The Lothian Cycle Campaign

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

Richard Lyall
Transport Division 1/1
SEDD
Victoria Quay
Edinburgh EH6 6QQ

Dear Sir

The Integrated Transport Bill - Consultation on The Executive's Proposals

We welcome the introduction of this Bill, particularly at this early stage of the new Parliament. Our comments are as follows...

Regional Transport Partnerships [para 33-39]

We recognise the arguments in support of the general direction of these proposals. However, we are concerned that the detail is strong enough to ensure that controversial 'named transport issues' are always made the subject of a joint plan, for example even where...

• a proposed scheme falls physically inside just one authority boundary, but impacts strongly on another authority [for example Midlothian's current A701 proposals]
• a proposed scheme is supported by all nearby local authorities but is nonetheless highly controversial [eg the M74].

There should also be a requirement that agreed plans are based on wide-ranging studies, including multi-modal transport comparisons, and full consideration of related policy options such as planning permissions, development plans, traffic management and traffic reduction.

Finally, the legislation should apply immediately it is passed so that, for example, the above current Midlothian A701 proposal, which in its present form is likely to have a major detrimental effect on the City and its transport policies, would be subject to the requirement of a partnership agreement with Edinburgh Council.

Forth Estuary Joint Board [40-45]

We very much support this proposal and, as a minimum, the powers suggested in para 44. However we do not support the possible implication in para 41 that a 33% vehicle increase should be enabled to cross the Forth Bridge reliably. Rather, it should be a prime objective to reverse the trend. Thus the Board also needs to have a firm input into other relevant local authority policies such as planning, so as to minimise the need to travel across the Forth (particularly by motor traffic, though not exclusively).

One important issue which the Board will need to tackle is a balance between charging at the Forth and Kincardine bridges to ensure that vehicles do not divert to longer journeys in order to minimise the tolls they will encounter.

Bus proposals [49-71]

Although you do not propose to set minimum standards for bus partnerships/contracts, a marker should be set that there would be a normal expectation for bus services which travel out of town to be able to carry two bicycles. You will no doubt be aware of how common this is in some countries, and of the preparatory and experimental work which has already been done in Scotland, for example through the former Scottish Office Cycle Challenge fund.

Congestion charging [75-87]

We very much support the proposed powers.

However, we are concerned about the 'contract with the motorist' [79-80], and ask instead for a 'contract with the public'. There has been extensive research by various bodies which shows that whilst taxes raised from the motorist do more than cover direct expenditure on the road system, they far from cover all costs imposed on society at large by current levels of motor traffic. These include the huge costs of climate change, the huge public health implications of our increasing sedentary lifestyles, and the appalling impact of motor traffic in driving walkers and cyclists off the roads in recent years, to the severe detriment of the independence and general life-fulfilment in particular of children and older people. In other words, the motorist owes society, rather than the converse. Hence the need for a contract with the public. We the general public, need to be sure not just of additionality and transparency as you propose, but also that the above deficit begins to be tackled by significant transfer of funds from the motorist to public transport, walking, cycling, traffic calming, etc.

We strongly oppose the presumption that charging is only relevant in 'major urban areas'. There may prove to be strong cases for charging in other areas. In England, for example, the Peak District National Park is already proposing to introduce road-user charging. Research for the National Trust in south-west England reveals that the prime reason for the decline in visitors at several NT properties is traffic congestion and the unpleasantness of driving in such conditions [Countrygoer News, Winter 2000]. Other authorities may wish to impose congestion charging on roads near major out-of-town retail parks. Since all charging schemes are for local authorities to propose, and for the Executive then to approve, there is no need to begin with presumptions as to where they may be appropriate. This should depend solely on the scheme proposed and the situation to which it relates.

The Executive proposes that some public transport improvements should be in place before charging begins. We are concerned that this is not made too onerous and that, for example, improvements funded by other means such as the Public Transport Fund or councils' own capital funds count as such prior improvements. If the prior improvements are only those funded by charges, this may mean that schemes have to be implemented so far in advance that interest payments will swallow up significant sums, making the charging a less effective funding mechanism than it should be.

We support the proposal that funds raised should be used only for transport. However, this should be given a wide interpretation. For example, if it can be shown convincingly that a relocation of a business would drastically cut down on certain journeys or assist a significant shift to rail, bus, walking or cycling, there could be a case to assist that move, though with an attached condition that should the shift not occur then the funds would have to be repaid.

Workplace parking [88-91]

We strongly support these powers. However, it is unclear why Ministers will pay 'particular attention' to the views of the business community but not to the local residents, workers, and other road users, whose lives are impacted by commuter traffic.

Subsequent to publication of the consultation document there have been rumours of a national exemption for NHS hospitals. We would strongly oppose such a national exemption. We also point out that hospitals in general have been at the forefront in drawing up Green Transport Plans and should therefore be somewhat less affected by parking levies than other more tardy institutions.

We are extremely disturbed and disappointed to see that the Bill does not include at least enabling powers for charging for numbers of spaces at large retail and leisure outlets, so that such charging schemes could be introduced in future without further primary legislation. Such powers were clearly foreshadowed in Tackling Congestion [para3.4.8], the 1999 consultation document, which stated "The primary legislation will allow the Scottish Executive to extend the scope of the levy to apply to types of non-residential parking other than workplace parking, through secondary legislation". We commented strongly that actual rather than enabling powers should be included, and find it incomprehensible that even the enabling powers have been dropped. We are equally disturbed at rumours that this is due to lobbying by Tesco at UK level.

We refer you to our previous comments [19.9.1999], and we particularly repeat the views of the House of Commons Environment, Transport and Regional Affairs Committee which 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]. More recently, the same Committee has published the report Environmental Impact of Supermarket Competition. This concludes that "the large amount of free parking offered by out-of-town developments gives them a massive advantage over town-centre retailers, as well as generating extra traffic" [quote from Local Transport Today 20.1.2000]. The Committee asks the government to tackle this issue "as a matter of urgency". Regrettably, however, the absence even of enabling legislation to allow for parking-space charges at large retail and leisure outlets is a move in the opposite direction to that urged by the Committee.

Other proposals [92-97]

Whilst supporting these proposals, we suggest inclusion also of the following 'relatively minor, but worthwhile' measures, all of which would assist government and/or local authority objectives in terms of transport, environment, public health, etc.

• Legal priority for walkers and cyclists in 20mph zones, or in Home Zones. In health and safety legislation we understand that those who create the hazards must take primary responsibility for safety [Information source: Slow Speeds Initiative]. The same should be the case in all transport legislation, and even more so in slow-speed areas whose intention is to give greater safety and freedom to walkers and cyclists. This is a top priority for Home Zones to be fully effective.
• Powers to create 10mph zones easily. We understand special permission is required at present.
• Car parking should be automatically banned at all times on bus stops and on zig-zags outside schools.
• Local authorities should be permitted to employ speed wardens as they currently employ parking wardens, and they should be able to retain the revenue to use for traffic-calming or similar purposes.
• A responsibility on local authorities and the police to protect children against the dangers of motor traffic on their way to and from school, as was introduced in the 1976 Danish Road Traffic Act. We understand that as a result of this legislation Denmark moved from one of the worst rates of child road mortality in Europe to one of the best. Also, most children now walk or cycle to school (cycling rates are up to 60%), with great benefits to public health, child independence and road congestion. [Information source: Sustrans].
• The biggest single source of complaints, by some margin, which we receive from our members, is about on-road cycle lanes being blocked by parked cars. We understand from the local authority that it is much more difficult to introduce a cycle lane on which parking is prohibited than one in which it is allowed. The conditions to create car-free cycle lanes should be made less onerous.
• As regards para 97, we presume that the design of rack or bar will not be covered by the legislation. However, we support the Scottish Executive guidance Cycling by Design recommendation of the Sheffield rack as the preferred design, and we would not want anything in the legislation which in any way encouraged traditional inferior cycle parking designs such as 'wheel twister' racks which support the bike only by a wheel.

There are two major areas where we feel the legislative proposals are completely lacking, and without which their effectiveness in promoting sustainable transport will be significantly reduced. We imagine it is unlikely these will be included in the legislation at this late stage, but include them here nonetheless in view of the importance we attach to them.

• The legislation should link its measures to national and local targets for overall reductions in levels of road traffic, as in the original intention of the Road Traffic Reduction legislation.
• There should be major changes to the mechanisms of local authority transport capital funding. The present system of a block allocation covering all services, along with a Public Transport Fund for major projects, and Local Transport Strategies which are non-statutory, means that the government has painted itself into a corner whereby its ability to promote sustainable transport policies is unnecessarily limited. For example...
• The Scottish Executive is unable to (i.e. has no mechanism to) allocate funds effectively to councils in support of its recently announced road safety policies and targets, even if it should wish to do so. The Public Transport Fund would be an unsuitable vehicle for most such schemes, whilst extra allocations under the block system need not be spent by Councils on the intended purposes. In England, by contrast, the DETR has allocated additional funds, and these can be allocated effectively through government support for Local Transport Plans.
• For the same reasons, the Executive could not effectively allocate funds in supported of its stated targets under the National Cycling Strategy, even if it should wish to do so.
• The government cannot penalise a council for an inadequate or non-sustainable Local Transport Strategy, or reward and support the general thrust of a good Strategy (except sometimes, and then only in part, through refusing or approving applications to the Public Transport Fund).

Yours Sincerely

Dave du Feu
 

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