1. THE BRITISH COUNCIL FOR OFFICES

  The BCO is an organisation that includes in its broad membership business space users, developers, architects, consultants, builders and others. The BCO strives to improve the design and specification of business space to enhance its performance and its efficiency in use.

2. A NEW DEAL FOR TRANSPORT: BETTER FOR EVERYONE

  The White Paper is a wide-ranging review of the problems and challenges of creating an integrated transport system. It includes some sensible objectives but the statements of objectives appear to be stronger than the proposed means of implementation or the development of sensible and affordable solutions. The format of the document makes it difficult to analyse the impact of the proposals as many of the ideas are still subject to further detail being published and subsequent public consultation. The success or failure of these initiatives is therefore dependent upon the scale of cost, the burden of regulation and the extent to constraint.

  It is encouraging that the White Paper does not outlaw the use of the car but it does discourage use and will make use more expensive.

  In reviewing the White Paper and its consequent implementation, it is important that certain basic principles are adhered to:

(a)  There needs to be certainty in the measures adopted.

(b)  Within these measures, there needs to be flexibility in their applicability to take account of differing urban and rural conditions and of different localities.

(c)  Authorities mandated to implement the measures should adopt consistency of application.

  3. There is a claim that Government is supported in these measures by popular opinion and that people want more choice of options.

  The White Paper sets out the options; but there remains a credibility gap as to whether many of these options do offer a realistic option for many people. People may not wish to exercise their choice of options if one of the choices were to be deprivation of mobility, particularly if deprivation also resulted in loss of employment and added cost.

  4. Paragraph 1.22 fairly states the primary objectives of an integrated transport policy, namely:

"—  integration within and between different types of transport—so that each contributes its full potential and people can move easily between them;

—  integration with the environment—so that our transport choices support a better environment;

—  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;

—  integration with our policies for education, health and wealth creation—so that transport helps to make a fairer, more inclusive society."

  These are worthy objectives but the question is can they be implemented in a way that maintains economic activity, the improvement of job opportunities, and does not add cost.

  There is an implied fragmentation of responsibility in the management and implementation of policies. This could well result in an under-achievement of objectives.

5. PUBLIC TRANSPORT

  5.1 Paragraph 2.20 states the objectives for a "New Deal for Transport" as follows:

"—  improve reliability for journeys in all modes, helping to support business and economic growth;

—  improve links with international markets;

—  support regeneration and the vitality of urban and rural areas;

—  make more efficient use of the transport system;

—  promote more sustainable UK transport industries."

  Can these objectives be applied?

  5.2 Whilst buses need some priority in coping with traffic, the biggest drawback to bus travel is infrequency of service, unreliable scheduling of timetables and lack of interchange. It is clear that, if Government proposals are to work, there has to be a greater focus upon real service improvements rather than merely improving the flow of information. The general perception of public transport is that the service is frequently poor both in terms of reliability and of safety. Providers must demonstrate the reverse.

  5.3 If there is to be significant growth in the provision of public transport with increased services, can the systems attract the necessary staff to man them to ensure improved services and reliability? Already public transport is subject to cancellation and delay due to shortages of key staff. There will also need to be significant increased investment.

  5.4 In trying to attract more freight to the railways, it is important to remember that 70 per cent of freight trips are for distances of less than 50 kilometres.

  5.5 The proposed Strategic Rail Authority must be given real powers to stimulate new thinking in terms of investment and operations. But they should also be under a duty to consider new routes to embrace new locations and cross-regional routes.

  5.6 The White Paper rightly focuses on the fact that many people use cars for very short journeys and suggests that more people could walk or cycle (Paragraph 2.45). This is a simplistic assumption that overlooks many other travel considerations and factors, principally a lack of good reliable public transport.

  5.7 In summary, the proposals made in the White Paper are full of promises but there is little substance directed to:

(a)  investment in new and better equipment,

(b)  remedying poor timetables and scheduling,

(c)  the consideration of orbital traffic needs, and

(d)  the consideration of reliable, predictable and safe services.

  It must be remembered that all public transport services have to respond to customer need and not to the operators' convenience.

6. TRAFFIC MANAGEMENT

  6.1 The White Paper places great emphasis upon traffic management, particularly Local Traffic Plans which are administered by local authorities. Whilst congestion can be expensive to business, exclusion and limitation of access could be worse.

  6.2 Traffic management schemes when organised by local authorities are likely to respond more to parochial and NIMBY principles whereas in practice they should be governed by sound pragmatic judgements of need based upon properly argued case research which ensures a balance of opportunity and does not necessarily deprive segments of the population of the choices which they find necessary and to which they are accustomed.

  6.3 Where traffic management schemes are prepared by local authorities, there is a risk of isolationist thoughts and a failure to recognise the interdependence of one community on another to assure a co-ordinated flow of people travelling to and from work and to ensure that there is an ability for road users to make cross-route journeys.

  6.4 The design and implementation of traffic management systems will impose a very considerable burden upon local authorities, many of whom are already struggling to fulfil the statutory duties imposed upon them. Not only will the burden be one of skills availability and resource but also one of competence.

  6.5 Traffic management policies are likely to be created without the same degree of scrutiny and accountability that is devoted to other development and planning policies. There may also be a risk that different local authorities will impose differential judgmental standards, thus introducing competitive pressures as between different authorities.

  6.6 The process of challenging the imposition of schemes, independent review and subsequent determination will also lead to delays, uncertainty and cost. There needs to be a clear process of review and perhaps the involvement of emerging regional agencies to harmonise policies as between neighbouring authorities.

  6.7 The White Paper tends to make the simplistic assumption that town centres are almost entirely governed by retail considerations and ignores other employment. The proposals are very much directed towards the problems of major conurbations and relate less to lesser towns and rural needs. But the problem is that all local authorities will seek to apply the principles regardless of the differences that exist across the country and as between differing communities.

  6.8 If licensing the number of car-parking spaces is to be implemented as a means of reduction, where will the surplus cars go? They will be parked indiscriminately on verges, landscaping and in side-streets, all contributing to increased road safety risks and environmental damage. It is better to face reality and accept that the use of good, well laid out parking at the workplace should be maintained.

  6.9 In proposing additional bus lanes, it must be remembered that where they are not necessary or where the roads are too narrow, the dedication of new bus lanes can and will increase congestion on the remaining road surface.

  6.10 There is reference to the need to de-trunk some roads. If this happens, it is important that local authorities should be provided with adequate additional funding to fulfil their future management responsibilities. Furthermore, before such roads are handed over, the trunk road network improvements should be completed. The recent announcements on the roads programme has clarified the future of some of these gaps but many needed improvements have been cancelled.

7. LOCAL ACTION

  7.1 Local authorities are likely to be charged with substantial responsibilities under the White Paper. If they are responsible for drawing up traffic management and transport plans, one has to question:

(a)  Whether they are competent.

(b)  Whether they fairly represent all interests.

(c)  Whether their narrow boundaries lead to a focus which will be disadvantageous to people from wider employment catchment areas, and

(d)  Whether they adopt too parochial an approach.

  7.2 Under Paragraph 4.94, it is arguable that the plans to improve public transport and related traffic management by charging road users to reduce congestion will hit those least able to afford such charges and will be against the interests of rural communities.

  7.3 To impose charges on the use of motorways and other main roads will drive traffic onto less suitable roads.

  7.4 Work-place parking charges will be a tax on jobs and will result in added cost to business. The White paper is ambiguous as to whether or not work-place parking charges will be imposed on all employment-generated parking spaces. Will there be exemptions and, if so, what activities and interests will be exempt, i.e., will government, hospitals, universities, schools, etc., be liable to the same charges? If they are not charged, the logic of reducing congestion will be defeated. If they are charged, who will fund the parking charges?

  7.5 The licensing of parking spaces might well work in town centres but it will not work in edge-of-town locations, many of which are inadequately served by public transport. It will result in hazardous parking by car users on landscaping, verges, side-roads, etc., which will inevitably result in increased road safety risks.

  7.6 These views are reinforced by comments from the AA who said:

"People would simply find somewhere to park in side streets. It is just not a solution. It is also unfair and prejudicial against people in rural areas."

  7.7 It is a tax which is likely to be discriminatory and its consequences could be perverse as it will be a tax on jobs.

  7.8 We are concerned by paragraph 4.76 which seems to suggest that Ministers are seeking to implement their objectives by stealth without the endorsement of legislation properly debated and enacted by Parliament. Interim non-statutory measures may lack the necessary levels of public accountability.

8. PLANNING ISSUES AND LAND USE ISSUES

  8.1 There are a number of references in the White Paper about the need to amend and intensify planning guidance in terms of transportation. It is important that these measures be scrutinised when available to ascertain their relevance to maintaining a level playing-field and to ensure that the changes do not further inhibit good development which is needed to maintain and sustain Britain's economic prosperity and trade competitiveness. It is also important to sustain the maintenance of good job opportunities in a rapidly changing world.

  8.2 We believe that the White Paper's proposals may well be a handicap to the Government's intentions to encourage urban regeneration and the use of brownfield sites.

  8.3 Paragraph 4.175 suggests that there will be a wider use of planning obligations to advance the objectives of integrated transport policies. There should be no extension of the well-established principles of planning gain until there has been a full review of the wider issues of the use and application of planning obligations.

  8.4 It is noted that the DETR will be issuing consultation papers on changes to a number of relevant Planning Policy Guidance notes. We will reserve comment on these until such time as they are published.

9. GENERAL

  9.1 We include as Appendix A[7] a paper on the implication of the White Paper written by Mr Simon Ricketts of S J Berwin and Co, Solicitors. Mr Ricketts is a member of the BCO Planning Legislation Committee. His paper builds upon many of the issues discussed above and raises a number of other points.

Nigel Mobbs

Chairman

BCO Planning Legislation Committee

23 September 1998