Memorandum by The National Trust (MMS
12)
MULTI MODAL STUDIES
INTRODUCTION
1. The National Trust welcomes the opportunity
to contribute to the Committee's inquiry into multi modal transport
studies. As a major landowner with long-term conservation objectives
and as a manager of over 50 million visits to our properties each
year we have a direct interest in transport issues. We depend
on effective transport to support our visitors but we are also
concerned to protect our properties on behalf of the nation from
damaging infrastructure development.
2. The Trust strongly supports multi modal
studies for their potential to help develop a new approach to
finding transport solutions that reduce both the need to travel
and its impacts. We have taken a particularly strong interest
in the "London to the South West and Wales Multi Modal Study"
(SWARMMS), and the "South Coast Multi Modal Study" (SoCoMMS).
We have also addressed the East Midlands Study, Orbit M25 Study
and the Thames Valley Study. Our response to the Committee's request
for evidence is based on our experience and involvement with these
studies.
SUMMARY
3. In summary, the National Trust:
— Welcomes multi-modal studies as a
key means for developing new and more integrated approaches to
tackling transport problems and believes they will provide significant
value for money if they can achieve these objectives
— Supports the effective diagnosis
of problems evident in the studies but is concerned that the approach
taken to meeting these challenges has focused on mitigating rising
traffic levels rather than addressing their root causes
— Believes the emphasis of the studies
has been unduly roads focused, with more limited attention being
paid to local solutions and "soft" transport measures
— Finds that the studies have been
inconsistent in their approach to key policy instruments, especially
road charging, not least as a result of a lack of clarity from
the Government on its position
— Believes the studies should be taking
a more positive approach to shifting the modal split away from
car-based transport
— Is concerned that the conclusion
of many studies are being shaped more by the likelihood of different
options being implemented than by the best long term solutions.
This reflects the different strengths and capabilities of the
implementing bodies rather than the merits of the options. The
Highways Agency (roads) is in a stronger position than the Strategic
Rail Authority (rail) or local transport authorities (soft measures)
to implement the recommendations of the reports and has been most
closely involved in their preparation
— Recommends a "learning approach"
to multi-modal studies which draws on experience from the first
studies to improve those in later phases. Key areas requiring
attention include:
— Clearer guidance from Government
on issues such as road charging to ensure consistency between
studies
— A renewed focus on achieving
a modal shift and the potential benefits of soft measures
— Resolution of the apparent disparity
of contribution between the Highways Agency, Strategic Rail Authority,
public transport bodies and local transport authorities
— Reviewing the role that environmental
impact assessments play in studies, so as to encourage protection
and enhancement of the natural environment and its economic benefits,
rather than assessing and mitigating environmental damage at the
end of the process
— Better engagement of key stakeholder
groups, such as public transport operators, in the development
of multi-modal studies to create a sense of shared ownership of
study findings and underline the need for effective implementation.
4. The rest of our submission follows the
line of questioning set out by the Committee.
Q1. WAS THE
APPROACH TO
SELECTING AREAS
AND SCALE
OF THE
STUDIES APPROPRIATE
AND CONSISTENT,
AND HOW
FAR HAVE
THE STUDIES
LOOKED AHEAD?
5. A key anticipated benefit of the multi
modal approach is the ability to move away from small-scale congestion
problems to examine travel in a wider context. This requires studies
to consider land-use issues beyond congested roads and pinch-points
and to examine its root causes and find strategic solutions. There
is no "right size" for a study area but the range from
the smallest (such as Access to Hastings) to the largest (such
as SWARMMS) is strikingly wide. In some cases this has restricted
thinking while at the other extreme SWARMMS has had to address
multiple problems with no obvious hierarchy, with the result that
objectives are confused.
6. The 20 to 30 year time scales adopted
by many of the studies is a welcome move away from short-term
decision making that has dogged transport decision making in recent
years. Such a long-term approach presents an opportunity to examine
more sustainable patterns of living and working, and the part
that transport provision can play in achieving such ends. It is
disappointing therefore that many of the findings from the SoCoMMS
and SWARMMS studies seek only to minimise the negative consequences
of meeting predicted transport demand, rather than taking an active
role in changing demand and putting transport on a more sustainable
footing. Such an approach seems out of line with that set out
in the Government's Transport White Paper, which states that the
focus should be on treating the causes of transport problems,
rather than patching up the existing system:
"The New Deal for Transport will make it
easier for people to choose different and more sustainable ways
if making their journeys, helping them to make the changes in
travel behaviour that are needed." (The New Deal for Transport,
DETR, 1998, para. 2.48)
7. The Trust is also concerned about the
relationship between studies, particularly in cases where the
boundaries overlap. For instance, the Orbit study recommendations
included reference to congestion charging over much of the south
east. This has repercussions for the SoCoMMs study but because
the two studies were undertaken largely in parallel, they were
seemingly unable to take full account of each other's work. In
effect, this leaves the two studies suggesting different answers
to joint problems, directly undermining the worth of the research.
Q2. HOW MUCH
HAVE THE
STUDIES COST
AND ARE
THEY VALUE
FOR MONEY?
8. It will be difficult to assess fully
the value of multi-modal studies until their findings are implemented
and their impacts considered. The Trust recognises that the complex
research methodology and the scale of the problems they are examining
demand a thorough approach. If this delivers genuinely new solutions
then the investment will represent good value for money. It is
important, therefore, that some simple and obvious flaws, such
as the lack of integration with the Strategic Rail Authority,
be removed so as not to undermine their benefit. A failure to
do so will cast doubt over the usefulness of the findings, and
hence whether they provide value for money.
9. The Trust is also concerned that elements
of the studies have not been allocated sufficient time in research,
thus downgrading the worth of information that is produced. For
example, the final stage of the SoCoMMS study consisted of a series
of implementation plans (called "strategic development plans")
outlining how the problems identified by the study should be addressed,
including through new infrastructure. As such, they represented
the key stage in study, and the first time definitive undertakings
had been firmly proposed. However, the "strategic development
plan" phase came so late in the project that not even members
of the steering committee were given sufficient time to study
them. By rushing this key stage, the project reduced the opportunity
for fine-tuning of its findings, and thus the value for money
it offers.
Q3. WHAT IS
THE EXPECTED
COST AND
HOW AFFORDABLE
ARE THE
SCHEMES BEING
RECOMMENDED?
10. There are questions as to the balance
of what is considered "affordable" by the study teams
and balance of options that this leads to. For example, the SoCoMMS
study has brought forward proposals amounting to just over £1
billion. Of this, around £640 million will be spent on road
improvements, with three road tunnels at Worthing designed to
deal with local traffic, accounting for around £400 million.
This poses questions about the approach of bodies charged with
implementing aspects of the strategy. The SRA has been critical
of a number of the studies final reports for having unrealistic
expectations of future rail schemes. Such an approach is arguably
born of many years of under-investment in the rail sector. By
contrast, the Highways Agency and many local authorities have
more of a "can do" attitude to road schemes. In this
way, the findings of studies match current approaches to difficult
transport modes, rather than providing the best long-term option.
Q4. HAVE THE
STUDIES BEEN
BASED ON
REALISTIC FORECASTS
OF GROWTH
IN TRAFFIC
AND HOW
EFFECTIVE ARE
MEASURES INTENDED
TO REDUCE
THE NEED
TO TRAVEL?
11. As the Government has shown with its
household projections, demand is not a "given" but is
affected by (and affects) a variety of other policy areas. The
Trust is concerned that forecasts of traffic growth are inclined
to consider future transport requirements purely as an outcome
of other trends in society, such as employment and leisure patterns.
Where this is used as a starting point it means that multi-modal
studies can do little more than limit the negative consequences
of spiralling demand for transport. By contrast, the Trust believes
the studies should address the root causes of traffic growth and
potential new approaches which both reduce the need to travel
and the impacts of doing so. It is also necessary to address other
policy objectives such as reducing the contribution of transport
to climate change and protecting biodiversity and designated areas.
12. The Government has made it clear that
reducing the need to travel is one of the key measures of success
for transport policy.
"We want transport to contribute to our
quality of life not detract from it. The way forward is through
an integrated transport policy. By this we mean.... integration
with land use planning—at national, regional and local level,
so that transport and planning work together to support more sustainable
travel choices and reduce the need to travel." (The New Deal
for Transport DETR, 1998, para. 1.22)
13. The 30-year time scale of the multi-modals
should provide an ideal framework for achieving this. However,
so called "soft measures" designed to reduce demand
for travel, have been given a low standing in both the SoCoMMS
and SWARMMS studies. It has been argued that this is because such
measures have not been widely trialled in the UK and their effectiveness
is therefore uncertain. This in turn leads to assessment regarding
their effectiveness to be on the low side. It is difficult to
see how soft-measures can ever be considered on the same footing
as more traditional methods of alleviating congestion if they
cannot even be properly incorporated into long-term strategies
such as multi-modal studies. If we are to break the cycle of road
building to alleviate congestion and reduce the need to travel
then more serious attention needs to be given to the potential
cumulative effects of soft measures in developing new transport
solutions.
Q5. HAS A
CONSISTENT APPROACH
BEEN TAKEN
OVER THE
NEED FOR,
AND BENEFITS
OF, NEW
WAYS OF
CHARGING FOR
TRANSPORT?
14. The Trust believes the studies have
not adopted a consistent approach to charging. This is partly
due to a lack of a clear position from Government. The Government's
most recent pronouncement is that wide area road charging will
not be considered before 2010. This puts multi-modal studies in
a difficult position of taking a decision on potentially expensive
and complex technology, which could form a central plank of future
road transport without knowing whether Government even intends
to pursue it as an option.
15. A key example of the inconsistency in
approach is the comparison between the Orbit and SoCoMMS studies.
The Orbit study has produced findings recommending serious consideration
of road charging over the M25 area and much of the rest of south
east. That the SoCoMMS study has not considered similar conclusions
raises the question of which study should have precedence, and
the value of having two studies with conflicting conclusions over
this key area of policy.
Q6. HOW DIFFERENT
ARE THE
RECOMMENDATIONS THESE
STUDIES ARE
BRINGING FORWARD
COMPARED WITH
PREVIOUS TRANSPORT
POLICY? HAVE
THE STUDIES
TAKEN A
BALANCED APPROACH
TO ALL
MODES?
16. The Government has made it an objective
to alter the modal balance away from the private car and toward
more sustainable transport options. Multi-modal studies should
be a prime mechanism in achieving this. In practice, there seems
little evidence that such a shift is occurring, with the modal
balance in the final strategies often being similar to current
transport patterns. In our opinion, this is due to a number of
factors, including:
— Pressure on consultants to provide
obviously deliverable strategies;
— Consideration of the current relative
strengths of the implementing bodies;
— Demands for new infrastructure from
local authority members, reflecting an inertia in thinking; and
— A failure to consider wider policy
implications of strategies, particularly in areas such as climate
change.
17. A particular success of multi-modal
studies concerns their in-depth research into the nature and causes
of current transport problems. With the exception of SWARMMS,
all the studies with which the Trust has been involved have been
highly effective at identifying weak links in the transport network,
and their causes. The approach to overcoming problems of road
congestion, however, all too often falls back onto road building
schemes, many of which have simply been resurrected from previously
rejected plans. Particular examples of this include the Bexhill
Relief Road/Hastings Western Bypass in SoCoMMS, widening of the
M1 between Nottingham and Sheffield, and the dualing of the A303
through the Blackdown Hills in Devon.
Q7. ARE THE
STUDIES PRODUCING
RECOMMENDATIONS THAT
ARE CONSISTENT
WITH GOVERNMENT
POLICY, PARTICULARLY
THE 10 YEAR
PLAN AND
THE SRA STRATEGIC
PLAN?
18. As the Trust understands it, measures
included in the 10 Year Plan and the SRA Strategic Plan are taken
as given in the do-nothing minimum strategies that form part of
each multi-modal study. As such, they are taken as a starting
point for research, rather than a stumbling block. The Trust's
main concern in this area would be that sources of funding for
the rail elements of multi-modals are not immediately obvious
as much of the SRA's funding has already been allocated through
its Strategic Plan. This problem seems to have the effect of making
large-scale rail investments, such as on the Paddington to Exeter
line, difficult for multi-modal studies to recommend without implying
a need to re-allocate already-appointed funding.
Q8. HOW EFFECTIVE
WILL THE
SCHEMES PROPOSED
BY THE
STUDIES BE
IN PROMOTING
REGENERATION?
19. Both the Access to Hastings Study and
the SoCoMMS study have as a key objective the achievement of regeneration
of disadvantaged areas. The Trust was highly supportive of the
decision on Hastings by the Secretary of State that the regeneration
of the town was best carried out by investing in public transport
improvements, rather than road options that would have damaged
areas designated for their environmental importance. In our opinion,
the Hastings decision showed a belief from the Government that
regeneration and environmental protection could be mutually supportive.
20. The Trust's Valuing our Environment
research, published in 2001, supports such an interpretation.
This work shows that retaining a high-quality environment can
be harnessed as an economic benefit in terms of quality of life,
attracting inward investment, and for tourism. We are disappointed
that this important conclusion has not been reflected in the findings
of the other studies in which the Trust has been involved. Here,
the old maxim that roads=regeneration often still holds sway.
To demonstrate this pattern, two cases are worthy of particular
note. The western bypass of Hastings, one of the roads rejected
by the Secretary of State, has seemingly re-emerged as one of
the findings from the SoCoMMS study as the Bexhill relief road.
Second, SWARMMS argues that the perceived peripherality of south
west needs to be overcome and in particular that the future economic
well-being of Cornwall is dependent on two strategic road routes
connecting it with the rest of the country. We are unaware that
any direct evidence has been provided as to why this should be
the case and it certainly does not reflect a new approach to looking
at the issues.
Q9. HOW CAN
ALL OF
THE DIFFERENT
AGENCIES RESPONSIBLE
FOR ACHIEVING
THE DIFFERENT
RECOMMENDATIONS FROM
THE STUDIES
BE CO
-ORDINATED TO
ENSURE A
BALANCED SET
OF PROJECTS
ARE COMPLETED?
21. Implementation requires that projects
making up the findings carried out in a staggered manner. For
instance, the conclusions in the SoCoMMS study require that the
majority of the public transport recommendations be enacted before
new road infrastructure is provided. The intention of this approach
is to ensure that viable alternatives to the private car are available
before infrastructure to reduce congestion is put in place. The
effect should be to encourage as many people out of their cars
and on to viable alternatives as possible. The Trust is basically
supportive of such an approach if it is carried out in an event
driven manner, rather than a date driven one (ie new public transport
provision is in place before road capacity increases are considered,
even if the timetable for either element changes). We are concerned
that if such an approach is not followed and congestion is dealt
with through new capacity before alternatives are provided then
incentives to maximise the benefits of soft measures will not
be achieved.
22. It is important that changes to regional
planning are used to create a framework for implementing the findings
from multi-modal studies. Without pre-empting Government reform,
we would highlight the creative role that could be played by sub-regional
partnerships such as Cornwall County Council's Centre for Excellence
for Integrated Rural Transport.
Q10. WHAT ARE
THE MAIN
POLITICAL, INSTITUTIONAL,
FINANCIAL AND
PLANNING BARRIERS
TO IMPLEMENTING
THE STUDIES?
23. The Trust would wish to identify the
following as potential problems in implementing the studies:
Political
— One of the advantages of the multi-modal
approach to transport planning is the long timescales that the
studies consider. However, this has the potential to raise political
problems with a 20 to 30 year time frame entailing changes of
governments and transport policies, many of which will not be
anticipated by multi-modal studies.
— Similarly, a long timescale can also
allow difficult or potentially unpopular decisions, such as those
concerning congestion charging, to be delayed or postponed.
— The timescale of regional transport
planning does not automatically lend itself to the long-term objectives
to multi-modal studies. There is likely to be substantial public
pressure on local and regional institutions to reconsider findings
from multi-modal studies where they are not seen to be putting
local interests first.
Institutional
— The relative strengths of the national
transport agencies responsible for implementing different element
of the strategies is impacting on the development and implementation
of studies. The apparent "can-do" attitude of the Highway's
Agency contrasts with the more circumspect approach adopted by
the SRA.
— The impact of elected regional assemblies
is unclear, although they are likely to play a key role in implementing
and reviewing any multi-modal studies affecting their region where
they are established.
Financial
— Availability of long-term funding
for implementing studies will certainly be subject to short-term
pressures from other potential uses. Without effective ring fencing
at both national and regional level, this could lead to studies
being only partially implemented. The teams producing the SWARMMS
and SoCoMMS studies describe them as providing a balanced package
of measures that will only have the predicted effect if implemented
in their entirety.
Planning
— The studies consider transport requirements
largely as a reaction to other trends in society, rather than
a contributor to them. SoCoMMS, SWARMMS and a number of other
studies base their projections on the condition that it is desirable
to pursue current patterns of growth and development. The negative
social and economic impacts associated with the strength of London
and the south east suggest that this may not be the case and the
Government recognises this in its moves to encourage more balanced
regional growth. This may leave multi-modal studies out of step
with policy requirements in the medium term.
— The lack of certainty over the future
of Regional Planning Guidance and its role in relation to transport
remains a hindrance.
Q11. HOW CAN
THE MULTI-MODAL
STUDY PROCESS
BE IMPROVED?
24. The potential opportunities presented
by the multi-modal approach can be better realised if the following
changes and additions to procedures are made:
— An on-going implementation review
involving national, regional and local government, together with
the relevant agencies should be set up as part of each multi-modal
study. This should ensure that support and momentum is maintained
for the study.
— Increasing the importance attached
to achieving national targets outside the immediate topic of transport
as part of the study's development and implementation. This should
include areas such as climate change policy, encouragement of
tourism, re-use of brownfield sites and the protection of biodiversity
and landscape resources.
— The cumulative role that tools such
as home working, traffic calming and home zones could play in
reducing congestion needs to be researched, with the findings
being used as part of the implementation review.
— Work is needed to improve environmental
impact assessment in studies. Currently, this often simply looks
at detailed local impacts of proposals, rather than taking a broader
look at the importance of the natural environment (including its
economic importance). Performing an environmental impact assessment
at an early stage in the research would help ensure that particularly
important natural resources are central to the strategy at an
early stage, rather than having impacts on them mitigated later.
— Studies in which the Trust has been
involved have been highly successful in identifying problems affecting
a study area. This needs to be matched with more in-depth research
into the role that current and future institutional arrangements
will need to play in implementing strategies.
— There is scope for better engagement
of key stakeholder groups in the development of multi-modals.
For instance, the SoCoMMS study featured particularly sparse involvement
from public transport operators. Addressing such gaps will help
to create a sense of shared ownership needed for effective implementation.
|
