Memorandum by Friends of the Earth (TYP
INQUIRY INTO THE GOVERNMENT'S 10-YEAR TRANSPORT
Friends of the Earth (FOE) is very pleased to
respond to the Committee's request for evidence. FOE believes
that developing an integrated and sustainable transport system
is one of the greatest challenges facing the Government. For the
past decade FOE has campaigned for policies to reduce traffic
levels as a way of addressing all the problemseconomic,
environmental and socialposed by the way we travel. We
believe it is worthwhile to recap why this is so, and do so before
answering the Committee's questions. First, however, we present
our analysis of the state of the Government's transport policy.
In the 1997 General Election campaign, the Labour
Party said that it would "reduce and then reverse traffic
growth"1. In June 1997, the Deputy Prime Minister, John Prescott
said: "I will have failed if in five year's time, there are
not many more people using public transport and far fewer journeys
by car"2. These statements were made in response to growing
public concern about the environmental, economic and social effects
of traffic growth. The problems leading to this public concern
are, in many cases, as great now as they were when the statements
were made, if not greater.
FOE believes that the Government has back-tracked
consistently from its pledges, not because of a failure of policy,
but firstly because of insufficient resolve and subsequently because
of a loss of nerve. In "Transport 2010", the Government
moved back even further from its early vision. There now seems
to be little clear direction to transport policy. The Government
seems to be muddling through. This has had a knock-on effect on
transport policy at local level which has become much more cautiousparticularly
in urban areas. However, FOE does not believe that attempts to
integrate transport policy have failed. They have not been properly
A month after being re-elected, Tony Blair laid
out his Government's challenge: "our second term mission
is to make real and lasting improvements in our public services"
referring to education, health, police and public transport3.
The Prime Minister also acknowledged the scale of the country's
transport problems in his New Year message and press reports suggest
transport is viewed as the Government's biggest Achilles heel4.
FOE believes that the Government must use the review of Transport
2010 to re-affirm its commitment to public transport and to the
integrated transport policy and deliver the resources necessary
to reduce traffic levels, particularly in urban areas. The Prime
Minister told Labour's 1998 conference that he would rather be
right than popular. FOE believes that introducing traffic restraint
policies may cause the Government initial unpopularity, but that
in the end the policies will be seen to be both right and popular.
Traffic levels have a huge impact on UK business
through congestion, particularly in urban areas. Estimates from
the CBI put the cost at £15 billion annually. Other estimates
are higher still. The Government has made tackling this problem
a key aim of Transport 2010. However research by Professor Phil
Goodwin has shown that, across the full road network, even with
full implementation of the plan, "the average forecast change
in speed is slightly less than half a kilometre per hour (about
a quarter of a mile per hour), giving a time saving, at average
speeds, of 1.6 seconds per kilometre travelled"5. The time
savings are greatest in London (about one minute for a six mile
journey) but average speeds on rural roads and motorways will
fall. But, as is shown below, full implementation of Transport
2010 in relation to urban areas is unlikely. Congestion charging
and workplace car park charging on the scale envisaged are doubtful.
FOE believes that the Government must reinvigorate plans to reduce
traffic in urban areas if congestion is to be cut.
The Government says that "climate change
is one of the most serious threats facing the world's environment,
economy and society . . . the devastating floods, droughts and
storms we have seen in the UK and across the world in recent years
show all too clearly how vulnerable we are to climate extremes
and how devastating they can be"6. Transport is the fastest
growing UK source of emissions of carbon dioxide, the main climate
change gas. The Government's latest figures on climate change
gases show very worrying trends for transport. Total carbon dioxide
emissions in 2020 are forecast to be 3.8 per cent below those
of the base year (1990). Over the same period, carbon dioxide
emissions from transport are forecast to be 28.1 per cent above
those of the base year. Transport's share of carbon dioxide emissions
is forecast to rise from 23.8 per cent to 31.7 per cent7. The
report comments that "most of the forecast increase is from
road transport, resulting from a growth in incomes, a consequent
rise in the levels of car ownership, greater travel and a greater
demand for goods and services"8. The Government claims that
it will still be able to meet its Kyoto Protocol target of a 12.5
per cent reduction in greenhouse gas emissions by 2008-12 and
its unilateral target of a 20 per cent reduction in emissions
of carbon dioxide from 1990 levels by 2010. This second claim,
however, is disputed by Cambridge Econometrics9. Irrespective
of where the truth lies in this "battle of models",
it is certain that traffic reduction will make it easier for the
Government to achieve its targets.
The Government has recently proposed a new air
quality standard for PM10 particulate matter of 20 µg/m3
as an annual mean10. The Government's own analysis shows that,
under typical climactic conditions, and even with a package of
new technological pollution-reducing measures, this target level
will be exceeded alongside 1369 road links in the UK11mostly
in urban areas. FOE's analysis of this data shows that over half
of these road links are in the poorest 20 per cent of council
wards in the country. Short-term exposure to particulate pollution
is estimated to cause up to 8,100 people to die prematurely in
the UK every year, bringing forward the death maybe by months
or more12. Long-term exposure to particulates is a further growing
concern. In Britain's towns and cities, where the majority of
the population lives, road traffic is responsible for much of
the particulate pollution. It produces the majority of particulate
emissions in Birmingham, Liverpool, Manchester and Newcastle,
and is the largest single source in Bradford, Edinburgh, Glasgow,
Leeds and Sheffield13. The threat posed by particulate pollution
provides a particularly poignant justification for traffic reduction
in the areas affected.
The Government has also recently expressed its
concern over levels of ground-level ozone, which are set to rise
in the future14. Background levels of ozone are rising towards
the level at which they could start causing damage to vegetation
and crops. Although trans-boundary pollution contributes to the
formation of ground-level ozone, the contribution of UK "home-grown"
emissions is also very important. Ozone is not a "primary"
pollutant: it is not emitted directly, but is created by a reaction
between other forms of pollution such as nitrogen oxides and hydrocarbons,
emitted mainly in urban areas. Road transport produces 44 per
cent of UK emissions of nitrogen oxides15.
Failure to prevent traffic growth will inevitably
lead to further pressure for more road-building. The Government
has already acknowledged that "we cannot build our way out
of congestion with new roads"16. This is especially the case
in towns and cities. Large-scale expenditure on road-building
is counter-productive as it does not address long-term problems
of traffic growth. Indeed, in many cases, it exacerbates the problems.
And, as has been mentioned above, road-building on the scale planned
by the Government would barely impact on congestion.
The Government's road-building plans would damage
some of Britain's finest wildlife sites and landscapes. The Highways
Agency is currently bulldozing through the Bingley South Bog Site
of Special Scientific Interest (SSSI) in West Yorkshire. The Lune
Estuary SSSI, part of the Morecambe Bay Special Area for Conservation
(Europe's highest wildlife designation) is under threat from Lancashire
County Council's plans for a Western Bypass of Lancaster. The
Dorset Downs, Heaths and Coast Area of Outstanding Natural Beauty
is under threat from the A354 Dorchester to Weymouth Relief Road.
Building the Brunel Link and Harnham Relief Roads in and around
Salisbury will create pressure for the completion of the Salisbury
bypass through building the "missing link" across the
world-famous Avon watermeadows.
According to the latest figures, 28 per cent
of households do not have a car17. This figure rises to 36 per
cent in London and the former Metropolitan Counties18. Households
without cars are also concentrated at the lower end of the income
scale: the lowest levels of car ownership are in single pensioner
households (26 per cent) and single parent families (42 per cent).
Overall 70 per cent of the poorest 20 per cent of households do
not have cars19. Only 41 per cent of women have first access to
a car, meaning that in households with only one car, many women
are effectively car-less.20
The Government has forecast that, even in 2011,
a quarter of households will not have access to a car, and that
45 per cent of households will have only one car. Thus, in 2011,
millions of people will still rely on public transport, cycling
and walking for some or all of their journeys. Yet, as traffic
levels rise, life for public transport users, cyclists and pedestrians
tends to get worse. As FOE's recent report on transport and social
exclusion in Bradford shows, the socially-excluded suffer disproportionately
from these impacts21. If bus use falls, fare revenue falls and
bus companies have to cut frequencies or routes. The Government's
current target for increased bus use could be met solely from
patronage increases expected in London, and bus use elsewhere
could fall. As traffic levels rise, cycling becomes more dangerous.
And as car ownership rises, offices, factories and facilities
(supermarkets, cinemas, hospitals etc) tend to be built in places
convenient to reach by car. Thus people without cars face ever-greater
problems. Reducing the overall use of cars and promoting the use
of walking, cycling and public transport will reverse these trends
and make life easier for those that cannot use private cars.
Thus for economic, social and environmental
reasons, there remains a strong case for reducing the use of cars
and promoting the use of public transport, cycling and walking.
This case is especially relevant to urban areas.
What assumptions should be modified or challenged?
How important are the assumptions to the outcome
of the plan? What remedial action is necessary if assumptions
or targets need to be changed?
Transport 2010 was an important development
in transport policy in the UK in that its shape was significantly
determined by the extensive modelling carried out beforehand.
Consequently the assumptions and proposed targets used in the
modelling need to be critically reviewed. DTLR should also allow
independent access to the model used, in the same way as the Treasury
allows such access to its model of the economy. This would allow
the impact of alternative sets of assumptions to be assessed.
FOE is extremely concerned that Transport 2010
is based on the assumption that motoring costs will fall by 20
per cent over the period of the plan22. This is based on improvements
in car fuel efficiency leading to a reduction in running costs
per kilometre, and no real change in car ownership costs, non-fuel
running costs or fuel duty. This fall in motoring costs will lead
inexorably to greater car use. This runs counter to the objective
of many of the targets set by the Government in Transport 2010:
greater car use will make it harder to reduce road congestion;
to improve air quality; to reduce greenhouse gas emissions; and
to increase the use of rail, light rail and buses. This is shown
by the Government's own modelling. Transport 2010 shows that,
if motoring costs are kept constant rather than falling, both
congestion and carbon dioxide emissions will fall by greater amounts.
In particular, the CO2 savings are 50 per cent greater23.
The Government has said that it wishes to see
a "shift in the burden of tax from 'goods' to 'bads'"
because it recognised that the tax system sends clear signals
about economic activities that it believes should be encouraged
or discouraged, such as work and pollution respectively24. Emissions
of carbon dioxide and other pollutants are clearly "bads".
However if fiscal measures are to play their role in delivering
"a more dynamic economy and cleaner environment, to the benefit
of everyone"25 then it seems perverse that motoring costs
are assumed to fall while public transport fares are rising. Reversing
these would instead help to create a virtuous circle with increased
restraint of the least sustainable mode of transport, and additional
revenue to invest in more sustainable modes.
FOE also notes that no assumption seems to have
been made on the level of bus fares outside London26
Will the expected number of congestion charging
and workplace parking levy schemes be implemented, and when?
The 10 Year Plan assumes that a central London
congestion charging scheme will be in place by 2004-05, charging
£5 to enter central London between 07:00 and 19:00 hours
on weekdays, and that local authorities outside London introduce
eight congestion charging and 12 workplace parking levy schemes
in the centres of most large urban areas the size of Blackpool
and above27 with all net revenues recycled into transport improvements
in the urban areas concerned. It currently looks highly unlikely
that these schemes will be implemented. Local authorities were
asked to indicate in their provisional Local Transport Plans,
submitted in 1999, if they were considering introducing such schemes.
Only 12 schemes were proposed28. Furthermore, transport ministers
are reported to oppose the Mayor's congestion charging plans for
London29. The Government's conviction has been clearly stated:
"Traffic congestion is a major problem requiring a radical
solution. Road user and workplace parking charges are part of
the answer".30 It must now have the courage of these convictions
and give a stronger political lead.
How will the current situation in the railway
industry affect the need for and provision of private and public
The current situation casts doubt on the hoped-for
private finance materialising. This must not be allowed to stop
or slow down investment in rail infrastructure. FOE believes that
there needs to be a clear commitment from the Government to major
funding of rail projects that will bring social, environmental
and economic benefits. Government funding should be based on the
use of appraisal criteria that are strongly weighted towards environmental
and social sustainability, applied to both road and rail projects.
Is the balance and phasing of investment across
funding areas correct?
No. The projected spending on strategic road
building is too high. FOE believes that the strategic roads budget
should be reduced to approximately £500 million per year,
for maintenance purposes. All proposed trunk road construction
should be subjected to a rigorous multi-modal test, and a separate
budget heading should be set up to fund the outcome of these,
whether it be road or rail investment. Press reports suggest that
the Secretary of State is proposing to "borrow" from
the roads budget to put more money into the railways31. FOE believes
that these "borrowings" reflect an acceptance that the
balance of allocation is wrong.
FOE is also concerned that insufficient resources
have been earmarked for relieving the transport problems of the
largest cities. This is where much of the congestion on the road
network is found.
FOE also has serious concerns about the phasing
of funding. Following the (scheduled) completion of the CTRL and
WCML schemes in 2003-04, public investment expenditure in the
railways is scheduled to fall32. FOE believes that this gives
entirely the wrong signals about the direction of Government policy.
How do the emerging multi-modal studies affect
the 10 Year Plan?
The incorporation of their proposals from multi-modal
studies within the implementation programmes of the 10 Year Plan,
will be a major challenge for transport policy:
They represent a large investment
not just in money but also in time and opportunity cost. The first
task involves completing them to a rigorous standard.
The second challenge, recognising
their diverse origins and potentially diverse solutions, will
involve evaluating them for a consistent approach, and then proceeding
to implementation. This will create problems for public spending
(as their proposals are likely to be expensive), and for implementation
(if it seems easier to develop road rather than rail schemes in
this country at the momentbecause of complex institutional
arrangementswill the final output of the studies be genuinely
This would also reinforce the tendency, which
FOE can clearly discern in some multi-modal studies, for studies
to bring forward substantial new road programmes which merely
return transport policy and investment to the position of a decade
Should the plan represent a better balance between
large and small schemes, and between infrastructure, management
Yes. FOE believes that many smaller-scale measures
have a greater benefits: costs ratio than larger-scale infrastructure
projects, but these schemes often do not get funded. Work on this
subject is being carried out for CPRE, Sustrans, Pedestrians'
Association and Transport 2000 and we refer you to its outcome.
Some small-scale schemes may not appear sufficiently "sexy"
for prioritisation by local authorities. To this end, we believe
that the Government must take a lead through pledging itself to,
say, a safe route to school for every child in the country or
traffic calming on all appropriate residential roads.
Are the targets and the dates for their achievement
well designed (eg is reducing congestion the right objective)?
FOE believes that two targets in particular
The congestion target has been discredited
(see above) and should be reviewed.
The target to increase bus use by
10 per cent is far too low and could in practice be achieved by
doubling bus use in London (which some experts believe possible
if the Mayor's congestion charging scheme is introduced33) despite
further decline in the rest of the country. The target should
be made more challenging and more in line with Government thinking.
For example if bus use doubled in London and rose by 25 per cent
elsewhere in the country, this would be equivalent to a 47 per
cent rise in bus passenger journeys nationwide. It should be noted
that the bus target is not an output of the Government's models,
but was introduced "manually".
In addition, the target to increase rail passenger
kilometres by 50 per cent by 2010 looks challenging at first sight.
It has been calculated, however, that this could be achieved through
a lower rate of growth than has occurred over the last four years.
Growth of 50 per cent over 10 years equates to an annual growth
rate of 4.2 per cent, whereas the last four years have seen growth
at an average of 6.3 per cent per annum34. However sustaining
passenger growth at these levels will be problematic with the
current inadequate investment in capacity on the network.
What other targets, if any, should be included
(eg modal shift, walking, traffic levels?)
FOE believes that targets should be set in all
three areas suggested: for modal shift, walking and traffic levels.
In terms of traffic targets, FOE believes that the Government
should reconsider the idea of benchmark profiles for traffic levels,
as suggested by the Commission for Integrated Transport35. A benchmark
profile would be "a yardstick against which to measure progress
. . . a specified indicative level for each year, or every two
to three years, over the next 10 years" which could be set
for different types of area36. These could also be aggregated
into indicative national benchmark profiles. These would help
guide policy and funding nationally (through the 10 Year Plan)
and locally (through Local Transport Plans). They could also help
determine, for example, whether planning policy needed to be strengthened.
Should a more regional approach be adopted for
FOE believes that in some areas a national target
alone is a rather blunt instrument. For example, given that an
estimated 60 per cent of rail passenger journeys start or finish
in London, one approach to making sure the Government's passenger
growth was met would be to focus all investment into the South
East. Clearly this will not happen in practice, but we hope the
point is made. Regional targets for increasing rail passenger
numbers would ensure a fairer distribution of investment, and
could be included in new rail franchise agreements, which FOE
believes should be drawn up on a regional basis. Again, CfIT's
benchmark profiles provide a possible way forward.
How well does the Plan balance social and environmental
policy with efficient investment?
A top DTLR civil servant has admitted that Transport
2010 does not, in its current form, cater for the socially excluded37.
The problems arise in two areas. Firstly the proposed spending
on trunk roads tends to favour those with cars at the expense
of those, such as the socially excluded, whose main modes of transport
are buses, cycling and walking, for which smaller scale schemes
are more appropriate. Secondly the lack of real solutions to traffic
congestion, pollution and danger in urban areas affects the socially
excluded more severely than those in more affluent households
or areas (see above).
Does the Plan set out a balanced approach to all
modes (eg walking)?
One effect of the overemphasis on large schemes
is that modes that are dependent on a large number of small schemessuch
as walking, cycling and bus usedo not get their fair share
1. Although not in the manifesto itself,
this appeared on the Labour Party's website and in its handbook
2. The Guardian, 6 June 1997, reiterated
in Parliament on 20 October 1998.
3. Tony Blair, speech on reform of public
services, 16 July 2001.
4. The Guardian, 31 December 2001,
reporting that the Government's transport performance had been
rated by the public at minus 49 per cent.
5. "Running to stand still? an analysis
of the 10 Year Plan for Transport", CPRE February 2001.
6. "Climate Change The UK Programme"
Summary Document, 2000.
7. "UK?s Third National Communication
under the United Nations Framework Convention on Climate Change"
8. "UK's Third National Communication
under the United Nations Framework Convention on Climate Change"
9. Cambridge Econometrics "UK Energy
and the Environment" July 2001 p. 27.
10. "The Air Quality Strategy for England,
Scotland, Wales and Northern Ireland: A consultation document
on proposals for air quality objectives for particles, benzene,
carbon monoxide and polycyclic aromatic hydrocarbons", September
2001, paragraph 40. The 20 µg/m3 level corresponds to the
EU stage 2 limit value. A higher target (23-25 µg/m3) has
been set in London, but this appears to be solely for reasons
11. "The Air Quality Strategy for England,
Scotland, Wales and Northern Ireland" paragraph 94.
12. "The Air Quality Strategy for England,
Scotland, Wales and Northern Ireland" paragraph 50.
13. Data from National Atmospheric Emissions
14. DEFRA News Release 281/01, 10 December
2001 "Good news on cutting acid rainnew plans to protect
habitats from air pollutants".
15. Data from National Atmospheric Emissions
16. "A New Deal for Transport: Better
for Everyone" paragraph 1.16.
17. Focus on Personal Travel, DTLR December
18. DTLR "Focus on Personal Travel"
19. Office for National Statistics, Family
20. Focus on Personal Travel, DTLR December
2001 table 5.2.
21. Friends of the Earth "Environmental
JusticeMapping transport and social exclusion in Bradford"
22. Transport 2010: The Background Analysis
23. Transport 2010: The Background Analysis,
Figures 13 and 14.
24. The Government's Statement of Intent
on Environmental Taxation, 2 July 1997.
25. The Government's Statement of Intent
on Environmental Taxation, 2 July 1997.
26. The only allusion to bus fares seems
to be in paragraph 27 of Transport 2010: The Background Analysis,
which says that there will be no increase in real terms in public
transport fares in London.
27. Transport 2010: The Background Analysis
paragraphs 61 and 64.
28. These were in the West Midlands, Greater
Manchester, Leeds, Bristol, Nottingham, Cambridgeshire, Cheshire,
Derbyshire, Hampshire, Milton Keynes, Reading and Durham.
29. As reported in The Guardian,
10 December 2001.
30. Foreword to "Breaking the Logjam:
the Government's consultation paper on fighting congestion and
pollution through road user and workplace parking charges"
31. Financial Times, 5 December 2001.
32. Transport 2010 table A3.
33. For instance Prof David Begg, speaking
at University Transport Studies Group conference, Royal Geographical
Society 20 September 2001.
34. "A Plan for Growth? An analysis
of the 10 Year Plan's perspective for rail" prepared for
the Railway Forum by Dr. Rana Roy, London, March 2001.
35. Commission for Integrated Transport
"National Road Traffic Targets", November 1999.
36. CfIT "National Road Traffic Targets"
37. Willy Rickett, then head of DETR transport
strategy and planning division, speaking to a conference on Local
Transport Plans, organised by the County Surveyors? Society and
the Local Government Association, reported in The Surveyor, 22