TRANS<I>form</I> Scotland

TRANSformScotland response to Transport White Papers.



Rt. Hon. Dr Calum MacDonald MP
Minister for Housing, Transport and European Affairs
The Scottish Office
St. Andrew's House
Regent Road
Edinburgh
EH1 3DG


4th September 1998

Dear Dr MacDonald

TRANSform Scotland response to Transport White Papers

TRANSform Scotland broadly welcomes the publication of the Government's Transport White Papers as a contribution towards more sustainable transport systems. We certainly recognise that they represent a considerable shift in attitude, with a welcome focus on integration - away from the fragmentation and deregulation that has characterised much of recent UK transport policy. We are however concerned that this attitudinal change is not being backed up by high priority and swift action in addressing failings in the country's legislative base.

We certainly agree with Deputy Prime Minister John Prescott, who, upon the launch of the DETR White Paper "A New Deal for Transport: Better for Everyone" said that "radical change is necessary" and that "no change is not an option." We are however somewhat more concerned that action to achieve Mr. Prescott's "decent, modern and reliable public transport system" may be too slow in delivery. We are further concerned that the equivalent White Paper for Scotland, "Travel Choices for Scotland", while echoing many of the issues presented in the DETR White Paper, does not provide the necessary detail on how policy will be taken forward quickly. It is also unclear how the two documents relate to each other, but as Scotland is part of the UK, and except where specific policies in the Scottish Paper obviously differ from those contained in the DETR Paper, we must presume that the contents of the DETR Paper are also relevant to Scotland.

We welcome the recognition of different accessibility needs of the Scottish population, encompassing those of women, the disabled, older people, young people, people with children, those on low incomes and those without work. With 38% of Scottish households having no car, the Government's recognition that transport solutions cannot be just car-based solutions is propitious. We also welcome introduction of a more sophisticated analysis of the needs of urban and rural populations, acknowledging that the Scottish population lives across a continuum of settlements, from cities and large towns through smaller more remote settlements, to genuinely remote communities, for example Scotland's island communities.

We urge the Scottish Office to keep to the timetable for consultation outlined within "Travel Choices for Scotland", but to ensure that such consultation documents have a wide circulation and are presented in a style that is accessible and transparent, so enabling public involvement in the process.


Funding provisions for roads and public transport infrastructure

We welcome the commitment to hypothecation of transport tax revenues towards better local public transport and traffic management. However, for local authority charging schemes - whether urban road user charging or taxation of workplace car parking - to be introduced on a widespread basis, it is important that this principle is turned into legislation as soon as possible. There is concern that with funding from these sources remaining uncertain, and being subject to new legislation and further consultation, and then only after the completion of trial schemes, that significant modal shift from road to public transport, walking and cycling will not begin for a number of years. A further concern raised, especially relevant for local authority financing, has been whether revenue from these charges will be expected to replace, or be additional to, existing local government funding. We trust that the Scottish Office will undertake consultation on road user and workplace car parking charging swiftly with a view to introducing enabling legislation as soon as possible.

We welcome the introduction of the transitional Scottish Public Transport Fund. We hope that it will be used judiciously until such time as new local authority revenues can be brought into operation. We also welcome the extra funds for additional CalMac ferries and the previously-announced funds for rural transport schemes. However, we would like to seek assurance that the Public Transport Fund is also available for projects that support walking and cycling, and for traffic calming / speed reduction projects. As such, we would recommend renaming of the fund the 'Scottish Sustainable Transport Fund.'

We are pleased to see commitments towards continuing the fuel duty inflator at 6% above inflation, with a commitment to vary vehicle excise duty to encourage lower emission vehicles. We are however unhappy that the Urban Fuel Surcharge concept, as applied in Vancouver and elsewhere, has not been taken forward for the Scottish Central Belt area. Such a scheme could help redress the imbalance between rural and urban fuel prices in a more direct way that can be provided by urban road user charges.

We welcome the announcement of the end of a 'predict and provide' approach to road building. The work of the Standing Advisory Committee on Trunk Road Assessment in establishing that new road construction can simply generate new traffic and that economic regeneration will not necessarily follow has been important, and we trust that the Scottish Office will bear these findings in mind when assessing any new road proposals. The commitment to constrain demand is timely. The focus on making better use of existing capacity and analysis of other modes as an alternative to new roads is especially welcome; however, we are yet to see a commitment towards moving to a common appraisal framework for trunk road and public transport schemes.

We are concerned that the Scottish White Paper equivocates about possibilities for major new trunk-road building, especially given the apparent contradiction between the need to "overcome ... key blockages on the trunk road network" (para. 3.3.2), which suggests a considerable role for road construction, with the critique of 'predict and provide' in para. 2.2.7 that such a process is "unaffordable, unsustainable and ultimately self-defeating."

We are troubled with the announcement, issued in parallel to the Scottish White Paper, that Scottish Office trunk road spending will rise from £155.6 million in 1997/98 to £185.8 million in 2000/01, which exceeds by some considerable amount the £90 million made available over three years under the Public Transport Fund, and even then excluding private-funded road construction (PFI, shadow tolling, etc.). The large and increasing scale of the proposed trunk road budget doesn't sit well with the new policy direction presented in most of the Transport White Papers. Even accounting for a backlog in essential maintenance work, it currently appears likely that capital expenditure on capacity-increasing road improvements will exceed that spent on other modes. This is transparently in conflict with the vision set out in the Scottish White Paper. We would strongly recommend that the Public Transport Fund is substantially increased in scale with the Trunk Road Budget decreased by a commensurate amount.

We are also concerned that the Scottish Paper keeps trunk road and public transport budgets and operation far more separate than is healthy. It is our view that integration of transport must be extended to the financing of transport infrastructure. We are concerned that new trunk roads will not always be assessed on a corridor basis, that is along with public transport and planning initiatives. The Scottish White Paper has proposals for a Trunk Road Development Budget but fails to refer to Railtrack Scotland's Network Management Statement, apparently contradicting the commitment to integration.

While we welcome the move towards trial schemes for road user charging on trunk roads including motorways through the new Trunk Road Development Budget, we do not support revenue raised by trunk road tolling being retained for spending on new roads projects. While road user charging on local (mainly urban) roads is presented as a means of managing the demand for road space, trunk road charges are presented as a means to directly fund capacity increases to the trunk road network otherwise likely to be unaffordable. We find the naming of proposals for a M74 Northern Extension and a M8 upgrading in para. 4.3.13 to be a quite unfortunate use of examples in advance of the consultation process on the Review of the Strategic Roads Programme in Scotland.

We are however pleased to see in the DETR White Paper the announcement that in England the Highways Agency will be reformed and given a trunk road network management role, with priority given to the maintenance of, and the better use of, the existing network rather than building new roads. We would like to see the Scottish Office follow this lead, with the role of the National Roads Directorate being reviewed such that it is given a role akin to that of the Highways Agency, including more complete integration into other sections of Scottish Office's transportation planning framework.



Other White Paper policy measures

We welcome the DETR Paper's revised framework for local authorities to bid for funds from central government through the system of Local Transport Plans, but are concerned that Scottish local authorities are only given an "invitation" to draw up Local Transport Strategies. We would hope that funds from the Public Transport Fund are not made available to local authorities who choose not to construct Local Transport Strategies, and then only to local authorities who meet suitable criteria, for example progress towards fulfilling the Road Traffic Reduction Act 1997.

We commend the Government for its stance of identifying high quality bus services with road space prioritised for their use as being essential to public transport improvement. We welcome measures to ensure stringent enforcement of bus lanes to deter illegal parking by motorists. We welcome the commitment in the DETR Paper to give statutory force to exclusive Quality Partnerships to run buses on particular routes. We would have preferred, however, to have seen reference to statutory powers for promotion and participation in joint ticketing schemes between local authorities and transport operators.

We welcome the commitment to an integrated national public transport information system to be in place by 2000. We are pleased to see the commitment to a national minimum concessionary fares scheme for pensioners. We are pleased to see the issue of security of passengers being addressed with the commitment to 'Secure Stations' scheme and in addressing passengers' fear of crime being timely.

We welcome the proposed new Strategic Rail Authority to look into network improvement and promotion of integration with other forms of transport. We welcome the creation of the rail Infrastructure Investment Fund referred to in the DETR Paper, and seek assurance that this fund can be spent in Scotland. The announcements of a suspension of the sale of British Railways Board land and support for plans for a piggyback gauge rail freight route from the Channel Tunnel to Scotland are also timely. The announcement that 41-tonne lorries on six axles will be allowed from January 1999, while not in itself a good move, is preferable to the anticipated acceptance of 44-tonne lorries: hopefully this may give freight operators some "breathing space" thus helping facilitate modal shift to rail.

The DETR White Paper's commitment to improving conditions for pedestrians is very welcome, encompassing developments such as wider pavements, more widespread pedestrianisation, better footpath maintenance and higher priority for pedestrians at crossings. We are pleased to see commitment in the DETR White Paper to frame policies to help reduce the need for children to be driven to school by encouraging safer routes for walking and cycling, and by giving greater priority to public transport, in order to cut down on the "school run." We are encouraged by support for local authorities to develop lower speed limits and pedestrianised areas, including the development of "Home Zones," as well as a national review of speed limits. However, we are very disappointed by the Scottish White Paper's failure to address many of these issues adequately: this will be dealt with in the section below.

We are pleased to see practical partnership projects such as green travel plans for businesses, local authorities, hospitals and Government buildings, such as the Scottish Office Victoria Quay Green Travel Plan. We agree that it is important that Government officials show commitment to Government transport policy in their day-to-day choice of transport mode. We also welcome the Scottish White Paper's commitments to supporting travel awareness campaigns for Scotland.

While we believe that setting national traffic reduction targets should have been set by Government directly, the creation of the UK Commission for Integrated Transport (CfIT) may well prove very useful in monitoring progress on policy implementation and providing independent expert advice to the Government. The role of this body in Scotland, and how it will interact with the National Transport Forum for Scotland is unclear and we would appreciate clarification soon.

On the topic of regional transport decision-making, we are happy to see the Government recommend the setting-up of between four and six "Regional Transport Bodies", based either on the PTE model or the local authority "Transport Partnership" model such as that being developed in south-east Scotland. We would favour the creation of Regional Transport and Land Use Authorities as an appropriate way to integrate transport planning into broader land use planning requirements.



Key omissions from the White Papers.

We are disappointed that both White Papers omitted commitment towards powers for local (or indeed national) charges on parking spaces at retail and leisure developments, and perhaps more particularly at out-of-town car-based developments. This is disappointing as it would undoubtedly be important in reversing the trend towards out-of-town shopping, as well as providing an important instrument for raising money for sustainable transport. We hope that the Government will seek to extend new legislation required to bring in urban road charging and workplace car park charging to include trial schemes for out-of-town shopping centres.

We are disappointed that neither White Paper included a national traffic reduction target. Indeed both Papers talk of reducing the rate of growth of motor traffic - which of course means continued actual growth in traffic. We wish to see the CfIT, and its Scottish equivalent the National Transport Forum for Scotland, report on the topic of traffic reduction targets as soon as is practicable. We strongly urge the Scottish Office to draw up national Scottish traffic reduction targets, which local authorities can then use to seek to reduce traffic in their localities, following the provisions of the Road Traffic Reduction Act (1997).

We are however disappointed by the failure of the Scottish White Paper to make specific new proposals relating to walking, cycling or 'safe routes to school.' This is in clear contrast to the clear policy guidance contained in the DETR White Paper. While we approve of the Government's endorsement of the previous Government's National Cycling Strategy target to double cycling in six years, and the Scottish White Paper's acknowledgement of cycling as "a vital mode in reducing car use" (para. 4.6.1), the principal cycling section introduces no new initiatives, and has no new funds allocated. Previous considerations of a new 'Cycle Challenge' scheme have even been omitted. We would appreciate clarification as to whether the Public Transport Fund will be applicable for cycle and pedestrian projects.

We are concerned about the lack of support for light rail schemes. While capital costs in such schemes may indeed be higher than that of bus priority measures, light rail schemes in cities such as Manchester have proved successful in attracting public support and attention towards high quality public transport alternatives.

We welcome the Scottish Office's commitment to making "increasing use of economic instruments such as pricing and taxation to send clear signals about the wider social and environmental impacts of travel decisions" (para. 2.35). However, we are concerned at the lack of progress in attempting to identify, let alone incorporate, the wider environmental and social costs of private motoring into the tax framework. Studies such as that of David Maddison et al. of University College London ('The True Cost of Road Transport', 1996) have estimated that the costs road users impose on the rest of society exceed the taxes that they pay by a factor of three. While all road taxes that the Treasury received were calculated to come to £16.4 billion (i.e. fuel tax and Vehicle Excise Duty), road transport in the UK imposed costs of between £45.9 and £52.9 billion on the economy (incorporating congestion costs, air pollution, noise pollution, road damage, accident costs, and climate change costs, all at 1993 figures). These estimates omit other effective subsidies to car use such as company car subsidies, policing costs, licensing costs and new road-building. It is widely accepted that motorists now face historically lowest real costs of car use, as against historically high real public transport prices. We would contend that until debate is informed about the reality of this effective subsidy towards car use, and that the Government is seen to develop policies to "internalise" these costs, that a bias towards private motorised transport will continue.



Immediate priorities for action.

We welcome the Government's commitment towards providing solutions to the UK's transport crisis, a task that had been conspicuously avoided by previous Governments. We are however concerned that progress towards fulfilling the laudable aims of the White Papers will be slow, to the detriment of the economy, the environment and the transport accessibility needs of Scotland's population. One of the most striking commitments of the Scottish White Paper is that to continued consultation, which, while preferable to an absence of consultation, follows three years of wide-ranging and in depth consultation on transport policy conducted both by the current Government and by the previous administration.

We welcome the commitment to "publish new indicators so as to allow progress to be measured" (para.2.69). We need to see early Governmental commitment to setting national traffic reduction targets, as set out under the provisions of the Road Traffic Reduction (National Targets) Act 1998. We trust that the National Transport Forum for Scotland and its UK counterpart, the Commission for Integrated Transport, will be able to report to the Government on this matter before the end of the year. Additional to traffic reduction targets must be corridor forecasts of trunk road movements and modal share, to be used by local authority plans for road traffic reduction, under the provisions of the RTR (1997) Act. We must also see compilation of Scottish national targets and indicators for road safety, traffic-related air pollution and climate change gas reductions.

We need to see an early commitment to moving away from road capacity increases on Central Belt corridors. The good faith that organisations like ourselves place in the Government's commitment to a shift in transport policies towards a base in sustainability will undoubtedly be tested if we are to see hundreds of millions of pounds squandered on developments such a M74 Northern Extension, a six-lane M8 or an M80 through the Kelvin Valley. Developments of this scale are not concomitant with sustainable transport polices being sound neither in terms of environmental nor social policy, and would dwarf the expenditure committed to the Public Transport Fund. If we are to proceed with large-scale development projects then projects such as direct rail electrification of the Glasgow Central - Shotts - Edinburgh corridor should be prioritised as being more consistent with principles of sustainable development.

Lastly, we need to see the Scottish Office set a good example. While the Green Transport Plan for its Victoria Quay, Leith, offices is a valuable start, we need to see the Scottish Parliament be based on a sustainable transport access strategy. The current planning application for parking spaces for each MSP runs counter to the focus of "Travel Choices for Scotland." The Scottish Parliament must demonstrate a genuine commitment to sustainable transport systems for Scotland, with parking spaces reserved only for those with special needs, and with a presumption in favour of access by walking, cycling and public transport.

I look forward to your comments on our representations, and look forward to discussing some of these matters in more detail with you at our meeting on September 23rd.



Yours sincerely,


Colin Howden
Campaign & Development Manager, TRANSform Scotland


cc: Stephen Garland, Transport Policy Branch, Transport Division 1, The Scottish Office.

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