Memorandum from the Intelligent Transport
Society for the United Kingdom [ITS (UK)] (DLTB 32)
1.0 INTRODUCTION
1.1 The Intelligent Transport Society for
the United Kingdom, known as ITS (UK), is pleased to provide comment
on the Draft Local Transport Bill. ITS (UK) is a not for profit
organisation of around 150 organisations in the transport field
who are working to promote the use of Intelligent Transport Systems
(ITS). These are combinations of sensors, communications and mobile
Information Technology designed to assist all modes of transport.
ITS (UK) is fortunate in having membership from across the UK
and beyond drawn from the public and private sectors and from
academia. We are funded entirely from member subscriptions and
can therefore independently represent the interests of the whole
membership spectrum in this rapidly developing field.
A complete list of our Members is attached to
this Response.
In particular ITS (UK) would like to respond
to the Transport Committee's invitation as follows:
2.0 OVERVIEW
2.1 Government has set out its desire to
sponsor charging using both the simple tag and beacon approach,
and comprehensive Time, Distance, Place charging involving satellite-linked
on-board units. However, there is a large gap in understanding
between Government and Local Authorities in respect of how delivery
of such schemes at a local level should converge to enable compatibility,
interoperability and transparency to the customer. The Bill aims
to give Local Authorities greater powers to design, procure and
operate schemes with less direct Government involvement. If the
schemes are to operate cooperatively, and in the longer term converge
to form a national scheme, then the means of intercept needs defining.
Substantial costs and resource effort will be saved if the path
to the intercept method is understood in advance of the local
schemes being designed. It is essential that the Department for
Transport continues to be the focus for designing and promulgating
a national road pricing technology framework, which is in turn
compatible with EU-wide initiatives, and does not leave the impression
that the Government is distancing itself from the implementation
of Road User Charging schemes.
2.2 It is a truth universally acknowledged
that a successful road pricing scheme must be built on the foundations
of strong public transport and alternative travel choices. Managing
and delivering both of these types of service can be substantially
improved by deploying proven Intelligent Transport Systems techniques
and it is clear that there is a large gap between the best Local
Authority practitioners and the weakest. Regrettably too many
Local Authorities are simply not aware of the range and capabilities
of currently available ITS technologies. There would be substantial
benefits, and substantial economies of scale, if Government were
to organise centrally a programme of reference book and face-to-face
tutorials to raise Local Authorities" awareness of ITS technologies
and good practice
2.3 There will be smaller but worthwhile
savings from wider use of measures to enable pooling or joint
arrangements between schemes, for example, the introduction of
powers allowing Local Authorities to act on behalf of, supply
service to, and enter into joint arrangements with, other authorities.
Local Authorities should be encouraged to avoid individual procurements
and pool their needs rules thereby avoiding multiple inefficient
exercises. The Government needs to consider this issue and decide
whether to issue standard "framework" contracts centrally
for Local Authorities to use.
2.4 The Bill deals largely with Public Transport
issues on which ITS (UK) has few comments apart from the need
for Local Authorities to have a better understanding, and thus
move to a better deployment, of complementary ITS systems and
services available today. It is important to avoid the feeling
that the Road User Charging elements of the draft Bill are there
regardless of the other elements and reflect transport improvements
that have been delivered through other elements of the Bill, potentially
reflecting a fiscal approach as opposed to a congestion reduction
approach.
2.5 The manner and delivery of revenue collection
from Road User Charging is vital for public acceptance and a simple
and evident process is required to ensure reassurance and process
transparency. A clear indication of the relationship between investment
and revenue hypothecation must be detailed and published with
regular reporting to reinforce that position. Such a process will
obviate previous criticisms concerning the use of revenues generated
by Road Safety Cameras and the public perception that such schemes
are tax-raising schemes rather than systems to tackle transportation
and congestion issues.
2.6 Consideration also needs to given to
schemes" running costs" as these are typically either
underestimated or not fully understood from the outset. As with
system integration it is essential that the Department for Transport
continues to be the focus for technology advice and issues clear
guidance on achievable "ceilings" on running costs.
3.0 ENFORCEMENT
3.1 Enforcement is a key component of any
local road pricing scheme. Enforcement aims to contribute to the
sustainability of any scheme by ensuring that unpaid charges are
collected and the scheme operator's revenue streams are preserved.
Working alongside education and information programmes, enforcement
also aims to maximise user compliance thereby helping each scheme
achieve its objectives. Enforcement also helps reduce incidences
of deliberate misuse, fraud or evasion and should assist in reducing
the number of payments missed due to genuine errors.
3.2 For this to happen, the following need
to be considered:
— Enforcement must not just be fair
it must be seen to be fair—for a scheme to be credible,
enforcement must try to ensure that all drivers (or other relevant
liable parties) pay the correct charges accrued by them for using
roads within a scheme boundary.
— Unless the scheme uses physical barriers
to control entry to the pricing zone (such as the Durham scheme),
enforcement needs to be effective, be carried out retrospectively
but swiftly, and should not restrict the movement of vehicles
in any way.
— Enforcement carried out retrospectively
relies on tried and tested technology to record the presence of
vehicles within the pricing zone and to identify their registered
owner/keeper by matching their licence plate with vehicle registration
information held by the DVLA. For this process to be effective,
the following need to be considered:
— The procedures for administering
and collecting penalties need to be established.
— The location of roadside technology
and its impact on the urban streetscape
— The accuracy and completeness of
the DVLA database
— The degree to which vehicles not
registered by the DVLA can be identified.
— A fair and scalable prosecution and
adjudication system must be established which is able to support
a fair penalty Road User Charging structure defined at a national
level.
— DVLA must be given new powers to
permit the exchange of registered owner details with selected
other peer authorities in other EU and EEA member states.
— For enforcement purposes a scheme
operator needs access to the data held by Revenue & Customs
on non-UK registered vehicles at the point of entry to / exit
from the UK.
4.0 ENVIRONMENT
4.1 The Bill promotes considerable common
sense in promoting the use of public transport as a means to tackle
congestion and climate change however schemes will require imaginative
and innovative approaches to match public expectations. It will
be necessary for Local Authorities to carry out what, for many,
will be difficult and innovative customer research exercises incorporating
local consultation meetings as well as focus groups, other market
research techniques and wider public involvement in decision making
processes.
4.2 Local Authorities need to design Road
User Charging schemes inside the wider concepts of guaranteed
service delivery using an assured inexpensive and reliable service
linked to faster journey times on all occasions. Public engagement
in delivering well targeted schemes to make individual schemes
are effective is important. A long term transport vision related
to high profile efficient public transport needs to be integrated
with ITS schemes to ensure the most serious congestion are resolved
in the short term however this need to be linked to a plan to
make public transport a genuine future alternative prior to any
imposed introduction of a nationwide Road User Charging scheme
or "carbon rationing'.
5.0 CONCERNS
5.1 The Bill targets strategic objectives
and sets out examples of how to deliver them couched in terms
such as "Propose reforms'," Propose new PTA's', "Introduce
"quality contracts'. However the identification of the associated
substantial funding sources that will facilitate those desired
changes remains unanswered. Other potential concerns include how
Local Authorities will maintain and not lose sight of the hierarchy
of services in local, regional and national contexts, as improvements
in local services should seek to enhance the patronage of, not
detract from, nor be at the expense of regional and national services.
Ideally there would be enhancement of national services; however
where such investment for an already overcrowded transport system
could come from also remains unanswered. In promoting public transport
schemes to tackle congestion there is a need to consider the best
options between bus, rail, taxi and other bespoke transport systems.
6.0 LEGISLATION
& POWERS
6.1 ITS (UK) has the following points on
powers and related legislation:
— Regarding DfT Circular 01/2007 Para.
16/17—the Bill needs to make explicit that enforcement /
detection / monitoring equipment such as cameras or DSRC beacons
on poles / gantries, including cabinets is not "development"
so neither planning permission nor permitted development rights
are required.
— Local Authorities will need inspection
and enforcement powers for tags and GPS-based On-board Units.
These need to make explicit that the data gathered from these
devices can be used for evidential purposes; as at present only
images are regarded as sufficiently robust as primary evidence
without a witness statement.
— The Bill proposes using regulations
for:
a. Imposing limits on the charges payable
b. Regulating exemptions and discounts
c. Ensuring consistent vehicle classification
d. Equipment and traffic signs.
Far too often the time needed to centrally prepare
such regulations is too long. For example, the regulations on
bus lane enforcement were only agreed recently—6 years after
the publication of the Traffic Act 2000; in addition key parts
of regulations related to the Traffic Management Act 2004 are
still outstanding. The Government needs to consider this situation
and decide how these issues would be addressed through local regulations.
7.0 SUMMARY &
CONCLUSION
7.1 ITS UK welcomes the proposals to assign
greater control to Local Authorities through the Bill. This is
a key requirement to enable public transport interchange but more
importantly it acknowledges that public transport is a key component
of the delivery of integration of Intelligent Transport Systems
Applications.
7.2 The Bill addresses a broad range of
important transport issues, but could have been even more potent
and influential if it had set out some specific reference to the
capabilities and deployment of Intelligent Transport Systems in
public transport. The Bill has made loose reference to how tackling
congestion through improved public transport will influence and
impact on climate change; however it fails to identify how this
would be estimated. In addition there is no mention of how this
relates to other environmental gains and social issues. Furthermore
there is a need to understand local and regional land use planning
and its impact on transport and public transport such as linking
education establishment's schools and public transport
7.3 ITS (UK) welcomes the draft Local Transport
Bill and supports the ethos that is included therein. These comments
are intended to be supportive of the proposals acknowledging that
road space availability is finite and measures need to be put
into place to address these for the improved management of urban
networks and environmental implications.
June 2007
ITS UNITED KINGDOM
The Intelligent Transport Society for the United
Kingdom
FOUNDATION MEMBERS
Alcatel
Amey Infrastructure Services
Atkins Transport Systems
Atos Origin
BT
Capita Symonds
Civica
Department for Regional Development
Department for Transport
Department of Trade & Industry
Essex County Council
FaberMaunsell
Glasgow City Council
Highways Agency
IBI Group
innovITS
JourneyPlan
Mott MacDonald Ltd
Mouchel Parkman Services Ltd
QinetiQ Ltd
Real Fleet Ltd
RedSpeed International
Scottish Executive
Serco Integrated Transport
Transport for London
TRL Ltd
University of Southampton
Welsh Assembly Government
WSP
CORPORATE MEMBERS
ACIS
ACPO ITS Working Group
AGD Systems Ltd
Ankerbold International Ltd
Appian Technology
Applied Traffic
BAA Plc
Babtie Group
Barco Limited
Barlow Lyde & Gilbert
Brighton & Hove City Council
Bristol City Council
Cambridge Consultants Ltd
Cardiff County Council
Carl Bro
Centaur Consulting
City of Edinburgh Council
Computer Recognition Systems Ltd
ConsultingStream Ltd
DAR Consultants (UK) Ltd
Densitron Ferrograph Limited
Derwent CCTV Ltd
Dundee City Council
EC Harris
e-Plate Ltd
ESYS Plc
Golden River Traffic Ltd
Halcrow
Hampshire County Council (ITS Group)
Home Office Scientific Development Branch (HOSDB)
Hyder Consulting Ltd
Ian Catling Consultancy
Ian Routledge Consultancy
IDT Ltd
Imperial College
Initial Electronic Security Systems
Integrate Systems Engineering
ITIS Limited
JAI UK Ltd
Kapsch TrafficCom
Lancashire County Council
Last Mile Communications
Leicester City Council
Liverpool City Council- 2020 Liverpool Ltd
LogicaCMG
Marconi Transportation
MATTISSE Consortium
Merseyside Passenger Transport Authority
Merseytravel (Passenger Transport Executive)
Met Office
MIRA Ltd
mm02Plc
National Car Parks Ltd
Navteq
Norfolk County Council
Norwich Union Insurance
NTL
Ordnance Survey
Parsons Brinckerhoff
Peek Traffic Ltd
Peter Brett Associates
PIPS Technology Limited
Police Service of Northern Ireland
Rapp Trans (UK) Ltd
RBS Insurance
SciSys
Scott Wilson
Sheffield City Council
Siemens Traffic Controls Ltd
Society of Motor Manufacturers and Traders Ltd
Southampton City Council
Speedcheck Services Ltd
Systems Engineering and Assessment Ltd
Techspan Systems Ltd
Telenor Connect A/S
Tenet Technology Ltd
Thales Telecom Services
Trafficlink (UK) Ltd
Trafficmaster plc
Transpomatica Consultants Ltd
Transport Technology Consultants
TSEU Ltd
Tyco Integrated Systems Ltd
University College Dublin
University of Leeds
University of Newcastle upon Tyne
Variable Message Signs Ltd
Vehicle & Operator Services Agency (VOSA)
Walsall Metropolitan Borough Council
Warrington Borough Council
West Yorkshire PTE
White Willow Consulting
White Young Green
ZenSar (UK) Ltd
ASSOCIATE MEMBERS
The AA
BIFA (British International Freight AssociationBMF
(British Motorcyclists Federation)
CSI
Dornier Consulting GmbH
Dublin Transportation Office
Efkon AG
European Secure Vehicle Alliance (ESVA)
IET
Institution of Highways & Transportation
ITSO Ltd
Mapflow Ltd
Oracle Network
PACTS (Parliamentary Adv.Council for Transport
Safety
Pinpoint Faraday Partnership
Q-Free Tolling AS
Richmond Management Group
RNIB
Royal Institute of Navigation
Skills for Logistics
Smartex Ltd
University of Westminster
Vitronic
| 
