SUMMARY

  Whilst generally welcoming the Integrated Transport White Paper the RSPB has a number of serious concerns on specific issues relating to the conservation of biodiversity that the White Paper does not fully address. These concerns are as follows:

—  One-quarter of the UK's greenhouse gas emissions are transport-related and the transport sector is by far the fastest growing emission sector. Significant climate change caused by anthropogenic emissions of greenhouse gases is likely to severely damage biodiversity leading, in some cases, to species extinction. The White Paper recognises these facts but does not adequately address the question of how to reduce transport-related emissions. Neither do the "daughter" papers issued so far.

—  One of the cornerstones of the integrated transport policy described in the White Paper is the devolution of a considerable amount of decision-making to local and regional authorities. Although devolution may have many benefits it is likely to make achieving quantitative international and national targets more difficult, especially those concerning greenhouse gas and acid rain precursor emission reductions. The Paper does not adequately address the question of how to co-ordinate local actions so as to achieve national and international targets.

—  The White Paper contains comparatively little detail on air, sea and inland waterway transport. Whilst appreciating that road and rail networks needed urgent consideration, that daughter papers on the other subjects are to be anticipated and that international sea and air travel is largely governed by international agreement, there are a number of wildlife-related issues in these areas that need to be addressed, some as a logical consequence of having an integrated transport policy. The RSPB is especially concerned about increased air travel and the rapid growth of greenhouse gas emissions resulting from this increase.

—  The White Paper states that there will be a strong presumption against transport schemes being approved in cases where they could significantly (and adversely) affect biodiversity. The RSPB welcomes this presumption but concerned that it is apparently watered down, or even contradicted, by statements in subsequent daughter papers on road appraisal.

1. Introduction

  The RSPB welcomes the opportunity to contribute to this inquiry. The White Paper represents a significant step away from the unsustainable "predict and provide" policy on roads and towards a more environmentally benign policy based on a mix of transport modes, including cycling and walking.

  However, the RSPB has a number of reservations about specific aspects of the new policy, the more significant of which are outlined here. In particular, the RSPB considers that the White Paper and its "daughter papers" do not adequately address the problem of climate change and the damage that this will do to wildlife.

  This submission first outlines the RSPB's general concerns about transport policy and its effects on biodiversity (Section 2). There then follow sections on specific concerns about the devolution of decision-making (3.1), transport by air, sea and inland waterways (3.2), the new appraisal system (3.3) and the use of economic instruments (3.4).

2. The RSBP's concerns about transport

  The RSPB is concerned about transport policy because of the damage that transport systems can, and usually do, cause to wildlife and their habitat. This damage has two main causes.

  The first cause is the construction and use of transport facilities such as roads, ports and airports. Whilst digging habitat up and burying it under concrete or tarmac is obviously destructive, it is often the routine use of constructed facilities that is more damaging in the long term. For example, local air pollution can harm flora and fauna at a considerable distance from roads. The same is true of noise. RSPB studies indicate that many birds species, including the rare bitterns and stone curlews, are apparently very sensitive to traffic noise and will not nest anywhere near motorways. Mitigation measures such as creating nature reserves in the margins of roads are thus laudable in their intent but often limited in their effectiveness.

  The second cause of damage to biodiversity is more insidious and derives indirectly from burning fossil fuels and, indeed, some other forms of burning. Of particular concern in terms of their impacts on wildlife are the greenhouse gas emissions that lead to climate change and the emissions that lead to acid rain. Acid rain, for example, tends to destroy heather and hence the wildlife that lives upon it.

  All forms of transport that use fossil fuels emit greenhouse gases and usually acid rain precursors. The transport sector, especially road and air, currently accounts for about a quarter of UK greenhouse gas emissions. Both the sector and emissions from it are growing rapidly whilst emissions from the other main sectors are more or less stable or declining. Any strategy to mitigate climate change must therefore not just curtail emissions from transport but cut them.

  Climate change caused by greenhouse gases already appears to have had adverse effects on species far from the UK such as the Adelie penguin and the keel-billed toucan. At home, according to the recent review of the potential effects of climate change in the UK (prepared for the Department of the Environment in 1996), a one degree Celsius increase in temperature may significantly alter the species composition in about half of the statutory protected areas in the UK.

  Given that the same document anticipates that, on average, the UK will be 0.9 of a degree warmer by the 2020s than the average for the years 1961 to 1990, and 1.6 of a degree warmer by the 2050s, the prospects for wildlife do not look good, even assuming complete compliance with the Kyoto Protocol by all nations which will, by itself, do almost nothing to limit climate change; it is merely a first step.

  A common misconception is that wildlife and their habitat will simply move north as climate change occurs. This is extremely unlikely for many species. Not only is the rate of northward shift of climate in the UK likely to be too fast for some species (averaging about 5 to 8 km per year SE to NW) but a significant number of birds and animals are dependent on habitat that cannot move from place to place, if only for reasons of geology. The chalk downland habitat of parts of southern England will not simply travel north along "safe corridors", settling down temporarily in the sandstone regions of Yorkshire and the granite-based areas of the Highlands. The same is true of much waterfowl habitat in the related context of sea level rise. Many species thus face extinction.

  It is in the context of these concerns that the RSPB makes this submission. The Transport White Paper and its "daughter papers" published so far herald a welcome change in the direction of thinking about transport. They recognise all of the RSPB's main concerns in principle but they often either do not go far enough in addressing them or are too vague. Above all, the Government needs to grasp the nettle of how to cut transport-related greenhouse gas emissions hard, and soon. The White Paper merely aims to "reduce road traffic growth".

3.1 Regional and local planning

  Both the Integrated Transport White Paper and Review of Trunk Roads lay great store by local and regional plans for transport. Many more decisions concerning roads will in future be made at the sub-national level.

  The RSPB welcomes the devolution of decisions to regional and local levels. However, it is disappointing that the White Paper does not provide more detail on how this will be implemented. The revised PPG13 on transport and PPG11 on Regional Planning Guidance must provide more detailed guidance for local authorities and Regional Planning Conferences (RPCs). In particular, this guidance should specify that local authorities and RPCs should carry out a Strategic Environmental Assessment (SEA) of their transport strategies. The Government is committed to SEA as a tool to help integrated environmental considerations into decision-making, and this should be reflected in the guidance.

  The guidance should also require local authorities and RPCs to set indicators and targets in their transport strategies, including on biodiversity. In particular, they should set out how they will contribute to international and national targets such as emission reduction targets for greenhouse gases and acid rain precursors. This is important to ensure that the Government can deliver the emission reductions that the UK is legally obliged to make under international agreements such as the UN Framework Convention on Climate Change and its Kyoto Protocol (and the EU Council decision on burden sharing) and the Protocols to the UN ECE agreement on Long Range Transboundary Air Pollution (LRTAP). The role of the Secretary of State in finally approving RPG will be critical to ensure that these requirements are implemented consistently between regions.

  We welcome the criteria approach to decision-making at the regional level/(paragraph 4.53). These should be wider sustainability criteria, including biodiversity. In particular, we believe that there should be a cut off for decisions, where significant adverse impacts on biodiversity interests are likely, so that those proposals are automatically ruled out (see our comments on Appraisals in section 3.3). Government must also ensure that RPCs that they will be pressured by local authorities to include such projects.

  Whilst the devolution of decision-making is welcome, we remain concerned that local authorities and RPCs will require additional resourcing in order to carry out these increased responsibilities satisfactorily. We believe that the Government should address these resourcing issues as a matter of urgency, if its objectives for integrated transport and regional planning are to be met.

  We recognise the important role of the Regional Development Agencies in influencing the development of integrated transport strategies (paragraph 4.58). We are concerned however, that the guidance on the relationship between the RDAs' Regional Economical Strategies (RES), RPG and regional transport strategies is not stronger. In particular, we believe that the RDAs should work within the context of RPG, and help to deliver the objectives of RPG. Without this, there is a danger that the economic development and infrastructure needs in the RES could cut across or conflict with RPG objectives. We have proposed a Regional Sustainability Strategy for each region, to help integrate the different strategies for the regions, and to avoid potential conflicts or duplication of effort. We also suggest that the RDAs should adopt the sustainability criteria in RPG for new development as suggested above.

3.2 Air, sea and inland waterways

  The RSPB is concerned that the White Paper goes into comparatively little detail on air, sea and inland waterway transport. Whilst the RSPB appreciates that road and rail networks needed urgent consideration, that daughter papers are to be anticipated and that international sea and air travel is largely governed by international rules and guidelines, there a number of wildlife-related issues in these areas that need to be addressed, some as a logical consequence of having an integrated transport policy.

  The first of these issues is, again, how to cut emissions and the second concerns direct impacts. The key area in terms of emissions is air transport which is growing fast and is thus an area of considerable concern, especially as the "bunker fuels" used for international air (and sea) transport are not counted into national greenhouses gas inventories and hence emission reduction targets. Also, bunker fuels are duty free and this encourages rather then discourages their use.

  Successive UK Governments have a good record in trying to get bunker fuel emissions attributed equitably and the RSPB is encouraged to see that the White Paper expresses a commitment to continuing to press for tighter worldwide standards on emissions, the potential application of worldwide environmental levies and lifting the tax exemption on aviation fuels, either via ICAO or outside it. However, if significant emission reductions are to be achieved, especially in the case of greenhouse gases, the projected increase aviation related emissions needs to be curtailed, or rather cut, soon. The White Paper does not really address this issue other than, by implication, via the possible application of fuel taxes.

  As in the case of road transport, cutting emissions significantly will be hard to achieve politically, at both the domestic and international levels. Nevertheless, there are, at least initially, a number of potential win-win options that the Government could pursue as part of an integrated transport policy. Notable amongst these is to encourage less air and more rail travel, both within the UK and via the Channel Tunnel rail link to Europe.

  Increased air travel also, of course, tends to imply providing more or bigger airports, or both, and the means of travelling to and from them by road or rail. This is likely to mean more direct impacts on wildlife habitat and certainly means more emissions from ground based vehicles. The RSPB thus welcomes the intent expressed in the White Paper to make more efficient use of existing airports and to provide improved public transport access to them.

  The same concerns about damage to biodiversity apply to the greater use of ports and inland waterways proposed in outline by the White paper. Whilst welcome in terms of the overall transport-related emission reductions that waterborne transport can offer, its development may pose severe problems for wildlife, especially in terms of loss of birdlife habitat, unless improved appraisal guidelines are employed. (The next section thus deals with this topic in more detail.)

  Generally, however, the RSPB welcomes the intent expressed in the White Paper to make greater use of shipping of all types, coupled with the tightening up of controls on waterborne discharges. Indeed, we feel that the Paper might have gone further than it does in terms of the volume of freight that it envisages being transferred from road to water.

3.3 Appraisal

  The RSPB is pleased to see that the White Paper clearly states that " . . . there will be a strong presumption against new or expanded transport infrastructure which would significantly affect such [environmentally sensitive areas or] sites or important species, habitats or landscapes." However, the Society is less enthusiastic about some of the more detailed guidance on appraisals given in the allied, daughter documents on the trunk roads review: "Guidance on the New Approach to Appraisal" and "Understanding the New Approach to Appraisal".

  In particular, having developed a basically sound set of appraisal criteria, it seems a pity to state that "it is for decision makers to make judgments about the relative value to be put on the individual criteria" (in Understanding the New Approach). This would seem to leave it open to the new devolved decision makers to ignore the aforementioned strong presumption against site of special national or international importance. Similarly contradictory comments appear in the Guidance on the New Approach to Appraisal.

  It is hard to envisage any circumstances which would justify a local or regional authority authorising a new transport facility (or substantially amending an old one) that would damage a site protected by an international treaty or, indeed, by national legislation. It is thus essential that the "strong presumption" clause in the White Paper is systematically observed, or strengthened to an imperative, throughout any daughter papers concerning the appraisal of any mode of transport.

  Despite these reservations, the new appraisal framework represents an improvement on the previous approach. In particular, there is less emphasis on the monetary valuation of costs and benefits, and clearer presentation of impacts (such as biodiversity impacts) which cannot be expressed in money terms. However, the relationship between the summarised results for each road scheme and ministerial decisions is still far from clear. More explanation of the reasons for particular decisions would be helpful. Also there is a need for more consultation (in advance of decisions) on the scores for each criteria—the latest scores involved no external (non-Governmental) consultation.

  The RSPB supports the plans to apply the new approach to all forms of transport—to establish a "level playing field" between different modes (see paragraph 1.13 of the Guidance).

3.4 Economic instruments

  The RSPB agrees that economic instruments are an important way of influencing travel choice (paragraph 4.118). We particularly welcome the reduced vehicle excise duty for cleaner cars. (We developed detailed reform proposals on this with the Institute for European Environmental Policy in 1996.) However it is disappointing that the White Paper does not include any commitment to reform of the company car tax system—it merely refers to an on-going Inland Revenue review.

Transport, Energy and Climate Change Policy Officer

September 1998