INTRODUCTION

  The London Planning Advisory Committee (LPAC) is the Boroughs' statutory planning committee for London. It was set up in 1986 by the Act which abolished the Greater London Council. Its main role is to give Londoners, through their Borough representatives, a say in the overall planning of London. It does this by:

—  advising Government and Boroughs on strategic planning matters and major development proposals;

—  representing London in the regional planning of the South East; and,

—  advising Government on parking policy.

  Over the last decade, LPAC has forged a London-wide consensus on land use and transport policies, and their implementation. LPAC policy is expressed in formal "Advice" to Government and the Boroughs. LPAC's "1994 Advice", based on two years of London-wide participation, is the most authoritative and comprehensive strategy for London's future development, setting out integrated land use, transport and environmental policies. The transport strategy in LPAC's 1994 Advice is built around three inter-related components:

—  Reduce the amount of travel.

—  Restrain traffic, especially the car.

—  Improve public transport.

  This has been developed further since 1994, especially in LPAC's 1996 Integrated Transport Programme for London.

  The proposed Greater London Authority (GLA) will take over the functions of both LPAC and the Government Office for London with regard to strategic planning. As a result, LAPC's experience and expertise will be transferred to the GLA and the Committee abolished.

  The broad structure of this submission was agreed by the full LPAC committee at its meeting held on 22 September 1998.

SUMMARY OF LPAC'S KEY CONCERNS

  LPAC welcomes the Government's Integrated Transport White Paper as a significant policy document which sets out a comprehensive framework for dealing with transport policy in an integrated way and fills the void that had been in existence for a number of years. However, much of what is set out is still rather vague and it is being left to the proposed supporting "daughter" documents to set out the detail.

  LPAC has seven key concerns that it wishes to raise, as follows:

1.  The fact that the need for better land use and transport interaction is not carried through the document.

2.  Whether Regional Planning Conferences will have the resources, skills and necessary government advice to prepare regional transport strategies.

3.  The lack of clear timetable for the necessary legislation to implement road user charging and parking levies, and concern that the parking levies are not being extended to include non-workplace parking.

4.  The failure to recognise the importance of the national rail network to London.

5.  Concern that airports policy is still dominated by a "predict and provide" approach.

6.  Welcome to the Trunk Roads Review and new appraisal approach to major transport investment, but concern about the proposed M25 schemes.

7.  Concern about the lack of a clear indication that the timescale and resources necessary to implement the White Paper's approach will be forthcoming.

  Detailed comments on each of these seven points are set out below.

LAND USE AND TRANSPORT INTERACTION

  LPAC's response to the Government's consultation document, "Developing an Integrated Transport Policy", stressed the need to integrate transport strategy with other areas of public policy and particularly of the need for a fully integrated land use and transport strategy. This is because transport is not an end in itself, but is only an enabler. One of the essential objectives of an integrated transport policy must be to make both development and transport itself more sustainable. To achieve this objective, proper integration of land use and transport planning is a vital pre-requisite of an integrated transport policy.

  Whilst the White Paper talks about the integration of transport with land use (paragraph 1.22) and acknowledges that "land use planning plays a central role in delivering sustainable development, complementing and contributing to the success of other measures such as economic instruments" (paragraph 4.156), this thought is not carried over into the majority of the White Paper, where transport too often appears to be dealt with as a self contained activity and integration sought in terms of transport provision rather than throughout the whole gamut of public policy. Much will need to be done in the proposed revisions to planning policy guidance (PPGs) to deliver true land use and transport integration, and indicate how transport will support wider planning and sustainability objectives. In many ways this is similar to the position on the Greater London Authority (GLA) White Paper which proposes a strong transport executive body (Transport for London) to oversee transport provision in London, but does not really address the need for a holistic approach which brings together land use and transport planning with environmental and regeneration objectives.

REGIONAL TRANSPORT STRATEGIES

  The White Paper continues the welcome recent trend of placing transport planning firmly within the wider planning context, as is evidenced by the Supplement to PPG13 which provided for trunk road proposals to be considered as part of, and in the context of, regional planning advice. In particular, Regional Planning Conferences are to develop regional transport strategies; although it is also to be noted that the guidance on what should be included in those strategies is purely in terms of transport rather than what transport can contribute to the achievement of wider planning objectives. These regional transport strategies should then set a context for both the transport aspects of development plans and the new Local Transport Plans, and for decisions on major investment proposals, including trunk road schemes.

  The White Paper, in keeping with the Government's intention of giving greater political status to the regions, places considerable responsibilities on the Regional Planning Conferences. It fails to recognise, however, that, judging from the experience of the South East, the Conferences do not necessarily have the authority (from and with) their constituent membership or the financial, technical and administrative resources to assess, formulate, present and deliver a comprehensive transport strategy. Regional Planning Conferences will also need clear guidance on how to carry out these new responsibilities, including advice from Government on the methodologies necessary to assess public transport accessibility and determine regional transport priorities. As a result, further consideration of their role must include options that address these issues so that Regional Planning Conferences are put on a much firmer footing.

ROAD USER CHARGES AND PARKING LEVIES

  LPAC has long recognised the need for mechanisms to manage demand (the "sticks") as well as those which promote alternatives to the car (the "carrots") and, hence, welcomes the proposals for powers for local authorities to charge road users and/or set levies for workplace parking. These will also have the added benefit of raising additional finance to improve alternatives to the car. However, LPAC is concerned that no clear timetable is set out for the necessary legislation for this or for the Strategic Rail Authority. In London, these powers will be vested in the Greater London Authority (GLA) and it is essential that they are available in time for its expected inception in April 2000.

  LPAC is also concerned that non-workplace parking (i.e., for customers and visitors to retail and leisure facilities, hospitals, schools, etc.) appears to have been excluded from the parking levy legislation. These types of trip are the ones experiencing most growth and dispersal, and are also the types of trip where the provision of large out-of-centre car parks has encouraged increasing car dependency. Whilst new developments can be guided to more appropriate "central" locations that can also be well served by walking, cycling and public transport and more restrictive parking standards can also be used to reduce car dependence, there is much existing development that is unsustainable and whose travel patterns needs to be influenced. As such, the parking levy legislation should be drawn as widely as possible to allow the inclusion of non-workplace parking so that the GLA is able to consider whether such measures are required in London as part of the development of an integrated land use and transport strategy early in 2000.

THE IMPORTANCE OF THE NATIONAL RAIL NETWORK TO LONDON

  LPAC's main concern about the current organisation of the rail industry (expressed in "An Integrated Transport Programme for London?", 1996) is that the decision making process in respect of infrastructure investment and service provision no longer takes account of planning and the wider objectives of public policy—something that is essential to achieve integration in its broadest sense. This concern is heightened by the Integrated Transport White Paper which presents rail only in terms of its national function. In London, rail is not only a vital part of the regional transport system, bringing people into London to work, shop and for leisure purposes, it is also part of local transport with over half of all rail journeys starting and finishing in London. For example, local passenger services like those on the North and South London Lines and the Gospel Oak/Barking Line provide the most effective means of orbital public transport travel in the areas of London they serve.

  In order to rectify the situation, the new Strategic Rail Authority (SRA) should have a statutory duty to take account of planning policy and considerations. Investment in the national road network is being increasingly put in the context of regional planning and so should investment in the national rail network. If local government, at regional and local level, is given the responsibility of formulating transport strategies, it must be given the means of influencing those whose actions will play a major part in determining whether those strategies are implemented. The White Paper talks of the SRA working "closely with local and national organisations, including local authorities, Regional Planning Conferences, Regional Development Agencies, . . . " (paragraph 4.14). How this should be done must be spelt out clearly. In London, the Greater London Authority (GLA) must have a clearly defined and real influence with the SRA, and through it with Railtrack and the train operating companies. The GLA must have a real say in investment decisions and service provision, the latter including a role in the negotiation and determination of franchises. Without this, the GLA will not be able to deliver an integrated transport strategy for London.

AIRPORTS POLICY

  The White Paper's commitment to the preparation of a UK Airports Policy looking some 30 years ahead is welcome. LPAC has long advocated the formulation of such a long term, national aviation strategy. For too long the planning of airport capacity (both terminal and runway) has been subject to decisions based on short term expediency. The implementation of a long term strategy will allow its integration with surface access proposals, regional development strategies and the broader objectives to be achieved from transport's integration with other areas of public policy. The recognition of London's airports as one system is welcome. This should lead to a lessening of the over emphasis often given to Heathrow which leads to transport, environment and development impacts which are counter to broader planning objectives.

  However, it is disappointing that the White Paper makes no reference to moving away from the "predict and provide" approach which has now been applied to the provision for air travel for many years. In other areas, notably the highway programme, where the increasing demand for travel has had impacts that are unacceptable in both environmental and economic terms, this principle has been abandoned. The White Paper's emphasis on regional airports and surface access considerations are welcome, but they alone will not be sufficient to ensure that airport policy contributes towards sustainability rather than working against it.

THE TRUNK ROADS REVIEW

  The outcome of this review, which is a related document to the White Paper, is broadly welcome. It continues the trend of placing highway investment decision making within the context of regional planning policy and regional development. Particularly welcome is the new appraisal framework. Not only does this allow a wider range of consequences to be taken into account, and increasingly for those factors to be quantified, when assessing proposals, but it provides an assessment framework which is intended to be applied across modes. This was something LPAC's "1996 Integrated Transport Programme for London?" considered was essential to gain best value for money from investment in transport and to ensure that that investment was contributing as fully as possible to wider planning and sustainability objectives.

  Whilst the Trunk Roads Review generally seems to be in keeping with the White Paper and its objectives, the decision to go ahead with the further widening of the M25 between junctions 12 and 15 is more of a throw back to the previous approach. Here, the Government's approach seems to be that the conditions for road traffic are so critical over this section of the M25, that it cannot wait for the kinds of approaches being taken elsewhere in the review to have effect because of the time they take. This is to reject the solutions being put forward elsewhere in the roads review because, in this case, they are not considered to be effective enough. This does not foster confidence in the new approach in those areas where it is to be applied, where undoubtedly some people will see the problems they face as being just as great as those on this section of the M25. Here, an integrated approach is not being taken to the solution of a transport problem and, since a significant proportion of the traffic on the M25 over this section is related to Heathrow Airport, this also seems to indicate that an integrated approach is not being taken to the issue of airport development and the surface access requirements it generates.

TIMESCALE AND RESOURCES

  In policy terms the White Paper sets out the intention of making considerable change, with much of the detail of how that change is to be effected to follow in forthcoming, complementary publications from government. What the White Paper fails to give an indication of is the timescale it anticipates for its policies, and different parts of those policies, to be implemented. Many of the policy changes need to be backed by legislation and/or changes to planning policy guidance which together will form the broad national framework within which policies will be implemented at the local level. Local authorities, and other interested parties such as business and providers in the rail industry, need an outline programme as to what is expected of them by what date and what powers are going to be available to them to achieve it. As important as the knowing what the framework and mechanisms for policy implementation will be, is to know what resources will be available. This is particularly so in local government which is increasingly taking on board responsibilities from Central Government for transport and related matters, e.g., the provisions of the 1995 Environment Act in respect of air quality, and the requirements of the 1997 and 1998 Road Traffic Reduction Acts, without any indication of additional sources of funding. LPAC's advisory 1996 Integrated Transport Programme for London sets out a broad indication of the level of resources needed in London.

  In London, the need for these timescale and resource issues to be dealt with quickly is acute. The Greater London Authority (GLA) is expected to come into effect in April 2000. Much is expected of it, including the preparation of an Integrated Transport Strategy, which will be the main instrument of pursing many of the policies sought in the White Paper, to be delivered largely via a new, multi-modal transport agency, Transport for London. The need for the new Mayor for London and the GLA to have, from the outset, the power to introduce congestion charging and charges for private non-residential parking space is referred to above, but more generally, the rest of the implementation framework, including the resources that will be available, needs determining quickly. As such, a firm timescale for the implementation of the White Paper's proposals is urgently needed.

CONCLUSIONS

  LPAC welcomes the Integrated Transport White Paper and believes that it provides a firm basis on which to develop an integrated transport policy. Our main concern is that it is still weak on the link between land use and transport planning. We are also concerned about the lack of detail on how the approach will actually be implemented and the lack of a clear timetable for the urgently needed legislation.

23 September 1998