Environment Audit CommitteeWritten evidence submitted by Derek Halden, DHC

1.0 Summary

There remain many market and policy pressures that lead to poorer access for some people. Markets serve majority populations better than minorities, and accessibility benefits are often sacrificed by public agencies and service providers to achieve single sector efficiency goals. Despite these difficulties, accessibility goals have increasingly become more explicit in policy over the last decade, and progress has been made checking that accessibility needs are being met, and tackling identified problems.

The implementation of accessibility planning as envisaged by the SEU in 2003 is still work in progress.1 Faster progress could be prompted by changing how transport investment decisions are made, and nurturing new professional practices.

The transport industry views improving accessibility as its core business, but is often unclear about who has benefitted from transport investment, and for what trip purposes. More auditing is required to ensure that accountability is clearer. Only a minority of transport authorities have so far embraced the opportunities of accessibility planning, and the general culture of transport planning and delivery continues to be focused on promoting more mobility, which does not always lead to greater accessibility.

Accessibility planning in the transport sector, parallels similar evidence led, people focused, partnership delivery initiatives in other sectors. Initiatives for people and patient focused care in health, and child centred learning in education, adopt very similar principles, and have faced similar challenges. People focused approaches should be distinguished from client and customer service improvements, since non users can be the main beneficiaries.

Transport related social exclusion is still widespread. Despite improving accessibility being the policy rationale for investing in transport, the current public funding of £20 billion+ for transport each year may still be making more impact on growing travel demand than improving accessibility; perhaps also creating more exclusion than it solves; and compounding land use changes which continue to make some essential services less accessible.

Without the improvements made through accessibility planning over the last 20 years, accessibility in the UK would be worse, the economy weaker, society more unequal, and there would be more emissions from transport.

2.0 Evidence Base for This Response

2.1 This response draws evidence from experience over 20 years of accessibility planning, and has been prepared by DHC founder, Derek Halden. Derek helped to introduce and implement accessibility policies within the Scottish Office between 1991 and 1992,2 and subsequently researched the theory and practice of accessibility planning at the Transport Research Laboratory until 1995 at a time when the concept was gaining ground within policy.3 Since 1996 DHC has pioneered many aspects of the practice of accessibility planning. DHC developed guidance for the Scottish Executive between 1998 and 20024 and subsequently along with University of Westminster developed accessibility planning processes in England from 2003 to 2005.5 Since 2006, DHC has been helping DfT to prepare the national accessibility statistics referenced in the call for evidence.6 References are made to some of this work, as footnotes.

3.0 Q1—How are the Government’s current transport policies affecting the accessibility of public services?

Access to services is very much better than it might have been, but the implementation of accessibility planning in transport policies is still work in progress.

3.1 The case for government action is greatest where there is market failure. With levels of accessibility falling for many people as travel times and costs rise, tackling these problems is probably the greatest market failure in transport. Yet transport investment and delivery still tends to emphasise market pressures, such as road congestion, rather than market failure, such as the inability of people and businesses to meet their travel needs.

3.2 Since 2003,7 when a new cross governmental co-ordinating role on accessibility was allocated to DfT, there have been two distinct transport sector roles in improving accessibility:

As a champion for cross-sector action for better accessibility

Delivering improved accessibility through transport.

3.3 The first role could potentially be led by a non-transport government department, and this was considered by the SEU in 20023. Government is seeking to redefine its role as a champion for the needs of citizens, rather than just a provider of public services,8 so transport was selected as the sector best suited to championing accessibility change.

The transport sector as a champion for better accessibility

3.4 Although the theory of accessibility planning can be perceived as complex, the practice is actually very straightforward. Accessibility planning checks that needs are being met, and organises solutions to the identified problems. In 2003 the SEU noted that no government department was formally responsible for either checking or organising, and as a result other pressures were leading to a decline in accessibility for many people. Transport’s wide ranging remit and covers issues like checking that, when land use changes or public service delivery is re-organised, citizens can still access the new sites, and then ensuring that transport and other complementary changes are made to secure access for all. Some elements of this have worked better than others.

3.5 Becoming responsible for accessibility requires that there must be some accountability for failure if accessibility gets worse. However few people working in transport yet perceive their role as critical in checking that health departments do not inadvertently make accessibility worse when they re-organise service delivery, or education authorities do not inadvertently build new schools in inaccessible locations, or that land use planning authorities avoid permitting developments which lead to the closure of local accessible grocers. The pressures on accessibility have continued to increase since 2003, and the transport sector has only partially checked the impacts of the changes, or organised solutions to identified problems.

3.6 Practical progress has been achieved by DfT championing the cross sector agenda through the annual publication of accessibility statistics. DHC has calculated these for DfT each year since the statistical series started, and we have observed the encouraging use being made of these statistics by many government departments and campaign groups.9 Examples can be identified where decisions of the Departments for Health, Work, Justice, and other departments have been influenced by accessibility statistics, and have delivered more accessible solutions as a result.10

3.7 In the call for evidence, the committee refers to these statistics11 and summarises some results for populations that were considered to be within “reasonable” travel time thresholds. As far as we are aware, when publishing these statistics the Department for Transport has always avoided making judgments about “reasonableness”. DfT is responsible for checking for change, and prompting co-ordinated action, so the indicators are used to support these roles. DfT has sought to ensure it does not inadvertently blur the clear accountabilities for accessibility within each tier and sector of government12 so has used continuous indicators for monitoring. For example access to health is a statutory Department for Health responsibility, but transport authorities can usefully prompt action by health authorities if checks on accessibility reveal that the travel time or cost of reaching health services is increasing.

3.8 Much more could be done. If transport departments nationally and locally were formally required to report annually to their colleagues in other departments and sectors their concerns about accessibility issues, then this might prompt more action. This is discussed below under local transport planning, but the same principles apply nationally. A cross sector reporting requirement would prompt DfT to raise issues with other departments and help to keep accessibility planning on national agendas. The 2003 SEU conclusion, that accessibility would continue to be seen as a secondary order problem by all departments unless specific action was taken, is pertinent.

3.9 The national analysis is based on travel time. Time is a necessary condition for access, but is only one of many parameters. In the future it should be possible to add more dimensions to accessibility statistics, but in the meantime other dimensions of access can be considered in more local analyses and include the personal capabilities of each group of people.

3.10 The travel time to local services and facilities is regarded internationally as a factor of increasing importance when determining the livability of a place. The DfT statistics are seen a pioneering example, since they include not just drive times to facilities, but walk, cycle and public transport travel times. Ensuring that each resident of the UK can walk and cycle to as many local services as possible is not just good socially and economically, but ensures that local access choices are competitive with longer distance travel. Transport authorities have achieved many successes securing local access improvements as part of place making, regeneration and neighbourhood planning agendas. The new focus on accessibility has provided a policy framework for this joint working. Research has shown that previously roads and public transport managers had found it difficult to relate their job description to these wider goals and accessibility planning has helped to overcome these joint working problems.

3.11 Using statistics requires care. The national statistics have shown a steady increase in the travel times to hospital which is partly misleading, as only some hospital services have been centralised, with others now being delivered from more accessible local health centres. The statistics challenge practitioners to ask relevant questions, to prompt further action.

Delivering better accessibility through transport investment

3.12 If we “follow the money” then most transport practitioners have little incentive to support accessibility planning. When local shops and services close, people need to travel to more remote locations, so the transport sector grows with financial benefits for all those that work in the transport industry. One of the aims of giving accessibility planning responsibilities to transport authorities was to ensure that accountability was clear for delivering better accessibility for all—not just more transport.

3.13 However, policy statements about improving accessibility are often vague, and delivery often does not optimise accessibility benefits for all citizens. Some have argued that separate funding is needed to deliver accessibility plans providing a funding incentive, but, other than for training and pilot project development, this is not either what the SEU suggested in 2003, or what we recommended in 2004 to DfT on how to implement accessibility planning. With £20 billion+ of public funding being invested in transport each year, a relatively small fund to support accessibility improvements would make only a small impact compared with re-aligning mainstream transport investment to be consistent with accessibility plans. We therefore recommended accessibility audits of all transport investment, to ensure that transport delivery is consistent with accessibility aims.

3.14 These audits could be part of requirements that all government funded transport investment should be consistent with NATA (New Approach to Transport Appraisal). Many improvements to transport appraisal have been made to NATA since 20034 but transport appraisal remains poorly integrated with accessibility planning for the following reasons:

Transport appraisal remains focused at growing the transport economy, rather than the wider economy and society, and wider issues are considered only as factors for mitigation.13

In NATA, mode shift from car to walking is regarded as a negative economic effect, as it transfers value from the transport economy to the wider economy. Instead of looking at opportunities for access by walking, NATA uses the concept of severance to demonstrate how road and rail infrastructure might make local walking trips more difficult rather than valuing walking trips in their own right.

Transport efficiency is measured in the economic appraisal, but transport effectiveness in delivering accessibility improvements is only partly covered and even this relies on a complex proxy measure called “transport option value”. This was introduced in 1998 and we have yet to see an example of this type of analysis being performed successfully outside major rail projects. As a result NATA notes that the transport option value criterion remains in draft.

The recent introduction in 2012 of the personal affordability appraisal requirement is extremely welcome, but has not yet had time to work its way through into widespread practice.14 This new 2012 requirement also reports the consistency of transport investment with local accessibility plans which also for the first time recognises local accessibility planning as relevant to transport investment decisions. Personal affordability is not the only NATA criterion that needs to be better grounded in local accessibility plans.

3.15 A corollary of not understanding the benefits for people, is that technical appraisal is less useful than it should be in supporting decisions by elected representatives15 and voters. For example, transport minister Norman Baker alluded to this when he highlighted the Alloa railway project as an example of how transport delivery happened despite, not because of, transport appraisal rules. Just as child centred learning in education needs to use techniques that can be used by parents, teachers, social workers and health professionals, so the transport planning toolkit needs to change to support more integrated delivery approaches. For example, the current DfT analysis and reporting requirements, despite their recent revisions, would do little to help the transport sector work well with Job Centres to improve access to work.16

3.16 If the most common trips made by UK residents to access local stores and services by walking are still regarded in transport appraisal as being of no value to the transport economy, it is of no surprise that high streets are starved of the transport investment needed to make them pleasant, attractive places to visit. Local walking trips are the most environmentally sensitive, socially inclusive and economically efficient ways to ensure good access.

4.0 Q2—Are other policies (such as planning, education, health, welfare and work etc) adversely affecting the accessibility of public services and the environment? Do decisions on the location of public services adequately reflect available public transport infrastructure and the environmental footprint of the transport needed to access them? How significant are any adverse impacts for accessibility and the environment?

Core business is viewed in narrow single sector terms with cross sector concepts like accessibility being regarded as secondary issues, but clear public accountability for all sectors is assisted by the publication of evidence of accessibility change

4.1 Most public service providers have statutory responsibilities for ensuring that all people can access their services. Most aim to discharge that responsibility by concentrating on their core values in health, social services, education, leisure services, employment services, legal services, and other provision, and informing transport providers about the transport difficulties. However transport departments could not possibly fund all the transport needed without a massive increase in transport budgets as they currently spend far less on revenue support for transport than other sectors like health, social services, and education. Accessibility planning has sought to deliver better value joint approaches, but tactical budget dumping has undermined progress. Better accessibility is an overlapping policy aim between transport and other policies, but turning these shared policies into jointly funded solutions has been more difficult.

4.2 A classic situation which has been repeated many times across the country has been as follows. A health authority wishes to build a new hospital and selects cheap land since this makes better use of the health budget. Planning agreements then often fail to secure the long term investment in transport needed to compensate for moving the health services from an accessible to an inaccessible location, and transport authorities are faced with picking up the costs of dealing with support for public transport, congestion on the road network, and social exclusion amongst health users unable to access healthcare. There have been examples where transport authorities have used their accessibility plans to change NHS plans, but these remain the exception.

4.3 Accessibility audits of land use plans were introduced to land use planning policy in 199517 and most planning authorities continue to support development in more accessible locations. When we reviewed the practice on this in 1999 we found that a few enthusiasts had used the opportunity of the new policies to apply accessibility planning, but this practice was rarely seen as core business by local authorities. Core business was viewed in narrower single sector terms. For example, a senior authority staff member summed up the accountability challenge, by noting that “nobody loses their job because accessibility gets worse, but if the potholes are not filled then there is trouble”. Therefore when the SEU started to look at the topic a few years later we highlighted accountability as a key issue.

4.4 The new approaches since 2004 for accessibility planning have sought to make it easier for employment, health, education, social services, environment, and planning departments to invest more efficiently and effectively in accessibility for staff and clients. However there is far more failure of these partnership schemes than success. Where joint cross sector schemes have been established, it has not taken long for each sector to seek to tactically withdraw their funding in the hope that other sectors will pick up more of the costs.

4.5 This race to the bottom continues to be damaging for both accessibility and the environment. Less accessible services mean that people travel further and use more resources. This longer distance travel congregates particularly on networks such as motorways and railways, leading to a growing list of infrastructure investment requirements for transport departments to fund. Some longer distance travel choices add value to accessibility, but catering for these choices within limited budgets at the expense of local investment is a false economy.

4.6 It is clear that greater support is needed from Government if accessibility is to be improved. There is evidence of public demand for such action, with public protests being common when changes are made to the locations of public services. As predicted by the SEU in 2003, there is less clamour within government to be accountable for such a complex issue as accessibility. Although transport authorities were given responsibility for leading accessibility planning, they cannot ultimately be accountable if a land use planning, health, education, or other authority makes a decision that causes accessibility problems, since ultimate accountability must follow the more narrowly defined legislation. Transport department objections to decisions in other sectors based on accessibility concerns are rarely viewed as commanding sufficient significance to change policy, and are not often made with sufficient force to secure the investment in accessible solutions. This blurring of accountability means that accessibility continues to be regarded as a secondary issue by both transport and non-transport departments who continue to focus on issues where they can be held more directly to account. The accountability problems identified by the SEU in 2003 still apply, and this continues to be a difficult issue to resolve.

4.7 Declining accessibility is viewed as an inevitable problem by some stakeholders, but there is a gap between public expectations of accessibility and current delivery which must be tackled. As we noted in 2004, there are few easy answers, given the polycentric power structures of a modern democracy, but if mandatory annual audits of accessibility are published as discussed above, then a more constructive dialogue with the public and between public authorities should deliver such solutions as are practical.

5.0 Q3—Is the Government’s current approach of requiring the accessibility of public services to be reflected in local transport plans working? How effective is the Department for Transport in furthering the accessibility agenda?

The scale of culture change in transport has been underestimated, and future success requires stronger leadership and incentives for short term delivery.

5.1 Local transport plans do not in themselves determine what happens but help to manage, structure and co-ordinate diverse investment programmes. Local authorities that view the need for a local transport plan purely as a legacy of a system where they used these documents to bid for national capital funding will probably not deliver anything useful by following an accessibility planning process.

5.2 In our recommendations to DfT in 2004, we highlighted that one of the main barriers to progress would be the culture and skills in the transport profession. There had been concerns in the Cabinet Office about giving an agenda like accessibility planning to transport professionals, since the profession was known for its strong analytical skills and modal passions, rather than its interest in people and their needs. Staff with people skills would be more likely to choose professions other than transport.

5.3 However we argued, as did many others, that transport was not unique in having a better track record of operational delivery than people focus. Similar changes were taking place in other professions to deliver more people centred services. However managing such culture change in transport was a substantial undertaking. DfT has made a start in nurturing the change, but a step change is needed in the scale and scope of action, if accessibility planning is to thrive in all parts of the country. Currently only a few leading authorities are delivering accessibility planning as envisaged in 2004.

5.4 The best performing transport authorities will succeed largely without help from DfT. Managing culture change relies on spreading good practice across the country. In 2004 we recommended top level communications about the new policy focus, and a parallel support system to foster change across the profession. The top level communications about the new accessibility planning requirements were supported by senior DfT staff visiting every transport authority to explain the changes. This was very helpful in raising the profile of the initiative, but the practical support for the profession was restricted to a small training programme which ran between 2005 and 2007. The sessions were not typically attended by professional leaders and little attempt was made to get the professional institutes on board, who set professional standards in the industry, or to change the education of transport professionals.

5.5 Confusion about the new top down policies for accessibility planning was compounded as commercial marketing of software filled the gap in the need for more training. The transport industry has a strong business and training infrastructure to support modelling and analysis of transport systems, so the new accessibility planning market was targeted as a business growth opportunity. As a result most professionals across the industry were offered sales pitches and training on software. Although accessibility planning is an evidence based approach, and modelling can be part of that, within a few years many professionals confused accessibility planning with modelling. This was also comfortable for the transport profession, re-interpreting the new requirements in terms of existing analytical skills, rather than the new people and partnership focus which had been intended.

5.6 It is interesting to observe that accessibility planning for the Olympic Games in London has demonstrated best practice and lessons about how to manage change. The needs of each group of people were systematically considered, and by working in partnership, ways of meeting each need were planned through a range of transport and non-transport interventions. Translating this success into wider accessibility planning, requires a similar time limited focus, with an expectation that failure will not be acceptable.

6.0 Q4—How should the transport-related accessibility of public services be measured? How can decision-making in government better reflect “social” and accessibility impacts, alongside environmental and other considerations? Do social and accessibility concerns conflict with environmental considerations? Would a measure of the transport accessibility of key public services, in a similar manner as “fuel poverty”, be useful for policy-making (and if so, how should it be defined?)

If each tier of government measures what it values then the prospects for delivering what is valued are much improved.

6.1 There are few right or wrong answers about how to measure accessibility. However it has been shown repeatedly that attempts to measure such a complex concept with a single measure fail. In defining these measures the following key points may be helpful:

As relatively simple supply side measures showing opportunities for people, accessibility indicators are modally agnostic about transport systems, can include the impact of telecommunications networks as alternatives to travel, and can be adapted to fit a very wide range of situations. They are therefore well suited to help focus on people, and manage the modal tribalism that can make transport a politically unstable sector.

The flexibility of the measures is their strength, but also a weakness if inappropriate indicators are used tactically to misrepresent benefits, eg to secure investment or planning permission.18

Once a focused aim is clear (eg reducing the costs of travel to further education in xxx for 16–19 year olds by 50%) then a suitable accessibility measure can be defined to represent the policy. Policies should drive indicators, not vice versa.

Sustainability requires a balance between social, economic and environmental perspectives. Pursuing any of these goals in isolation is unsustainable. Accessibility indicators have proved to be one of the most practical types of measure to help planners manage the trade-offs to achieve sustainable development including transport systems. However accessibility indicators have been widely abused in support of plans for transport schemes. It is important to recognise that transport investment should serve accessibility goals for people, not vice versa.

Emotive measures like “fuel poverty” have a place in motivating action, but concepts like poverty of access are difficult to define if adverse unintended consequences are to be avoided. Relative accessibility for different mobility groups is usually the safest way to define inequality. For example ratios of accessibility for car and non-car available access are helpful. The Institution of Highways and Transport has recommended ratios of travel time by car and public transport to implement the accessibility requirements in planning policy,19 and ratios of cost are similarly revealing.

6.2 It is important to avoid unintentionally setting ill-defined policies through accessibility measures. To ensure clear accountability at each level of government we recommended in 2004 that accountability for accessibility should be resolved internally within each level of political authority. However there was pressure from the local authorities on the central and local working group on accessibility planning (CLWGAP), for stronger national leadership to assist with the local promotion of the new national policies. The local authority representatives felt that they could more easily create momentum for a new programme if there was a mandatory national requirement—eg to ensure that everyone living in an urban area lived within 10 minutes travel time of a grocer. The indicators adopted by DfT respected both positions, with thresholds in the national indicators to illustrate reasonable benchmarks for urban areas, but with performance monitoring based on continuous indicators to avoid setting unintended targets. These principles should still be valid for future accessibility measurement.

7.0 Q5—The impact of broadband networks and the Internet in mitigating the need for transport infrastructure to access public services

Electronic networks are already included good accessibility planning practice

7.1 Broadband networks and the internet are changing many aspects of transport provision. It is common to focus on the substitution of transport access with electronic access, but most of the evidence shows that the complementary effects will be at least as important as the substitution effects.20 Future planning of transport and electronic networks needs to be as closely integrated as possible to ensure complementary benefits for access. As noted above, accessibility analysis lends itself to a common treatment of transport and electronic networks to describe the connections between people and places. Accessibility planning therefore supports practical decisions to ensure cost effective opportunities for all, whether or not the improvements are to transport or electronic networks.

29 August 2012