Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence

Memorandum by English Nature (TYP 46)


  1.1  English Nature is the statutory body that champions the conservation and enhancement of the wildlife and natural features of England. We do this by:

    —  advising—Government, other agencies, local authorities, interest groups, business, communities, individuals;

    —  regulating—activities affecting the special nature conservation sites in England;

    —  enabling—helping others to manage land for nature conservation through grants, projects and information;

    —  enthusing—advocating nature conservation for all and biodiversity as a key test of sustainable development.

  1.2  In fulfilling our statutory duties, we:

    —  establish and manage National Nature Reserves (NNRs);

    —  notify and safeguard Sites of Special Scientific Interest (SSSIs);

    —  advocate to government departments and others effective policies for nature conservation;

    —  disseminate guidance and advice about nature conservation;

    —  promote research relevant to nature conservation.

  1.3  Through the Joint Nature Conservation Committee, English Nature works with sister organisations in Scotland, Wales and Northern Ireland to advise Government on UK and international nature conservation issues.


  2.1  English Nature welcomes the opportunity to provide the Transport Sub-committee with comments on Transport: 2010, the 10 Year Plan announced by the Government in July 2000. The plan was an important milestone in establishing the direction, scope and planned level of resources to be allocated to the delivery mechanisms contained in the 1998 White Paper on integrated transport. English Nature's interest is in ensuring that the Government's transport policy takes full account of biodiversity and geological conservation considerations.

  2.2  With this inquiry our particular interest lies in three of the topic areas identified in the Press Notice for the inquiry, namely Implementation, Targets and Integrated transport policy. We use these three sub-headings for our more detailed comments provided under sections 3, 4 and 5 below.

  2.3  In overall terms English Nature is supportive of the aims and much of the content of the 10 Year Investment Plan. In particular, we were pleased to see commitments to:

    —  the NATA/GOMMMS appraisal methodology;

    —  the early involvement of the statutory bodies in the development of policies, programmes and schemes;

    —  the protection of environmentally sensitive sites;

    —  the use of delivery mechanisms such as Local Transport Plans and the Multi-Modal Studies rather than a straightforward announcement of road schemes;

    —  an integrated approach with a significant shift towards public transport.

  2.4  We believe that the £180 billion earmarked for transport investment under the plan should provide sufficient resources for more imaginative, integrated solutions to transport problems to be delivered with benefits for the travelling public, communities and the natural environment. Recent and more welcome examples of more environmentally sensitive solutions include the proposed use of tunnels at locations with high quality natural environments, such as at Hindhead in Surrey and at Stonehenge in Wiltshire. The preferred route for the A30 at Indian Queens in Cornwall (which currently passes through Goss Moor National Nature Reserve) is another example of a more sustainable solution to a transport problem and one we have been promoting as an example of good practice.


  3.1  There have undoubtedly been problems with delivering the plan and our comments about implementation relate mainly to Multi-Modal Studies and to rail issues. We view the Multi-Modal Studies as having a crucial role to play in finding more environmentally-sustainable solutions to transport-related problems. We are monitoring progress with the studies in order to ensure that we have sufficient involvement as a statutory body and that biodiversity considerations are being taken fully into account in the appraisal process. The evidence so far is that the situation is improving and that following some initial difficulties we are now being properly consulted at a local level by those managing and participating in the studies. We would still recommend that the consultants for the studies are required to consult English Nature's local teams on a regular basis throughout the life of each study. There are still some teething problems with the appraisal process and our perception is that there needs to be a greater degree of quality control at the centre (ie within DTLR) in order to ensure consistent application of the GOMMMS appraisal guidance across all of the studies.

  3.2  Another key issue is the recent and on-going crisis in the rail industry. At present the absence of a clear plan for future railway infrastructure and investment and, in particular, a clear funding route for rail schemes means that the Multi-Modal Studies and Local Transport Plans could end up emphasising road solutions and thus blocking the desired shift towards public transport provision. We believe that regional and local authorities need the ability to secure dedicated funding to deliver the rail component of a balanced transport investment programme in order to avoid a situation where there is pressure for "quick fixes" through road investment. This could lead directly and indirectly to loss and damage to nature conservation sites as outlined in our Position Statement on transport which is annexed to this submission. Railtrack are a key player in the inland transport sector from a biodiversity perspective as they have an interest in over 150 Sites of Special Scientific Interest. English Nature would like to see any successor to Railtrack appoint an Environmental Director and be given a duty to promote sustainable development and protection and enhancement of the natural environment.


  4.1  There is a lack of defined targets and a lack of clarity over their relationship with the Government's own quality of life sustainable development indicators as a means of measuring progress. In addition, we would support the views of bodies such as Transport 2000 that the Government should set targets for reducing traffic levels in areas where people live and stabilising levels elsewhere. At the same time some of the targets need to be more ambitious eg for growth in bus usage and walking and cycling. A wholesale review of the targets is necessary in view of the fact that many of the forecasts eg for funding, passenger and traffic growth are now out-of-date and need to be revised in the light of experience and changed circumstances.

  4.2  We believe the targets must be able to demonstrate that Transport: 2010 can sustain economic growth whilst reducing overall transport growth, particularly road mileage, through a package of measures including shifts to other forms of transport, integrated land use planning, financial instruments and the use of new technologies.


  5.1  Integrated transport requires not just integration between different transport modes but integration across different levels of decision-making, integration between transport and land-use planning and integration between environmental and other policy objectives. We believe that there is much still to be done in this respect and would encourage the use of the regional institutions to integrate the spatial requirements of the various sectors including transport. Again the integration of decision-making over rail investment is required by Multi-Modal Studies and Local Transport Plans.

  5.2  The 10 year plan does contain a clear statement that there will be a strong presumption against environmentally damaging schemes and we are pleased that the Government appears to be adhering to this commitment. The evidence is provided by the decision to reject the two bypasses as part of the package of measures for the Hastings Multi-Modal Study and the most recent Local Transport Plan financial settlement announced in December 2001 in which 50 per cent of the major road proposals put forward by local highway authorities were rejected whilst some other more sensitive schemes were approved.


  6.1  We understand that the Government is committed to carrying out a review of the 10 Year Plan during 2002 and we would recommend that this should include a review of the targets and the NATA/GOMMMS appraisal processes and be undertaken in a consultative fashion rather than behind closed doors within central Government.

  6.2  Large-scale transport investment could result in environmental degradation and a loss of biodiversity even where more environmentally sound forms of transport, such as cycle and rail networks, are being put in place. Wherever possible we wish to work with the necessary stakeholders to avoid this but, as an absolute minimum, we would wish to see the avoidance of damage to special sites and protected species and, at best, imaginative solutions to transport problems which integrate environmental gain and biodiversity enhancements.

Environmental Impacts Team

English Nature


11 January 2002

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