The Lothian Cycle Campaign

SPOKES The Lothian Cycle Campaign

St. Martins Church, 232 Dalry Road, Edinburgh EH11 2JG 0131.313.2114 (answerphone) http://www.spokes.org.uk/

19 September 1999

Stuart Johnston

Scottish Executive Development Department

Transport Div 1

Victoria Quay

EDINBURGH EH6 6QQ

Dear Sir

TACKLING CONGESTION - CONSULTATION

In general we welcome the proposals in this consultation, and hope that implementation will be as rapid as possible, consistent with full attention to the points below.

Before turning to the questions you raise, we wish to comment on four general aspects, and will refer back to some of these from relevant questions.

A Aim of the consultation

The consultation is entitled "Tackling Congestion". This is a very restricted view of what should be the objectives of the proposals, and indeed the text does recognise other aspects although placing congestion at the top. Other objectives which should be seen as equally important include...

 
• Raising additional funds for sustainable transport initiatives, and for maintenance; although certainly not for providing additional motor traffic capacity. See (D) below. We also take this opportunity to remind the Executive that, despite the promise in the Labour Scottish Parliament Manifesto of "extended" support for cycling, so far there is no sign of this happening. Instead, there have been above-inflation increases in the trunk road budget (albeit for maintenance), whilst the Public Transport Fund has remained static at £30m p.a. - and in any case its very title and the Guidance do not suggest any priority or "extended support" for cycling as a means of transport. At the same time, the government has failed to ensure increased priority for cycling from local authorities, as local authority cycle budgets have been falling for the last 2 years (in parallel with falling local authority overall transport budgets), as shown by our annual survey. The only positive area of cycle funding has been increased amounts from external agencies such as Sustrans, Europe and the Lottery, but even some of these sources are likely to decline soon with the end of Millennium funding schemes.
• As one in an armoury of measures to assist in moving closer to the position in which motoring pays the full economic and environmental costs which it imposes. We are pleased that the document acknowledges that there is a current deficit.
• As one in an armoury of measures to manage demand for motoring to assist in meeting Britain's obligations on Climate Change, and the objectives of the Traffic Reduction Act. We are pleased that the document acknowledges that it is not sufficient just to encourage sustainable modes, but that motoring demand must also be managed (and of course many other measures across other policy areas such as education, planning, development, etc are required).

B Non-workplace charging for numbers of parking spaces

We are extremely disappointed that this option is not intended to be allowed to local authorities at the initial stage. It is quite impossible to understand the reasoning behind this decision, as the arguments in the UK White Paper point very convincingly in this direction, despite the conclusion being in the opposite direction! It is difficult not to give credence to the press speculation that the decision results from pressure from the supermarkets.

The argument you give that retail and leisure operators should work with local authorities to develop sustainable access is particularly weak in that exactly the same argument could be used to dismiss workplace charging! Also, councils have already been advised of the need to work with major retailers/leisure operators to ensure Green Transport Plans etc, but we do not believe this is happening other than in a few isolated pockets. Councils are still granting permission for supermarkets etc without even including the basic requirement of a Green Transport Plan. We do not believe that retail/leisure operators are likely to take this issue really seriously until they have a financial incentive.

The government's line on this issue has been heavily criticised by the local authorities who are expected by the government to progress sustainable transport policies [Local Transport Today 17.12.98, 11.2.99]. The House of Commons Environment, Transport and Regional Affairs Committee concluded [April 1999, para 259] "Local authorities should be allowed to introduce customer parking charges where they think it is appropriate. We recommend that schemes for customer parking charges be included in the pilot projects that have already been proposed to evaluate road user and workplace parking charges, or the subject of separate trials". [Note: we understand 'customer parking charges' to include the option of the charge being levied on operators, for the number of spaces, rather than necessarily directly on customers].

Indeed, the somewhat ludicrous position has been reached that some councils are now proposing to institute road user charging on the approaches to large retail developments as a way of getting round the inadequacy of the government's proposals! The above Committee [para 258] has also advised promoters of road-user charging to try and design their charging proposals to encompass such developments!

From the political point of view, charging operators for numbers of non-workplace parking spaces could even be popular with the public. For operators such as supermarkets, where each car space is used repeatedly during the day, the charge levied per car visit would almost certainly be so low as not to be administratively convenient to charge to the parking motorist. [eg a PNR annual charge of approx £100 per space would mean only 1p-2p per car visit]. Nor would the charges have a noticeable effect on prices in the store. However, the aggregate sums levied on the operator would be sufficient to make operators far more likely to institute green transport measures such as cycle parking and routes, bus links, home deliveries, etc; all of which would be popular with the public!

Finally, if for some obscure or political reason it is deemed that only one of workplace or non-workplace charging should be implemented initially, then it is very arguable that non-workplace should be the initial priority. Workplace charging, whilst clearly useful in cities, is perhaps more questionable in other areas - see for example the reasoning in West Lothian Council's submission to this consultation. Charges for numbers of spaces at large retail/leisure outlets, in contrast, are valid in all areas and, owing to the limited numbers of such premises, far easier both to implement and to effectively enforce.

We hope even at this late stage that the Executive will change its mind and allow non-workplace charging as one option for local authorities to experiment with, along with the other charging options they are being given. If however this is not agreed, then at the very least a fixed and early timetable should be set for the review of policy on this issue, promised in 3.4.8.

C Distortion/diversion resulting from charging regimes

Although supporting parking and road-user charges, we are extremely concerned over possible distortions to motorist or employer behaviour which may result, and which could be very detrimental to walkers, cyclists, local residents, to minimisation of motorised travel, and to sustainable transport policies in general. For example, workplace charging could result in increased on-street parking, or could cause workplaces to relocate to places less accessible except by car; motorway charging could result in diversion onto all-purpose roads, and so on. Our concerns are strongly supported in the above House of Commons Environment, Transport and Regional Affairs Committee investigation into the Transport White Paper.

These issues are recognised in the document, but we feel they must be highlighted, as they are critical, not just to our members, but to charging becoming a publicly acceptable policy instrument. If charging proposals result in unreasonable distortion/diversion, the political backlash could be such as to ruin individual schemes or even to remove credibility for the entire policy. In particular, every charging scheme proposal of every variety must include a very thorough assessment of likely diversion/distortion, and every final scheme must incorporate countermeasures as an integral part of the scheme and of its financing. There must also be scope and financial leeway for further countermeasures should they prove necessary - but there must be no question of 'waiting to see' if diversion happens and postponing countermeasures till then.

Indeed, to ensure public acceptability and to further sustainable transport policies, it would make sense to ensure that all charging schemes, as an integral part of their design, aimed to improve conditions in surrounding areas. Taking motorway diversion as an example, the scheme could incorporate traffic calming in adjacent communities and on adjacent rural or all-purpose roads where there is currently need and demand for such measures but absence of the necessary funding. These measures would be designed not just to counteract diversion or its effects, but to improve on the previously prevailing situation, as part of the transport objectives of the overall charging scheme. Similarly revenue from workplace charging could be used to provide measures to ensure that nearby cycle lanes were made free of car-parking. We emphasise that all such measures must be integral to the entire scheme and its finances.

In terms of minimising distortion related to road user charging, we support the proposals by a number of councils (eg Falkirk and W.Lothian) that road user charging should be based as far as possible on low charges paid at a large number of locations rather than large charges paid at a small number of locations.

D Use of revenue

Revenue from all charging schemes [local authority and government, parking and road-user] should be used only for sustainable transport purposes. This should have a wide interpretation including, for example ...

• Measures which effectively reduce the need to travel, or to travel such long distances. For example, support for local services and employment, where it can be convincingly demonstrated that this does reduce motorised travel. Furthermore, any such scheme should include measures (such as bus or cycle lanes, or pedestrianisation) to ensure that any road capacity freed up is not filled by induced motor traffic.
• Road maintenance [from road-user charges].
• Road schemes which tackle danger.

E Comments on selected paragraphs

Local authority charging [workplace and road-user]

1 Our comments in (C) above are crucial here. The necessary countermeasures and enhancements must be an integral part of the scheme and its finances. Note that charging over as wide a geographical area as possible (regional or even national) is likely to reduce distortion (although workplace charging in non-city areas may bring other problems; see C above).

7 There should not be a maximum limit. Also, local authorities should have powers to set up a scheme in which charges gradually increase (possibly at a pre-announced rate), rather than being introduced at a fixed high level. This would allow individuals/organisations time to adapt. In such a scheme further consultation should not be necessary at the time of increases which were a planned part of the scheme.

13/14 For repeated violations by individuals, removal of the driving license should be the ultimate sanction.

20/21 For the reasons stated, there should certainly be no exemptions here. These organisations need a full incentive to institute Green Transport Plans.

22 No - but local charging schemes should be allowed to permit charities to contribute some or all of their levy to a Green Transport Plan, provided the local authority deems it to be an effective plan. Also such a conditional exemption should be applied to other voluntary organisations if a suitable definition of such organisations, which is not too administratively cumbersome, can be found.

23 No, for the reasons given.

24 No, for the reasons given [except possibly for charities and voluntary organisations, as in 22]. Moreover, many organisations have now shown that an effective Green Transport Plan does lead to a reduced parking requirement, so it is not just "arguable".

25 No - it is an added complication, with no clear rationale. At most there should be an exemption for one vehicle only, on the grounds that this would assist very small businesses and that a vehicle, or space for a vehicle, may be required in emergency situations.

26 This dilemma would be avoided by adopting (B) above.

27 An appeal based on exempt vehicles being counted should not be allowed if the number of non-exempt vehicles exceeds the licensed numbers.

30 Yes, for several reasons. It is important for public acceptability. Secondly, a scheme should only be approved by the government if the intended use of the revenue is in furtherance of sustainable transport/planning policy - and certainly not for increases in motoring capacity - see (D) above. Thirdly, the requirements in (C) above must be integral to this statement. We would agree to some flexibility in the wording, for the type of reasons given in (C), but for any major change of purpose an amendment order should be required.

31/32 The levy should certainly apply, for the reasons given.

Motorway and Trunk Road charging

33/34 See (C) above. The complementary measures must be an integral part of the scheme, fully funded by the scheme itself (not in part by local authorities), and as suggested in (C) should aim to improve conditions on adjacent/parallel roads and in nearby communities - both for transport/environmental reasons and also to help ensure public acceptability of a controversial policy. There should be no question of local people having to suffer for this policy.

Note that recent TRL research [Reports 349 and 357] has indicated under various reasonable assumptions, and with no countermeasures, a likely diversion of 10% of traffic onto alternative rural or local roads, and a possible 20% increase in fatal and serious accidents relative to the previous numbers on the motorway - but now also presumably involving non-motorway users. Such an outcome would obviously be extremely serious for cyclists on rural routes, and for cyclists, walkers and local residents on local roads, and would run totally counter to other government transport objectives. Note also that already 50% of cyclist road deaths are on rural roads. Therefore we insist that an integral and required part of any tolling scheme must be bike-friendly traffic calming, provision of alternatives, and/or other measures as appropriate on potential diversion routes and in relevant communities, to prevent all but minimal diversion, and to improve conditions as described in (B).

36 Exemptions should be at the absolute minimum. Rather than giving exemptions, for example for disabled people as suggested, part of the revenue could be used to provide improved public transport accessibility, or improved local services reducing the need to travel long distances, or other means of improving accessibility [see (D) above].

38 There is no reason why both workplace and road-user charging should not apply - it is not a question of double charging. Also, road charging is paid by the driver [though sometimes recompensed by the employer] whereas workplace charging is normally paid by the employer. Similarly the 'encouraging modal shift' effect of road-user charging is largely aimed at the driver, whereas in workplace charging it is largely aimed at employers (getting them to set up Green Transport Plans etc).

Yours Sincerely

Dave du Feu

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