The National Farmers' Union

  The National Farmers' Union (NFU) represents some 75,000 farming members in England and Wales, and an additional 40,000 "countryside" members with an interest in farming and the countryside. Agricultural industry representation covers tenant farmers and owner occupiers as well as farm co-operatives.

  With a wide range of agricultural and horticultural businesses, the NFU has a vital interest in securing a sensible transport strategy. Furthermore, many of its members also provide tourism, recreation and leisure facilities, and their land may be used by other industries such as wind farming, aggregate extraction, rural crafts, storage, fuel for power generation or even licensed waste disposal. Finally, its members are rural dwellers. They and their families have a keen personal, as well as business, interest in the transport debate.

RESPONSE TO PROPOSALS

General Comment

  The White Paper has many laudable aims, and few could object to the overall objectives of reducing congestion, improving public transport and a cleaner environment. However, it is an eclectic document with few new ideas for immediate action, but lots of promises of new policies, mechanisms and structures for the future. Whilst it is accepted that it is intended there should be further consultation in many areas of more detail, few hard facts are presented on which to judge whether or not the objectives will or indeed can be achieved. This is especially the case with many of the important decisions in how to achieve objectives being devolved to Local Authorities or new quangos.

SPECIFIC AREAS

Commission for Integrated Transport

  The intention to establish an independent body to provide advice on implementation of integrated transport policy and related issues is a worthy objective. In the light of the example of the Firearms Consultative Committee, it is, however, questionable as to the benefits that will accrue from such an approach. It is imperative that if the Commission for Integrated Transport is established, it must be an effective body.

Funding for Transport

  The White Paper focuses on the comprehensive spending review three year approach as giving a better base on which to plan and manage transport programmes and also highlights a number of new funding areas for development, including road user charging. In that review, significant sums are to be retained by the DETR to be invested over the thre year period in other areas of transport apart from rail. Around one-third will be spent on improved road maintenance and much of the rest passed to Local Authorities for transport related measures including support for bus services.

  The increase in investment is welcomed after cuts of previous years and the emphasis on road maintenance is also welcomed. The White Paper's recognition of the importance of investment is noted as responding to lobbying from transport interests. However, the increase is still significantly less than the increase in transport investment required to comprehensively modernise our transport system.

INVESTMENT IN RAIL

  We note that there will be additional funds made available to cover infrastructure and passengers. We welcome the infrastructure investment being focused on addressing capacity constraints on key rail infrastructure to supplement that invested by Railtrack with a view to ensuring sufficient capacity to meet anticipated increase demand fro rail freight. However, such investment should not be the expense of investment in the road infrastructure.

INVESTMENT IN TRUNK ROADS

  Whilst noting that the Highways Agency will explore the scope for private financing of trunk roads and will be giving maintenance of current trunk road infrastructure priority,w e also note that the White Paper contains a proposed series of routes for de-trunking. Whilst it is difficult at this stage to make any informed conclusions on the proposal as criteria for de-trunking is not available, we question whether this is not a case of giving with one hand whilst taking away with the other.

INTEGRATING TRANSPORT AND PLANNING IN ENGLAND

  We note that it is the intention of Government to publish draft guidance (PPG 11) setting out new arrangements for Regional Planning Guidance to include Regional Transport Strategies. In the absence of further detail, we cannot comment further on this except to highlight the need for such guidance to address the rural dimensions of the transport debate.

REGIONAL TRANSPORT STRATEGIES

  Whilst in theory we support the proposed changes to the procedures involved in the production of Regional Planning Guidance, this would be with the caveat that the Regional Planning Conference comprises as wide a range of interested organisations and democratically accountable members as possible to ensure that a single minority interest does not have undue influence. The DETR's consultation on the Future of Regional Planning Guidance (January 1998) aims to ensure that any organisations with a purely commercial interest in the planning process will not be able to unduly influence decisions. We would also wish to ensure that those elected members that represent rural wards and those organisations that represent rural issues are fully involved in the process on the basis that in the past, there has tended to be an urban emphasis on the production of Regional Planning Guidance.

LOCAL TRANSPORT PLANS

  Noting that local transport plans will be the centrepiece of the proposals in respect of integrating transport and planning, our main concern is the failure to identify in the White Paper if local transport plans will become a material planning consideration. Although the paper makes it clear that the plans will be statutory, it does not identify their future role in the development plan process.

  We would also raise reservations about any linking of the plan to Local Agenda 21 strategies. All too often Local Agenda 21 strategies are perceived as a green policy tool i.e., they reflect closely the Bruntland definition (1987) of Sustainable Development (development that meets the needs of today's generation without compromising the ability of future generations to meet theirs) by interpreting this into local protectionist policies. Planning Policy Guidance 7 gives a much wider definition of sustainable development that reflects rural economic and social matters, and we believe this should be incorporated into Local Agenda 21 strategies in rural areas particularly if they are to inform local transport plans.

RURAL SERVICES

  We welcome the recognition given in the White Paper to the poor state of public transport in rural areas. We note that the Commission for Integrated Transport willb e asked to advise on future funding priorities in this area. We welcome, in line with Planning Policy Guidance 7, the emphasis on encouraging local services. However, we are concerned about the potential use of key villages as a policy tool. Key villages are an outdated planning tool whereby resources and services are focused on one village (in a hierarchy of rural settlements) leaving others to fend for themselves. This is no longer recognised as a valid planning tool and instead villages etc. are considered on their own merits. It is important that policies for reducing the need to travel should be considered in the same light.

NEW POLICY GUIDANCE

  We note the intention that planning guidance will be updated to create the right framework to deliver integrated transport policy at a local level. We note that in respect of transport, the guidance will be updated in a number of areas but it would appear that what is being suggested is merely good practice already in many Local Authorities.

  We note that for housing, planning guidance will be revised to give clear advice on the location and form of housing development and that Local Authorities will need to consider future travel patterns when planning for new houses but would urge that the need for affordable housing—especially affordable to those living and working in the rural environment—in rural areas must not be forgotten in this (in line with Circular 6/98 on Planning and Affordable Housing).

BETTER IMPLEMENTATION

  The White Paper states that Government will look for improvements in delivery of an integrated transport policy through various routes.

  On a review of the Use Classes Order, we have already responded to a consultation in this area for a new business use class. In summary, we are concerned that a rural business use class would seek to use traffic generation and character as a means of control. We consider that this proposal would be difficult, if not impossible, to implement and enforce since it is unclear at what point traffic volume and character becomes unacceptable. There would therefore remain an uncertainty for developers who would not be able to plan for business growth or expansion.

  On review of the General Committee Development Order, with lack of detail, it is difficult to comment on. We would not wish to see any proposals that would cause undue delay to the agricultural community and that would prevent them being able to continue to carry out small scale essential changes swiftly and efficiently as required by the business.

  On updating guidance on use of planning conditions, we would seek to ensue that updating was in line with Circular 11/95 on the Use of Conditions in Planning Permission.

  On the encouragement of incorporation of green transport plans into planning obligations, we are unclear as to what is meant by "a green transport plan". If this is not to be the same as a local transport plan, then this should be defined clearly. Any changes to planning obligations must be in line with Circular 1/97 on Planning Obligations.

TACKLING CONGESTION ON LOCAL ROADS

  Representing a rurally based industry and persons living in rural communities, we are particularly concerned over the proposals relating to the introduction of legislation to allow Local Authorities to charge road users as part of a package of measures in a local transport plan. Whilst this is going to be subject to a further consultation on how road user charging schemes could operate, introduction of such charges in rural areas where there are significant problems caused by high levels of seasonal traffic, could present significant problems for a rurally based industry and residents therein. The needs of rurally based businesses must not be overlooked in utilisation of such schemes.

CHARGING MOTORWAY/TRUNK ROAD USERS

  The NFU notes that it is intended to develop pilot charging schemes and that full implementation will be dependent on development of appropriate technology and studies on impact in areas such as personal privacy and diversion onto non-tolled roads. We note that the intention expressed in the White paper goes beyond the intentions in proposals announced in 1992 to target users of inter-urban motorways. Whilst it is recognised that such an approach may be a mechanism for dealing with localised urban congestion in specific problem areas, we believe it inappropriate for wide scale implementation, particularly encompassing the trunk road network, since it would impact on the needs to move freight through and to/from such areas and would lead to diversion onto non-tolled roads with consequential problems being generated thereon.

WORKPLACE PARKING

  The NFU note the intention to introduce legislation to enable Local Authorities to levy a new parking charge to apply to all types of private non-residential workplace parking. We note that non-workplace non-residential parking (e.g., at retail sites) will not be subject to charging.

  The White Paper does not give detail on implementation of this proposal although it does promise further consultation on how the scheme will operate. However, if the intention is to impose charging for parking in the workplace, and, it is not focused in urban areas where congestion is a primary problem, then the implications for rurally based industries, including agriculture will be signficant.

  Sectors of the agricultural and horticultural industry require significant workplace parking to be provided, particularly the intensive horticulture sectors. Imposition of a parking tax on such businesses will be a significant burden. The NFU are opposed to workplace charging in rural areas on sites such as agricultural holdings.

  Application of workplace parking in the rural environment will also be contrary to the objectives expressed in the White Paper incentives to encourage the use of local services and encouraging local employment. For example, farm diversification schemes creating employment can reduce the need to travel significantly, but will suffer if they are to be on the receiving end of both workplace charging and/or congestion charging in rural areas.

  We are also concerned over the impact of urban charging as those obliged to take supplementary employment in urban areas to support rural businesses.

ECONOMIC INSTRUMENTS

  The White Paper recognises the use of economic instruments, such as price measures and taxation, as an important way of influencing travel choice. Differential fuel duty is already used in this way and it is noted that Government are looking at ways of using taxation on vehicles to achieve similar results.

  Determination of the wider environmental and social costs resulting from transport in order to ensure that transport users pay more accurately for them is extremely difficult. Many reports by various organisations have over the years sought to "internalise and apportion the external costs" of transport arising from various sources. There are many uncertainties. An attempt to use taxation to precisely reflect external costs would be dangerous as a consequence of the uncertainty and variable with time.

  However, whilst external costs may not be safety used to change overall levels of taxation of road users in particular, improving the link between supply and demand for infrastructure and re-balancing the tax and charging regime in transport may improve the current system where external costs are not taken into account at all. However, any change introduced must meet certain key requirements:

—  it must be undertaken in the light of pan-EU harmonisation of taxation and the Government must continue to work for such harmonisation;

—  it must take full account of UK competitiveness in the European and international markets;

—  it must not increase the overall tax burden on business;

—  it must be more transparent, be enforceable and cost efficient;

—  it must deliver a more consistent and increased funding for transport;

—  it must not disadvantage rurally based industries and communities unnecessarily;

—  it must be carefully researched before introduction and must be consulted upon throughout industry and the private sector, and;

—  it should comprise a comprehensive package of change to enable effective targeting of charging benefit.

  The NFU note that vehicle excise duty is already subject to reform with the introduction of legislation allowing reduced taxation for high emission standard HGVs, and, the development of the introduction of graduated vehicle excise duty for cars. However, whilst it has been suggested by some that vehicle excise duty might be significantly reduced or abolished altogether with a revenue-neutral increase in fuel duty, this would not be a simple process. Different levels of vehicle excise duty reduction might be needed for different categories of vehicles. Rural drivers and businesses who necessarily have high mileages and therefore higher fuel usage must not be disproportionately affected, and some mechanism to ensure fiscal neutrality will have to be devised for such users.

VEHICLE AND FUEL STANDARDS

  The White Paper notes continued support for research into more efficient vehicle design and the use of alternative fuels. The NFU fully support this approach. On alternative fuels, one principal area of interest to the agricultural industry is in the development of cleaner energy sources utilising materials of agricultural origin. Fuels showing most promise but requiring further development are ethanol and methanol, and fuel calls can be derived from wood sources i.e., biomass of agricultural origin.

  The introduction of the "non-food uses" option in the EC arable setaside scheme was an important step in developing a positive agricultural contribution in these areas. Under the right fiscal and technical conditions, the agricultural industry will be able to make a major contribution to the development of a more environmental friendly transport system through a cleaner energy route. The NFU believe it is imperative that the Government should offer appropriate incentives to the development of cleaner energy, such as pilot plant status for biodiesel production.

BETTER AIR QUALITY

  We note the system of local air quality management and that Local Authorities have a duty to assess air quality in their area to determine compliance with strategy objectives. We are concerned that the Local Authority power to designate an air quality management area will be yet another opportunity to set up another local designation, but this time with boundaries that are potentially undefinable. The NFU have experienced many problems in achieving essential development due to various forms of environmental and landscape designations, and we would be opposed to the use of any further designations such as air quality designations to restrict required agricultural development.

ROAD TRAFFIC ENFORCEMENT

  The NFU policy in respect of legislation in relation to road traffic is that the NFU does not condone any breach of legislation. The NFU recognise that in ensuring compliance with relevant legislation, there is need for adequate and effective enforcement. We therefore recognise the need to ensure that such enforcement can be enabled. However, enforcement must be based on a combination of capability and trust. Whilst technology can be utilised for certain enforcement activities with a reasonable degree of reliability, such as use of speed cameras, the need to utilise human resources in enforcement will continue. Any proposals to increase the role of other agencies in enforcement activity, apart from the police, should be carefully thought through and it is noted that Government are intending to consult on extension of powers to be granted to other bodies for enforcement purposes.

  The NFU welcome the White Paper commitment to enforcement which respects the right of individuals but is properly targeted on the bad driving and anti-social behaviour. To this, the NFU would add the need to ensure that enforcement also targets vehicle operators who by virtue of failure to comply with the legislation put themselves in an economically advantageous position relative to those who comply. This is particularly the case in respect of the HGV sector and abuse of the Operator Licensing system. We therefore welcome that the White Paper includes stated intentions to improve co-ordination of activities between different Enforcement Agencies and to bring forward legislation to enable detention of illegally operated vehicles.

BETTER APPRAISAL

  The NFU note that transport impact assessments will be incorporated in the process of assessing the environmental implications of all relevant Government policies and major location decisions. We would wish to ensure that there is no duplication with existing environmental appraisals which are both costly and time consuming. Major development proposals are already subject to environmental impact appraisals.

  It is noted that environmental impact appraisals will be enhanced in their use and that for all environmentally sensitive sites or areas, there will be a strong presumption against new or expanded transport infrastructure which would significantly affect them.

  This does create a slight contradiction in the White Paper in that it may fail to recognise the need for an integrated and efficient transport system for all. How will the transport needs of those who live in sensitive areas be addressed where such a presumption against is in place. This is especially important given that many of them are in remote rural areas? What will happen to the traffic that might divert away from the sensitive areas and possibly create problems in non-sensitive areas?

RURAL TRAFFIC

  In considering integrated transport, the White Paper does comment on rural traffic, focusing on demonstration projects in Cumbria, Surrey and Dartmoor as examples of what might be done. The use of appropriate traffic management on a strategic basis is recognised and the work of the Countryside Commission is referenced in respect of their Quiet Roads Initiative. Whilst recognising the concerns regarding increasing traffic in rural areas, the NFU are extremely concerned that in seeking to address those concerns, the needs of rural industry and rural communities will be over looked. Efficient transport services and an effective and useable infrastructure in rural areas are central to the continuing agricultural industry and to rural communities. Policies and practices impacting on rural roads must recognise this. Movements of freight and of people for business purposes is essential and as is already being seen, measures being utilised to control traffic in rural areas are having significant impacts on the industry. Reduced speed limits and traffic calming measures are examples.

  The NFU are particular concerned with the Countryside Commission activities in respect of the Quiet Roads Initiative. The proposals to make rural roads pedestrian, cycling and horse riding predominant will significantly impact on the agricultural industry.

  The NFU notes that the White Paper recognises the importance of goods delivery by transport systems and that government intends to ensure sustainable goods distribution. The NFU awaits with interest the strategy that is to be published in order to deliver this objective.

  Whilst the White Paper does cover a number of areas in relation to freight distribution, there is an impression that whilst the White Paper addresses the commercial dimensions of transport policy, the main thrust of the document concentrates on people movement and relieving congestion. The NFU is concerned that future policies will be dominated by such concerns about people movement and as a consequence could set frameworks that are detrimental to commercial movements.

VEHICLE WEIGHTS

  The NFU notes one of the few firm commitments made in the White Paper is in respect of vehicle weights. The NFU is disappointed with the continuing Government rejection of 44 tonne maximum permitted weight even though this was recommended as long ago as 1980. The NFU note that one of the prime reasons for not introducing 44 tonnes at this stage is the fear that such a move could prejudice the objective of promoting rail freight. The NFU continues to urge the Government to introduce 44 tonnes across the board at the earliest opportunity.

SUITABLE ROADS

  The NFU notes that Government shares the concerns of those, especially in the rural communities, regarding problems caused by heavy goods vehicles. The NFU shares these concerns. However, the NFU is concerned that in seeking to address the problems of heavy goods vehicles travelling on unsuitable roads, the powers given to Local Authorities to prohibit or restrict heavy goods vehicle access will become too liberally used. There is already evidence that Local Authorities are seeking to use their current powers to introduce restrictions on vehicle access covering areas rather than specific problem roads. Increasing imposition of weight restriction on bridges on rural roads causes particular problems. No consideration is given in some cases to the requirements for access by frontages in roads or areas affected, nor, consideration in respect of businesses utilising vehicles in affected areas such as agricultural vehicles.

  Determination of suitability or otherwise of a road for use by classes of vehicles should be subjected to certain criteria but such criteria should include the need for access and efficient freight distribution as well as consideration of the requirement to create a more peaceful countryside.

  The NFU awaits with interest further details on proposals under this heading.

INLAND WATERWAYS

  The NFU notes that it is Government's intention to encourage greater use of inland waterways where it is practical and an economic option for freight transport. For agricultural purposes, the inland waterway system faces the same problems as the railway system in respect of lack of localised infrastructure available to the majority of agricultural production sites in the UK, although the unit size of the carriers on the canal system for freight transport is more suited to individual agricultural producers/utilisers than is the case with railways.

  The NFU awaits the revised planning guidance which will encourage more freight to be carried on the water and Local Authority Development Plans which will be expected to consider opportunities for new development to be served by waterways.

  The NFU would raise concerns, however, about possible impacts of upgrading and reconnecting remaining working systems and construction of new parts of the inland waterways on adjoining landowners.

RAILWAYS

  The NFU notes that railways both nationally and locally are not delivering their full potential as alternative modes for goods or people transport.

  The NFU believes that railways can play an important part in the development and implementation of an integrated transport policy provided that:

—  rail transport is competitive, flexible and reliable;

—  improvements are made to rail infrastructure;

—  rail becomes a normal part of the transport chain without the need for specialist equipment;

—  investment is made to fund loading gauge improvements to allow, for example, the piggy back carriage of road vehicles;

—  the rail freight grant system is enhanced;

—  costs are reduced by reducing or removing track access charges, and;

—  development of inter-modal transfer systems is encouraged.

  However, in respect of integrated transport development, railways are unable to service the local needs of the agricultural business or rurally based community in many cases simply because of lack of infrastructure.