was attached to the ERCDT assessments in determining annual
funding settlements. We know only that there was a standard paragraph
which appeared in the decision-letters on LTP funding settlements
sent to all local authorities, saying that ERCDT's assessments
were a factor in the funding settlements. However, it is unclear
how or to what extent these assessments were actually factored
into the process in practice.
2.28 With ERCDT now no longer in existence,
we are very concerned as to whether Government regional offices
have either the resources or inclination to factor local authorities'
performance on cycling into their assessments of LTPs and APRs,
and when determining funding allocations.
2.29 Many of CTC's local campaigners have
persistently argued that their voices are also excluded from the
APR process. They are neither consulted on the content of APRs,
nor is there any opportunity for them to feed in an alternative
perspective to Government offices when they feel the APR is presenting
an unrepresentative picture of the progress actually achieved.
Funding: capital v revenue
2.30 CTC strongly believes in the importance,
for the promotion of sustainable transport generally and for cycling
specifically of "soft measures" (ie those aspects of
transport policy which aim to influence attitudes and awareness,
as distinct from "hard measures", ie physical infrastructure).
These require revenue (rather than capital) funding, and we—like
many both inside and outside the transport planning profession—feel
that the balance of transport funding is weighted too heavily
towards capital rather than revenue. Moreover, many authorities
are lacking in staff with the skills required to develop and deliver
an effective cycling strategy.
2.31 The LTP guidance itself recognises
the value of soft measures, citing the DfT-sponsored report on
"Smarter Choices: changing the way we travel"5 as evidence
that these measures can be highly effective in tackling congestion.
Measures requiring revenue include: information and promotional
activities (eg Travelwise, or participation in "Bike Week"
or "In Town Without My Car" week); individualised marketing
initiatives (eg the highly effective TravelSmart programme run
by sustainable transport charity Sustrans); cycle training; and
the development of travel plans and other partnership working
with schools, colleges, employers and the health sector. The "Smarter
Choices" report actually cites an average benefit:cost ratio
of 10:1 for the measures studied, a truly impressive figure which
puts most capital investment to shame. Yet the LTP guidance still
declines to make dedicated revenue available for transport. This
makes it difficult, if not impossible, for local authority officers
to make commitments more than a year ahead about what revenue
they can commit, since this is subject to annual internal negotiations
between Councillors and departments, across the whole range of
a local authority's activities.
2.32 Feedback through our Benchmarking process
indicates that local authorities themselves have had variable
success in their efforts to have promotional campaigns treated
as capital spending (eg by linking these with specific capital
projects), depending on the approach taken by individual District
Auditors. The Department for Transport and Treasury jointly need
to address the problem, either by clarifying what can and cannot
be treated as capital, or (preferably) by provided dedicated revenue
for local transport spending.
Best practice
2.33 There are many examples of best practice
which could be cited, covering all aspects of local cycle strategy
delivery: policy and target-setting, cycle facilities and other
"cycle friendly infrastructure", partnerships with schools/colleges/employers/health
trusts etc, marketing and promotion. We enclose a selection from
the many which have been identified through our Local Authority
Benchmarking programme (see www.ctc.org.uk).
2.34 Whilst these examples demonstrate what
is possible within the existing policy framework, they still remain
exceptions; the LTP process has not enshrined them as the norm.
Moreover, regrettably, we are far from confident that the LTP2
framework will encourage good practice to become more widespread.
Indeed, the lack of political impetus behind cycling, apparent
in LTP2 guidance would suggest that, if anything, the opposite
is more likely.
3. CONCLUSIONS
3.1 Any attempt to draw conclusions about
the LTP process is inevitably tentative at this stage. However,
the limited evidence so far available suggests that the following
observations are probably justified:
— The Government seems to have little
idea of what impact LTPs have had, or will have, on wider policy
objectives, notably on climate change, but also on promoting cycle
use and its health and other benefits.
— The late publication of the LTP2
and accompanying Accessibility Planning guidance has hampered
both internal and external consultation in many authorities.
— The reference to 0% growth as a "satisfactory"
LTP cycling target has signalled to local politicians and senior
officers that pro-cycling polices are effectively "optional",
being a much lower priority than in LTP1.
— Cycling is hardly featuring at all
in local authorities' Accessibility Strategies, due to its virtual
omission from the original draft guidance and the lack of any
indication in the final guidance on how it should be addressed.
— This sense of cycling being a lower
priority more generally in LTPs, and the lack of specific references
to key elements of good cycle policy, means that local authority
commitment to those elements (such as the "Hierarchy of Solutions"
as set out in the Government's Local Transport Note LTN 1/04)
is much weaker than in LTP1.
— The continuing lack of availability
of revenue for local transport plans, and the uncertainties over
what can be treated as capital, are hampering efforts to deliver
"soft measures", despite their acknowledged cost-effectiveness
and the wide range of transport, health, environmental, social
inclusion and other objectives to which they can contribute.
— The lack of good data on cycling
at the local level, or guidance on the most cost-effective ways
to increase monitoring capacity, is also hampering progress on
cycling, not least because local authorities and others still
have little information on what measures are most effective (and
cost-effective) to promote cycling.
3.2 We are grateful to the Committee for
the opportunity to contribute to this extremely important inquiry,
and urge it to make recommendations aimed at tackling the issues
outlined above.
April 2006
REFERENCES1 Cycle
Training UK. Survey on the effectiveness of cycle training.
CTUK, 2004.
2 Atkins Consulting. Review of provisional
second Local Transport Plans. Atkins, 2005.
3 Countryside Agency and English Nature. The
Treatment of Landscape, Biodiversity, Access and Recreation in
16 Provisional Local Transport Plans. CA/EN, 2006.
4 English Regions Cycling Development Team. End
of project report. ERCDT, 2005.
5 Cairns S et al. Smarter choices;
changing the way we travel. DfT, 2004.
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