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SPOKES response to Transport Consultation Document 'Developing an integrated transport policy'

November 1997

As a group which has played an active role in the development of cycling policy in Edinburgh over the last 20 years, Spokes very much welcomes the opportunity to comment on the new Governmentís Consultation Document on transport. This is an important document which will help to set out a framework for the countryís future transport policy. Many of the suggestions contained in the paper represent a welcome re-appraisal of priorities and it is very encouraging that the government also seems prepared to re-allocate resources within the transport budget. However, it is Spokesí view that this new policy framework requires further development if Government is to realise the aim of a truly sustainable transport system.

The role of cycling in an integrated transport policy

The most fundamental failing of the document as published is its very minimal emphasis on cycling (and walking) as modes of transport. Instead, the document concentrates very much on ways of improving public transport as an alternative to car use. It is our view that an integrated transport policy cannot claim that title unless it addresses and includes all modes of transport, including cycling and walking. Furthermore, we believe that the characteristics of cycling make it, and not public transport, more likely to "offer a genuine alternative to the door-to-door flexibility of the car" (Para. 6). We would not like to see the new Government regressing to the "bad old days" when official DoT policy was to discourage cycling because it was too dangerous; rather, we are anxious that the new Government builds on the work of the last in working towards and perhaps even surpassing the targets for cycle use set out in the National Cycling Strategy.

Cycling has the potential to be an important mode of transport for a number of reasons:

The potential of cycling is obviously not being realised in the UK at the current time - unlike in countries such as Germany, where 11% of trips are by bike, and in cities like Apeldoorn in the Netherlands, where more than half of all trips are by bike. Freiburg in Germany is another example of a city which, through the provision of traffic calming and improved infrastructure, has significantly increased its rates of cycling whilst continuing to prosper economically - indicating that growth in car use is not an inevitable accompaniment to economic growth. If we are to progress towards such levels of cycle use, the Government needs to ensure that cycling is perceived as much safer, and also that it is more convenient and faster than travelling by car. Means of so doing are suggested in our answers to the "27 questions" at the end of this response.

Car ownership and mobility

We believe that there are good reasons to attempt to limit the growth in car ownership in the UK and not to treat it as an inevitability, as the consultation document tends to do. Once a car is acquired by a household, use of other modes of transport falls substantially. Pilot schemes such as the City of Edinburghís City Car Club and car free housing, which aim to reduce car ownership, should therefore be much more widely encouraged. There is still a tendency in the document to see mobility as an objective and a good thing. Mobility will be maximised by encouraging car ownership and the dispersal of activities. Instead, the Government should work towards maximising accessibility to facilities by all modes.

The role of land-use planning and other mechanisms for reducing car use

Spokes agrees that it is vitally important for the land use planning system to be used to reduce the need to travel, and that local authorities are encouraged to review their planning policies with this in mind. It is very important that at the detailed level of development control, proposals for major schemes are carefully examined to ensure that cycle access and parking are at least as convenient and safe as those for car drivers. However, the land use planning mechanism will at best be a long term and somewhat blunt instrument for reducing the demand for travel, and there is a need for other - economic and fiscal - measures to be used in tandem with land use planning measures if the full benefits of the latter are to be realised. It is for this reason that we are in favour of local area road-pricing; Spokes is, however, opposed to trunk road tolling as we believe it would divert traffic onto unsuitable local roads which are already used by cyclists.

Public transport

This should be better integrated with cycle use. The National Rail Authority should introduce uniform national conditions of carriage for cycles and ensure that new rolling stock has adequate cycle space.

Role of trunk roads in an integrated transport policy

Building new trunk roads focuses a great deal of transport capital spending on one mode, to the exclusion of other, more sustainable modes. Rather than conducting a review of the trunk road programme alone, Spokes believes that these new transport schemes should be assessed on a multi-modal and objectives-led basis, as this is likely to lead to a more detailed consideration of the role of cycling than has perhaps been the case up to now, and may lead to the conclusion that a new road is an inappropriate solution. This approach could, it seems to Spokes, be usefully applied on an area-wide as well as a corridor-specific basis.

New trunk roads have been shown by the previous Governmentís own SACTRA report to induce new trips by car. If and when new roads are built, then, a mechanism must be put in place to limit the number of trips made on the new road and to target its use at that type of traffic (e.g. long-distance freight) for which it was intended. Finally, cycling should be considered in the development of all trunk road schemes: there should in other words be a standard "cycle audit" for such projects, and proper cycle facilities provided.

The 27 questions

  1. The aims are too general. Since local authorities are now by law required to draw up Road Traffic Reduction plans, it follows that the reduction in traffic levels should be an aim. It should also be an aim to reduce traffic speeds. As mentioned above, the document should make much more of the potential of cycling.
  2. It is correct to conclude that "carrots" will not have only a marginal effect without "sticks", particularly for those people who are already heavily reliant on their cars. The introduction of incentives to use sustainable modes requires resources which may be financed from fiscal disincentives to use cars. To make disincentives acceptable it may first be necessary to introduce incentives, but this will require expenditure "up-front".
  3. Our current transport system could best be improved in the following ways:
    • Diverting resources from the trunk road programme to more sustainable modes.
    • Slowing road traffic to reduce numbers and severity of accidents.
    • Concentrating on low-cost measures such as bus priority, cycle facilities and traffic calming.
  4. It is vital that we consider ways of restraining the use of private transport. These could be pricing-based, fiscal or regulatory. Their effect on personal mobility need not be negative if the resources (road space or money) are used in such a way as to improve alternative modes. Traffic restraint is essential if quality of life - and hence regional and national economic competitiveness - are to be enhanced.
  5. It is important that road users are made aware of the marginal social cost of their choice of mode. Regulation is not a good way of achieving this; pricing and taxation must be altered/introduced instead. Regulation will however be helpful in setting the context within which more subtle methods of affecting peopleís travel choices can be set. Regulating (by permit) access to certain sensitive areas could be more politically acceptable than pricing in some circumstances.
  6. Plan to build things more closely together; reduce parking requirements; consider the transport effects of concentrating services at large isolated sites (e.g. very big hospitals); increase residential densities; tax parking for customers at large shops and return it through the business rate to small independent retailers.
  7. Targets are a useful tool, since they help us to find if our transport policies are taking us where they are intended to. The relevant levels of government do however need the powers to achieve them, otherwise they are meaningless, and they should be regularly reviewed. National targets should be more general but should be reflected in more specific targets set at the local level. They can take several forms:
    • Overall targets for e.g. modal split.
    • Targets measuring inter-related objectives: for example, that x% of people should live within y% cycling distance of local facilities such as schools and shops.
    • Targets for the implementation of new infrastructure e.g. Railtrack to raise line speed to 100 mph on x miles of line.
  8. New income streams can be introduced by increasing petrol tax; taxing company cars and parking more heavily; increasing and decriminalising enforcement of traffic and parking offences; and by developing road pricing. Cycling has been starved of funding by successive governments in spite of the low cost and excellent value-for-money of most cycling schemes.
  9. Cycling and walking can also be improved to make them more attractive to car users. The most important aspects of public transport to improve to make it more attractive to car users are reliability, speed, boarding time, availability of integrated ticketing, and comfort. Some of these are down to operators, but highway authorities must also be prepared to allocate more road space to buses even when conventional cost-benefit models (which over-emphasise travel time) do not give a positive result.
  10. There are sound reasons for replacing road tax for trucks with a mileage-related tax to act as a disincentive to lorry-use and to encourage smaller scale local production and distribution centres. The new tax should ensure that the average lorry pays more for using the roads as, at present, such vehicles do not pay nearly enough to reflect the external cost which they impose.
  11. Government has accepted the need to manage the demand for surface transport; the logical extension of this is to air transport, whose environmental disbenefits are proportionately much greater. The Government must press the EU to introduce a tax on aviation fuel; departure taxes should be increased; and domestic air travel in particular discouraged by fiscal means. Monies raised could be used to help fund high-speed rail.
  12. The pursuit of the "eco-friendly" vehicle over the last 25 years has not solved congestion and pollution problems in the USA. The solution is to reduce the amount of travel overall, rather than to seek technical fixes.
  13. An initial step in Scotland would be to integrate trunk road planning into other land-use planning. A more strategic approach could be taken by giving a wider role to existing and new PTEs (see below) and by ensuring that low-density out-of-town development is not permitted where it is not already well-served by public transport. At the level of the individual development it is crucial to ensure that access by bike, on foot and by public transport is more convenient than by car; that car parking spaces are limited to levels lower than those found in city centres and that a charge is levied for their use; and that developers commit themselves to a "modal split" for trips to their development, for which they must pay an agreed amount into a public transport/cycling/walking infrastructure fund if they do not attain the target.
  14. It is possible to use the taxation system to give some reflection of wider environmental and social costs by, for example, fundamentally altering the taxation of company-subsidised travel (the tax system currently rewards un-necessary travel on company business); differential sales and road tax depending on vehicle size and fuel type; and increasing fuel tax (while restoring full fuel duty rebate for low sulphur diesel bus fuel). Taxing these items is more progressive than many other forms of taxation.
  15. However, given that the same road user will impose widely varying social costs on others depending on when and where they drive, it is not possible to use the existing taxation system to accurately reflect such variations. Further research is required to assess the marginal cost of road use at different times and under different conditions.

  16. PTEs should have an enhanced role which should include control of strategic roads in their areas (similar to the roads responsibilities of the Traffic Director in London and the DTI in Dublin). As they are no longer bus operators, they should merge with the Traffic Commissioners and act as the regulators of the bus industry, monitoring (enhanced) entry standards, providing public transport infrastructure (including that on the highway) and letting contracts on an area basis to bus operators.
  17. Find some way around the uncertainties of annual funding. Ensure that local authorities spend the money they get on the projects set out in their TPPs (which should be much shorter documents, produced bi- or tri-annually with annual updates) - an incentive to this would be to grant further funding only if projects funded at an earlier stage are implemented. Introduce the package bid in Scotland and restore ring-fenced transport capital funding.
  18. There is without doubt a case for greater use of economic instruments to influence how people travel. The money raised from parking taxation and road user charging should be controlled by local authorities or PTEs who can decide whether to use the money to fund alternatives, or whether to return it to local people through council tax and business rate rebates.
  19. Urban traffic measures should give priority to buses, cycles, pedestrians, the mobility-impaired and (where appropriate) deliveries. They should also actively seek to restrain private car traffic by making journeys by car slower and less convenient than those by alternative modes. They should also be used to test the hypothesis that traffic can be "deduced" by reductions in capacity in the same way that increases in capacity have been shown to induce additional trips. Appraisal methodologies should place a reduced emphasis on travel time savings and a greater emphasis on the achievement of objectives; these, and environmental costs and benefits, should be quantified.
  20. Economic growth is increasingly dependent on (perceived) quality of life. Controlling/reducing pollution and congestion from traffic is fundamental to maintaining and improving quality of life. The document should recognise this rather than implying that there is a dichotomous choice between on the one hand economic growth and on the other the environment. Other forms of industrial assistance (e.g. direct incentives for firms to locate in particular areas) are more likely to promote economic development than is the construction of new roads.
  21. This list of priorities is correct only if it also includes cyclists and pedestrians!
  22. The rural road user imposes few externalities when driving in rural areas, but there are many rural dwellers who regularly drive into congested (sub)urban areas to work and shop. Thus there is an argument for increasing fuel tax in rural as well as urban areas: the money raised in rural locations could be returned through Council tax, business rate rebate, or improved local bus services so that poor people in rural areas have a choice not to own a car.
  23. The introduction of (sub)urban road pricing will have to be accompanied by more stringent planning controls in rural areas close to urban centres if road pricing is not to lead simply to more urban decentralisation. This vital point must not be overlooked.

  24. Any awareness campaign should seek to make speeding and thoughtless parking as socially unacceptable as drink-driving.
  25. This can best be achieved by speed reduction on all types of roads; this will require the introduction of speed regulators on private vehicles. In the meantime, decriminalisation of most traffic offences and greater enforcement of them on a self-funding basis would go a long way to reducing traffic speeds, particularly in urban areas where there are more vulnerable road users.
  26. By emphasising the role of slower modes, which are used to a greater extent by women, the elderly, the poor and children, such policies cannot fail to enhance social inclusion.
  27. Taxing car use encourages services such as home delivery, which benefit the mobility-impaired. Incorporating the needs of these people into the appraisal of new projects - a "disabled audit" similar to the "cycle audit" suggested above - could also help to make the transport system more accessible for the mobility-impaired.
  28. Some progress can be made towards this aim by making special attempts to involve them in transport decision making. At a basic level, these groupsí accessibility needs can be better met by cutting speeds of general traffic, developing Safe Routes to School, and enforcing parking regulations to reduce obstructive parking at dropped kerbs, crossings and bus stops.
  29. Transport must play a central role in achieving air quality targets; it cannot do otherwise, as the benefits of technical improvements to engines and exhausts will be outstripped if traffic growth continues unabated.
  30. Issues specific to Scotland

    • The Scottish Office should have a duty to ensure that a Scottish cycle network is provided, rather than simply providing assistance to Sustrans which is after all a non-statutory charity. This would go some way to affording a Scottish cycle network the same status as the Scottish road network.
    • At the local level the Scottish Office should require all local authorities to develop a Local Cycling Strategy, as English councils must now do. This could include targets for developing cycle networks in all towns over a certain population, for example. The English TPP "package" bids appear to be one means of assessing the respective roles of different modes in meeting specific local transport objectives, and in this regard it is to be regretted that the TPP system of funding local transport capital projects has been abandoned in Scotland. If a similar mechanism were to be introduced here, it would be one way to ensure that local authorities in Scotland play their part in developing a integrated transport policy.
    • There should be national targets, set by the Scottish Office, on cycling accessibility, and the Scottish Office should require local authorities to set similar local targets. Such targets should aim to ensure that, for example, x% of people would live within y% cycling distance of local facilities such as schools and shops.
    • There is a need for an ongoing national transport awareness campaign to emphasise the need to reduce car travel and to make more trips by sustainable modes. This should also stress the health benefits of cycling.
    Once again, thank you for the opportunity to contribute to this consultation process and we hope that we will see our comments incorporated into transport policy in the forthcoming months and years.
 
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