The National Society for Clean Air and Environmental Protection (NSCA), which this year celebrates its centenary, is a charitable organisation which brings together local government, business and industry and other NGO's to campaign on issues of air quality and environmental protection.

INTRODUCTION

  One of the most noticeable and consistent social trends in this country, and indeed throughout Europe and North America, has been the increased mobility of the populace. This mobility has been achieved mainly through the ever widening availability of the private car and the ability of the average household to afford to own and run them. The impact of the car on modern society cannot be over-estimated and for most of the latter half of the century, that impact has been seen as largely beneficial. As a result, successive Governments' transport policies have sought to facilitate the increase in car ownership and mobility to the detriment of other forms of transport and have helped create a culture which is dependent on the car and where the vast majority of freight is moved by road.

  However, over the past decade, the full social cost of an ever increasing trend towards private car travel and road freight has become apparent. Road transport is now the single largest source of ambient air pollution and noise and nearly all towns and cities, as well as large sections of our motorway network, enter virtual gridlock at least twice a day. The resources consumed by the manufacture and operation of road vehicles and the provision and maintenance of roads themselves is exceeding the capacity of our environment to supply them indefinitely. Not only is there a significant cost to industry arising from congestion but the effect on the quality of life in this country now outweighs the benefits brought by increased mobility in the first place.

  The task of resolving our transport problems is one of unparalleled difficulty, i.e., the reversal of a social trend whose growth has actively been encouraged for the last fifty years and which has become central to so many other parts of modern life. The introduction of a balanced and integrated transport policy is the first step towards the attainment of this goal.

THE NSCA'S RESPONSE

  The NSCA warmly welcomes the publication of the Government's White Paper on the future of Transport, A New Deal for Transport: Better for Everyone and the aims and aspirations contained within it. Particularly welcome is the recognition that transport policy must reflect social concerns, as embodied in the concept of sustainable development, rather than simply providing transport, particularly road transport, in isolation from other issues. The White Paper focuses instead on access and the provision of a viable set of alternatives which allow that access. The most obvious examples of this are the quality partnerships and quality contracts which local authorities can enter into with local public transport providers. If managed properly, these measures could go some way to reversing the damage caused to public transport, both in terms of quality and performance, by the deregulation of bus services.

  One fundamental change in Government policy which the White Paper signals is the abandonment of the "predict and provide" philosophy in road building. This philosophy has, at best, simply moved congestion problems from one bottle neck to another and has, at worst, created an increased demand for road space and, therefore, the congestion it was intended to alleviate. In its place the Government has moved towards a more "demand management" approach, which is greatly welcomed, although it could be strengthened, particularly in terms of aviation.

  The White Paper makes clear the links between road transport and air quality, and between Local Air Quality Management and the proposed Local Transport Plans. The reduction of traffic levels in areas which suffer from poor air quality will be one of the most important factors in achieving the air quality standards set out in the National Air Quality Strategy, currently under review by the Government.[6] The deadline for achieving the standards is 2005 and work is underway in all local authorities to review and assess local air quality. The availability of policy tools such as the Local Transport Plan to local authorities will have a direct effect on whether they can complete their task in the time given.

  However, one area which the White Paper is conspicuously light on is the connection between transport and ambient noise levels. Whilst the principle sources of complaint received by local authorities are amplified music and dogs barking, the principle contributor to ambient noise levels, particularly in urban and sub-urban areas, is road transport. The levels of ambient noise experienced, while not having a proven health risk, have a dramatic effect on quality of life, an effect which should not be under-estimated.

  In addition, in areas surrounding even moderately sized airports, aviation noise is of particular concern. As with road transport, the levels of air traffic have risen dramatically in recent years and, even with the advent of quieter engines, noise levels are, for some people, reaching intolerable levels. The NSCA feels that there should be a greater recognition of the importance of ambient noise issues and their relationship to transport.

  The awareness of air quality issues amongst the general public is currently at a particularly high level, as is frustration at the congestion on our roads and the apparent inefficiency of our rail system. A great deal of public interest was generated by the publication of the Transport White Paper and with it a raising of expectations that the general transport picture in the UK would improve over the short to medium term. It is likely that anything less than significant and visible activity to reform the transport system would be seen as a failure by the public. There must, therefore, be an assessment as to whether the White Paper can match these expectations and deliver significant improvements.

THE NSCA'S CONCERNS

  With this in mind, the NSCA, while accepting the aspirations of the White Paper, has several fundamental concerns as to whether these aspirations can actually be delivered by the measures it contains. The major concerns are threefold:

(i)  The White Paper has avoided setting any targets towards which the Government, both national and local, can work and against which progress can be measured. In its pre-election manifesto, the Labour Party stated that its aim was to "reduce and then reverse" traffic growth. Paragraph 2.25 of the White paper states that, among other things, it "sets the framework to reduce traffic growth [and] respond to the challenge of climate change . . . " While these statements provide the broad direction of government policy, without clearly defined targets, the effectiveness of the framework cannot be fully assessed.

  The lack of targets for the levels of road and rail traffic which the Government is working towards precludes making an assessment of how much the White Paper contributes to other key policy areas. As stated previously in this paper, road traffic emissions are, for the majority of the country, the largest single source of the air "pollutants of concern". It is extremely important, therefore, that the contribution of the White Paper towards the National Air Quality Strategy is understood. Equally, road transport is a major source of carbon dioxide emissions, the reduction of which is the subject of the international agreement on climate change signed by the UK Government at the Kyoto summit. Finally, the White Paper offered the Government an opportunity to state how far reductions in traffic could contribute to ambient noise level targets which, under a forthcoming EU Directive, will be required for all major urban areas. This opportunity has not been taken up.

(ii)  In order for a policy to achieve its stated aims, there must be a clear set of delivery mechanisms, i.e., it must be clearly shown how it is intended that any given policy is to be implemented in order to achieve the aims of that policy. The transport White Paper, despite containing a number of policy initiatives, including the creation of a strategic rail authority and new powers for local government to tackle congestion, does not make explicit how these are to come into being.

  This is thrown into sharper focus by the apparent lack of legislative time for any transport measures in the next one and possibly two sessions of Parliament. The NSCA considers this to be extremely short sighted; as has already been mentioned there is target of 2005 for achieving the national air quality standards and the sooner local authorities are granted their additional powers, the more likely they are to achieve the standards for their areas. In addition, the general public expects action on transport at a national, as well as local, level and anything else may well be regarded as a failure.

  Aside from this apparent lack of legislative time, there is a distinct reluctance in the White Paper to adopt a regulatory approach in addressing transport problems. The NSCA is fully supportive of the philosophy of change by consensus, where this is appropriate. However, there are circumstances when regulation is the most effective means of achieving change. For example, while there was a move towards the wearing of safety belts in cars amongst the general public, it is extremely doubtful that the levels achieved today would have been possible without legislative backing. Without national tax incentives, lead free petrol would not have become as widely used as it has and without legislation, it is doubtful whether car manufacturers would have fitted catalytic converters to all new cars.

(iii)  The legislative powers which are included in the White Paper are generally consigned to local authorities. Once again, the NSCA is supportive of the principle that local authorities should have a certain degree of freedom to decide what measures best suit their local environment. In addition, the principle that locally raised revenue, through congestion charges or parking levies, can be "recycled" into local transport schemes is one which the Society fully supports.

  However, another view suggests that, due to the likely unpopular nature of these charges, the Government has moved them on to local authorities for political reasons, rather than as a way of enhancing local democracy. The Government has failed to provide strong political or regulatory support for local authorities who will be taking up these new powers, when they become available. Nor has it made any suggestions as to how it feels the powers should be applied. At the very least there should be a commitment to providing clear and comprehensive guidance so that the national picture can be harmonised.

  The result of the discretionary nature of the charging schemes is that, in some areas at least, they may not be invoked, purely for reasons of local competition. It is a modern reality that neighbouring authorities occasionally compete to attract employers into their area in a way which is detrimental to the local environment. A national parking tax, or, at the very least, regional parking guidance, would level the playing field and allow fair competition.

PROPOSALS FOR ACTION

  In order that the objectives of the White Paper can be achieved, the NSCA believes that a number of further measures should be considered. The intention of these, overall, is to redress the current imbalance between national and local measures, to give stronger support to local authorities implementing the new measures and provide a wider toolkit for tackling congestion and air quality problems.

  Stronger fiscal incentives for cleaner fuels. One of the most successful, environmentally driven consumer changes in recent years was the introduction of lead-free petrol. Not only did this dramatically reduce the levels of lead in the atmosphere but it also allowed the widespread introduction of catalytic converters. However, lead-free petrol would not have made the impact it did without the fiscal incentive of a differential excise duty rate which resulted in it being cheaper, and therefore more attractive to consumers, than leaded petrol. The range of cleaner, alternative fuels is now far greater, including low sulphur diesel. LPG and CNG, and cleaner petrol formulations. If these are to be allowed to make their full contribution to the improvement of air quality they too should receive strong fiscal incentives.

  However, given the range of cleaner fuels currently available and coming on stream, there needs to be an assessment of what the optimum fuel mix for the UK fleet should be. In this way, the incentives can be manipulated to achieve this optimum balance and therefore maximise the benefits available. Such a study should be commissioned by the government and should be initiated as soon as possible.

  Mandatory environmental performance standards for public transport. It is a common complaint amongst the general public that buses, taxis and public service vehicles generally are among the worst polluters on the road. The NSCA fully supports the concepts of quality contracts and quality partnerships laid out in the White Paper but feels that they should be strengthened by the inclusion of mandatory performance standards in terms of fleet emissions and engine and fuel types. Furthermore, quality contracts should be extended to include taxi fleets.

  A strong enforcement regime for local authorities. The White Paper already contains provisional powers for locally imposed congestion and non-domestic parking charges. The NSCA proposes that, under their local transport plan, local authorities are provided with an enforcement regime which allows the effective use of, for example, bus lanes and high occupancy vehicle lanes. Under the current regime, schemes such as these are often undermined by the lack of an enforcement regime and a lack of resources with which to enforce. Local authorities must be provided with both of these along with enough flexibility to suit local circumstances.

—  The introduction of an MOT emissions test for cars under three years old. The Government is currently sponsoring a pilot scheme in seven local authority areas to carry out spot checks on vehicle emissions. Vehicles are tested against the standards set up under the Road Vehicle (Construction and Use) Regulations 1986 and it has been the experience of these local authorities that emission failure sometimes occurs in vehicles less than three years old. Such failures can be the result of poor maintenance and so there needs to be put in place a regime which encourages effective maintenance from the start, rather than waiting for three years by which time engine performance could have deteriorated considerably.

—  Strong support and a legislative framework for Low Emission Zones. The NSCA is currently undertaking an investigative project into the benefits of low emission zones to local authorities. The project enjoys the full support of the Government's Cleaner Vehicles Task Force and aims to provide local authorities with a tool kit of measures to help tackle urban air quality. However, without a legislative framework it will be extremely difficult to enforce these measures and will therefore severely undermine their usefulness.

—  Stronger disincentives for larger private cars and a realistic treatment of the company car perks package. The majority of new cars purchased each year are for use in company car fleets. This market sector will therefore be vital if a shift is to be made in the UK fleet towards smaller, less polluting vehicles. Tax incentives and disincentives are likely to be the most effective force for change although other measures should be considered. In addition, there should be a realistic attempt to reduce the number of business miles driven each year. Under the current tax system, company car owners are encouraged to drive more in order to exceed the "tax ceiling. This situation needs to be remedied at the earliest opportunity and should include the removal of free petrol for company cars.

—  Tax incentives for employee travel plans and financial support for school travel plans. It is a simple fact that the majority of congestion problems are caused by people travelling to and from work and children being taken to school by car. The Government has stated its wish to reduce rush hour traffic flows and encourage more children to walk, cycle or take the bus to school. It has been shown in several areas around the country that employee travel plans and school travel plans can make a significant contribution to this aim. Such action needs to be encouraged and, as has been illustrated earlier, tax incentives, particularly in the business sector, can be a major driving force for change. In addition, there should be support for school travel plans which often require capital investment before the collateral benefits of better child health, improved road safety and a higher quality environment in the school can be realised. The White Paper mentions some specific schemes which the Government is providing support to—this should be extended to support on a national level.