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Memorandum from CPRE South West
South West Parliamentary Regional Select Committee: Inquiry into transport in the South West, July 2009
Introduction
1. We welcome the opportunity to input into this review. We are mindful of the particularly difficult issues facing planners in the region, with a population of which more than 50% lives in rural locations. The region also has the largest proportion over retirement age of any English region, with major consequences for planning for the period up to 2026.
2. Our specific focus here is on rural issues as it is here that we feel that there is a particular challenge for planners. This requires exceptional understanding of how rural areas operate when it comes to appropriate spatial, economic and transport planning, and an ability to think laterally - beyond the norms of economies of scale.
3. We are encouraged by the statement in the Proposed Changes to the draft Regional Spatial Strategy (RSS) that "The RSS looks forward to 2026 and provides a broad and long term development strategy" (para 1.2.3). However we are concerned that the much improved transport policies in it are not supported by adequate delivery plans.
4. We fully support para 5.1.6 that places emphasis on making urban areas work more effectively whilst creating attractive places to live: "This will involve the implementation of demand management measures in the SSCTs that reduce reliance on the car, encourage use of sustainable modes and reduce the impact of transport on the environment".
5. But the urban areas have a role in providing jobs and services for the rural areas too, and at the interface there is much more opportunity for imaginative solutions. Just as in a river basin the small flows of stream water gradually come together to make the measurable and powerful flows of rivers, so the initially small numbers of traffic from rural areas come together to confront urban areas with major congestion problems. The missing key to managing transport well is to have a traffic equivalent of the river basin network - the most efficient and sustainable means of managing the flows.
Q1* Whether transport provision in the South West is adequate to meet the demands placed upon the region;
· Transport provision is failing to meet the needs of sustainable communities in the rural areas of the South West. The costs to the public purse of high levels of individual commuting and leisure travel should be assessed, and become the basis for a reappraisal. Much more innovative solutions are required, with the new round of park-and-ride schemes being particularly outmoded.
1.1 Although there have been welcome attempts to improve some rural bus services they still lack the publicity and promotion necessary to make them an economic success. The last ten years have seen rapid growth in rural road traffic. Meanwhile overall rural bus provision has declined or stagnated, and in some rural authority areas the information and facilities are not of a standard that helps bus provision to compete with the private car.
1.2 Many incoming residents to rural communities are well off and able to afford personal transport, and this has exacerbated the challenging economics for rural services. These are often communities where up to30% of their residents are without access to a private car, but the progressive loss of local shops and post offices has made travel to towns essential.
1.3 We are realistic about the revenue implications of better rural provision, but believe that better linkages between policies on transport, housing and economic development will begin to show how such investments will be cost effective over the whole spectrum of public service and provision.
1.4 We believe that there is not the capacity in the region, between the Local Authorities and the South West Regional Development Agency (SWRDA), to achieve this. At present the organisational and contractual structures make it difficult for the problems facing rural services to be managed as a whole.
1.5 Where rural travel into urban congestion has been tackled it has tended to be at the point where it becomes a problem - ie at the urban end. This has resulted in Park and Ride (P&R) schemes which while reducing urban congestion at least initially, have some bad side effects:
- encouraging car owners to drive from rural to urban, rather than supporting and therefore encouraging further rural regular services; - further discriminating against regular bus users; - diverting considerable funds from walking/cycling and safety schemes; - often encroaching into valued edge-of-town green/recreational space.
See Appendix, for references on park-and-ride.
· We would like to see criteria, or even targets introduced for investment in provision of interconnected walking/cycling and bus/rail opportunities.
2.1 While broadly supporting the main goals of Delivering a Sustainable Transport System: Consultation on Planning for 2014 and beyond (DaSTS), we would like to see them applied to the rural situation.
2.2 All the economic analysis shows that the strength of the South West economy lies in some large part with the quality of its environment - including its tranquillity. However the major transport interventions proposed in the rural parts of the region have largely been geared towards increasing overall road capacity. Yet there is an increasing recognition that the Department for Transport's role should include 'helping people reduce their need to travel or switch to lower carbon mode' - as is stated in the Secretary of State for Transport's foreword to the DaSTS report.
2.3 We would also like to see an immediate review of how Local Authorities are matching up to their obligations to address issues of social inclusion in rural areas. So often the argument is that everyone in a rural area has to have a car, ignoring the needs of the elderly, the young, and those who on rural wages cannot afford more than one vehicle per household.
Q3* How these priorities should be reflected in the upcoming Regional Transport Strategy;
· We would like to see focussed measures, addressing particular issues: prioritising interconnected walking/cycling and bus/rail opportunities; making best use of existing transport networks (including improving reliability across the whole public transport network, demand and traffic management); and addressing the dependency of leisure and tourism on the car.
3.1 An example where we have expressed concern about a particular intervention was the widening of the M4/M5 in the region of Bristol to improve capacity and in theory to relieve the strategic network. This project made no alternative provision for the predicted increase in medium distance commuting along the motorway. Consequently much of this new capacity is already taken up with growth of commuting, responding to active encouragement from estate agents in Weston super Mare, Taunton and beyond.
3.2 The aim of the emerging RSS is to reduce the need to travel through spatial planning, but the results will be longer term. Local authorities should be required to demonstrate through a scoring system how schemes proposed contribute to reducing emissions, encouraging modal shift and enabling greater take up of public transport provision.
3.3 As stated in DaSTS: "Overall, we must ensure that the aggregate level of emissions declines over time in a manner consistent with our greenhouse gas targets. There is no evidence at all that technological improvements alone will tackle the growth in emissions: we need to switch wherever possible (our underline) to less damaging modes to meet our travel needs."
3.4 In the short term the RTS needs to make behaviour change the top priority with a combination of demand management and investment that will make the alternatives more attractive - walking/cycling and public transport. The emerging strategy is not ambitious enough: its implementation plan still has a long list of road schemes which run counter to managing the demand for car travel and undermine policies elsewhere.
3.5 On
preparing Regional Transport Strategies, we would draw your attention in
particular to
3.6 However the proposals list, included in the draft SWRFA2 document, taken together do not add up to the "step change" in transport provision anticipated in the region's Strategies. In fact in a number of places they would contribute to new problems and will require even more expenditure in the future. This is true particularly of those schemes which are simply accommodating existing pressures, but not making provision for more carbon efficient transport systems or links to interchanges.
3.7 "Journey reliability " has been introduced as a key criterion for evaluation of schemes, and has often been cited as a reason for further road building. However within the South West rural areas journey reliability on roads is rarely an issue: savings created by recent road investments can be counted in a very few minutes at most. The RTS must focus instead on improving reliability across the whole public transport network, as well as quality.
3.8 For rural road users, the accident rate on rural roads - particularly rising accident levels for other road users (walkers, cyclists, riders) associated with excessive vehicle speed - is of more consequence than journey reliability.
3.9 Road traffic management should be a priority: for example on the A303 where flows are seasonally high, and road accidents have been cited as a major reason for further dualling. On this road speeds are frequently well in excess of the national limit, and as a result we continue to recommend traffic management and detailed road design improvements to enable this route to meet its requirements without major engineering projects.
3.10 The RTS must address the car dependence of leisure and tourism. Our papers for the Examination in Public (EiP) of the draft RSS commented on the current increase in road traffic resulting from leisure trips[1]. This has particular relevance to the South West given the very high levels of housing growth proposed for the region. In our earlier submissions on the SWARMMs multimodal transport study we commented on the importance of addressing inter-connectivity of public transport to achieve modal change for tourism. This needs to include easy transfer between train and bus and facilities for bike and baggage handling. The latter is particularly important - for both tourism and local people - in view of the rising age profile in the region noted above.
3.11 We have also proposed that a much more robust requirement should be made of the airports through the RTS to provide real improvements to public transport land access, whilst a regional recommendation of the SWARMMs study was improved rail linkage to Heathrow. The proposed approach to the expansion of Bristol airport falls lamentably short of the reductions necessary if we are to see overall falls in CO2 emissions in the region.
· We advocate a switch in existing investment (not necessarily an increase in funding) resulting from a different approach to evaluation of proposals. This needs to include investment in local authority skills in sustainable transport.
4.1 In recommending a step change towards traffic and demand management, increased investment in "soft" measures and public transport we are conscious that this often requires switching capital investment from road provision to other forms, and that this in turn has some revenue implications.
4.2 However the statistics already gathered illustrate that, for example, the value for money from P&R investments is considerably lower than that from major walking and cycling innovations, which give some of the highest returns on investment, and have the added advantage of encouraging healthier modes of living.
4.3 If the wider consequences (on health, reduced greenhouse gas emissions, and further road/parking investments as a result of encouragement of more car use in rural areas) are taken into account we believe the case for a step change is undeniable, but it will require a different approach to evaluation of proposals.
4.4 There will however be some necessary other investments, in capacity,
experience and skills on behalf of planners. Evidence shows that softer
measures are harder to plan and out of our comfort zone, but are cheaper to
provide, deliver greater value for money, and in the long run avoid the
creation of further bottle necks and problems that mark many road building
schemes. Our experience from the RFA process suggests that local authorities in
the South West often lack access to the necessary expertise for planning
integrated public transport schemes, demand
management and the "soft measures" necessary for a forward vision (see revised
Q5* Whether the current arrangements for prioritising, approving and funding infrastructure projects are effective and appropriate;
· A more transparent regional scrutiny system is required at an early stage to ensure that schemes are listed and then worked up which genuinely fit the criteria. We would welcome a robust scoring system, or target percentages for the proposed schemes, to show how DaSTS principles are being met.
5.1 This would enable a far more informed discussion of proposals to follow. We commend the process developed for affordable housing advice for RFA in the South West, where appropriate proportions for urban, brown-field and rural focus, etc have been considered and discussed with stakeholders through, for example, the Regional Housing Forum.
5.2 Local transport authorities are not required to achieve a clear overall reduction in emissions. Those we have challenged have stated they do not have the capacity to evaluate the implications of a scheme. Without such appraisals at the planning stage emissions from transport will continue to rise, putting other elements of the economy under pressure.
5.3 We have major reservations about the links made by planning authorities between road building and regeneration. There is still a given assumption that the relationship is clear, and that no other form of stimulation of the economy is as effective. While urban regeneration may follow an intervention, it is by no means automatic that it will: viz the Planning Inspector's report to the Westbury eastern bypass proposal (K3930/V/07/1201863) which was partly justified as necessary for economic development: "However, there is little evidence of how the scheme would encourage
sustainable economic growth or reinforce social cohesion. Taken as a whole, the
route and details of the design would be out of context and harmful to the
landscape in the terms of
5.4 During the widely welcomed process for analysis and discussion in Regional Funding Allocation Round 1 (RFA1), the Regional Environment Network's members argued for development and support for integrated public transport schemes. It was noticeable that LAs were often putting forward schemes that had been worked up against the background of the previous ten years, tackling local congestion on the roads, providing bypasses to town centres or providing access to new sites.
5.5 We had hoped that the support shown for the new guidance would have resulted in schemes put forward for RFA2 that would truly look forward to addressing the pressures and requirements of 2026. We were therefore very disappointed to see continued support for schemes which certainly would increase pressure on important recreational and conservation landscapes, and encourage more use of the private car.[2]
5.6 We are also concerned that the new arrangements for regional planning will not of themselves improve the Local Authorities' ability to develop schemes for submission.
Q6* Whether the region is doing enough to promote environmentally friendly
transport; · The simple answer is 'no' - a step change in approach is required. Policy in the emerging RSS needs to be strengthened, for example, to require that urban extensions at the SSCTs - and extensions to smaller towns across the region - are developed with the same high standards for sustainable transport as outlined in the advice for the Government's proposed eco-towns[3].
6.1 CPRE welcomes those urban schemes which are starting to promote environmentally friendly patterns of travel, such as in Plymouth and Bristol, although even here we have concerns that some unexpected consequences may be increased car use in suburban areas.
6.2 There are real barriers to the development and delivery of similar schemes in rural areas, particularly as it remains the case that the marginal cost of running a car is less than the cost of using bus and train on many routes in the region. We would welcome a thorough re appraisal of the operation of buses in the interests of the bus user. We would also like to see a tighter requirement on local authorities to plan and develop integrated public transport opportunities. Furthermore we would like to see a re-evaluation of the perceived benefits of on-route competition, which in our view results in poor quality services and poor timetabling.
6.3 We are worried at the ability of some shire counties to meet
the needs of rural residents and their service/employment needs. We would like
to see positive engagement in promoting towns and larger villages as focuses
for local people and a facing up to the need to plan for regeneration and job
creation based on alternatives to the car. Sadly the new spending criteria for
investment by SW
6.4 We welcomed, for example, the recommendations of the Bristol Bath South Coast study. The railway line from Bath - Salisbury and beyond is a particularly important line for school and college pupils, as well as having a high level of usage by many adults who are socially disadvantaged. There is capacity in the line to carry a considerably better service and we are disappointed that despite the addition of a few carriages, people are still being turned off trains at peak times, and the service leaves much to be desired in terms of quality and bus links. There is opportunity for the wider use of such measures as quality contracts to ensure such improvements in bus and rail along the corridor.
Q7* The role and effectiveness of regional bodies, such as the Regional Development Agency and South West Councils, in identifying and addressing transport issues;
· There is no strategic regional body with a lead on sustainable transport that can help the South West Councils to achieve the necessary step change in their working and facilitate delivery of the DaSTS principles.
7.1 For example the South West Councils retains a desire to see the A303/358 retained as a second strategic route, despite the conclusion of the SWARMMS study that the economic benefits were only perceived. In contrast ... the rail element para 3.14 (Wider Economic Impact Appraisal) "is potentially significant in terms of achievement of regeneration objectives" ( 69 and 55 minute reductions Plymouth-Paddington and Penzance-London.)
7.2 We continue to advocate investment in skills, added value, knowledge base and indigenous employment opportunities (as per the focus of Cornwall's Objective 1 plan) as a more sustainable and innovative base for business. We believe that a continued emphasis on providing more road access could undermine this more localised development, and challenge the quality of the environment.
· It is desirable to retain the Regional Funding Allocation process, but with improvements (See above and Appended letter to the Minister Paul Clark, April 2009, attached.)
Appended documents
NB This paper draws on our experience and submissions on regional transport planning in the South West in recent years. All our submissions can be found on our regional website: www.cpresouthwest.org.uk under Our work/transport or Our work/ planning - where our comments on the Regional Transport Strategy chapter of the emerging RSS can be found for the draft RSS (2006), EiP (2007) and Proposed Changes(2008) stages. Here we append simply our recent letter to the Minister expressing our concern about Regional Funding Allocation Round 2 (April 2009).
July 2009
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[1]We understand that the most recent England day visits survey indicates that recreational users typically travel 17.2 km to visit a countryside site for the day and the longer distance of 25 km to visit a coastal site. [2] We welcome recognition of this in the recent decision by the Decision of the Secretary of State for Communities and Local Government re the Westbury bypass. [3] Town and Country Planning Association, 2008: Eco-towns transport worksheet. |