The Official Response of
The Association of British Drivers
to the DETR's October 1998 consultation
“Breaking the Logjam”

1999 March 29


What is the Association of British Drivers?
The Association of British Drivers (ABD) was founded in 1992, by a group of drivers from across the country and from all walks of life who had become concerned that the case for the motor-car was no longer being put effectively in this country. It was felt that the AA and RAC, with their growing insurance businesses, were no longer fulfilling their traditional role, and that the time was right to set up an organisation solely dedicated to representing the interests of all car users — from ordinary motorists who rely on their car for every day mobility to enthusiasts. The case for the motor-car is, in our view, so obvious that it is in danger of going by default.

How the UK benefits from the Motor-Car
UK motorists contribute close to £32 Billion per annum to the Exchequer, but transport spending currently amounts to a paltry £6 Billion. This represents a very substantial income for the Treasury.

Policy makers will be aware that 2.3 million people and their families are directly dependent on the wider motor industry in the UK for their employment and incomes. The car industry is one the UK's leading manufacturing industries, one that continues to expand at a time of considerable difficulties for engineering based businesses in this country, and at a time of considerable worldwide economic uncertainty. Truly a success story, the British motor industry continues to receive investments of Billions of Pounds from major world motor manufacturers from the US, Japan, Germany, and France. The car industry has become a major export earner for the UK. But the industry needs a healthy home market if it is to continue to thrive.

The car has been the greatest liberator of all time — giving a degree of freedom and mobility that our great grandparents could only have dreamed of. As car ownership has risen, it has torn down social and geographical barriers, liberated women from the drudgery of shopping daily, enabled families and friends to remain in close contact even when they live miles apart, and made it possible for employers and employees to have access to a much wider market.

The ABD — Britain's leading drivers' group
The ABD has taken part in several Consultation exercises in the past, having submitted, inter alia, responses to the Air Quality Strategy, Integrated Transport, Trunk Roads, Highway Code Consultation Documents and the UK Climate Change Programme. The ABD has been widely quoted in national and local newspapers, motoring publications, as well as appearing on BBC and independent radio and TV broadcasts. Our membership is rising across the country.

The ABD is also represented on the Parliamentary Advisory Council on Transport Safety (PACTS).

The ABD is entirely independent and is funded by subscription.

The ABD's Response

The ABD is alarmed to see from the consultation document that the Government appears already to have decided to bring in legislation allowing new charges to be introduced for road use and for parking. Such intentions are surely premature since the Government has yet to receive the views of the many interested parties on this consultation paper.

We see from the text of the document that the Government recognises the strength of opposition to these proposals (clause 2.7). Unfortunately, no indication is given of the proportion of consultation document responses actually opposed such taxation, but we infer that this must have been significant, even if you believe that "opposition is declining".

Whatever the eventual decisions are, it is clear that a great deal more genuine consultation with the public (particularly road hauliers, business and car users both private and commercial) is essential before any decisions can be made on a controversial issue with far reaching implications such as this.

The public must be allowed to voice their concerns on an issue such as this properly and in person before any decision is made as to whether it would be right to proceed. The Public Enquiry for the proposed Terminal Five at Heathrow ran into years to ensure that all concerned could give their views, yet that is a minor project in terms of effects on people and their lifestyles compared to the tolling and tax proposals contained within this document. It would be wholly inconsistent if at least an equal chance was not given to all interested parties over the Government's taxation proposals for motorists.

Some issues, such as tolling of motorways have profound implications in terms of road safety and traffic diversion which have not been addressed properly. Indeed the issue of motorway tolling is currently under consideration by the Parliamentary Advisory Council on Transport Safety. Their deliberations are on-going, and it would be wrong to take this matter further until they have reported fully.

The ABD's Views

The Government will be aware that the ABD has consistently opposed the introduction of additional road-user charging.

The British motorist is now not only paying his and her way, but contributing a large surplus to the Treasury, and even the docile British are just beginning to react to the growing tax burden. The AA recently ran a high profile campaign distributing leaflets advising motorists of the fact that £8 out of every £10 spent on petrol is tax, and the truck drivers have become the first group to commence direct action over the level of road user taxation in the UK.

In truth, we all have an interest in building a fast, world class transport system, in order to ensure quick and cheap delivery of goods and rapid mobility for business people, commuters and other travellers. The UK has been slow to develop its infrastructure during the Twentieth Century, leaving us with the worst developed and maintained road system in the industrialised world, the worst and most expensive public transport system in western Europe, and a railway system that is rapidly falling behind as competitor countries construct new dedicated high speed rail links.

It is time that more of the tax revenue received from motorists was invested in quality transport infrastructure: including more and better roads, better public transport, and new and better rail links (involving the construction of wholly new high speed lines as well as upgrading existing facilities).


The Government's Proposals — A Breach of Promise

The British public are pretty used to breaches of promise by Governments:-

No Justification for the New Taxes and Tolls

The Consultation document seeks to justify the tax and toll proposals on three basic issues:-  

Taking the issues in turn:-

1. Pollution
The Government is well aware that levels of pollution from road traffic, particularly cars is falling. Pollution peaked in about 1990, and according to the latest figures has fallen by over one quarter during this decade.

The Royal Commission Report on Transport and the Environment (appendix B), published in 1984, predicted that emissions of all pollutants from road traffic would fall by approximately 75% by 2005- 2010, largely as a result of the introduction of catalytic converters on petrol driven cars since 1993, and other technical improvements. The Report made it clear that these improvements will occur even if traffic levels were to continue to rise at the highest projected rate.

New EU legislation passed since the Report was published will ensure that air quality will continue to improve beyond 2010.

The latest evidence suggests that it is in fact diesel powered vehicles, particularly buses, taxis and public service vehicles, that are causing the greatest pollution problems in urban areas. The ABD wants to see the quality or our air improved, and has long campaigned for:

Much is made both in the Consultation Document and in the media generally of the numbers of people alleged to die prematurely as a result of poor air quality. It is grossly unfair to blame car users for this. The allegations relate to:-

(A) People with breathing disorders such as asthma — yet it is now known that there is no link between asthma and air pollution. Indeed, the world's highest rate of asthma is in New Zealand, a country renowned for its clean air. People with existing breathing disorders can suffer as a result of Particulates, emitted by diesel engined vehicles; and allegedly from ground level ozone — which is found in the highest concentrations in rural areas well away from urban traffic.

(B) Cancer causing agents — Particulates (a diesel by-product as previously mentioned) are known to be cancer causing. It is thus ironic that local authorities like Oxford, who have excluded cars from the city centre on a largely spurious air quality grounds, suffer severe air pollution as a result of the numbers of diesel powered buses which choke the central shopping streets with Particulate-bearing emissions. Benzene and Butadiene are also cancer causing, but do not normally escape during driving. As previously stated, we would like to see all filling stations fitted with vapour recovery systems as in California.

It is important to note that the only pollutant that has been proven to be harmful to human health at normal concentrations are Particulates.

2. Congestion
Congestion has arisen largely as result of decades of underinvestment in transport — both public and private — by Governments of all colours. The ABD believes that it is wrong to single out car users for blame. Britain has the worst traffic congestion in Europe after Poland, despite having an unacceptably low level of car ownership. This needs to be tackled, but not by imposing damaging new taxes on vehicle users. It is beyond the scope of this document to detail all the measures which we believe should be taken, but we list some examples below:-
(A) Roads
The Government must recognise that free choice must remain paramount, and ensure that adequate roads are provided. Britain's road infrastructure is inadequate compared to that in most countries. The road system needs to be expanded, as a matter of urgency. In London, the London Expressways scheme of proposed underground motorways could present a unique opportunity to allow free movement of traffic and at the same time allow for less congestion on the surface;

(B) Public Transport
Investment in good quality public transport should be geared to provide for journeys that can best be undertaken by that method. These are primarily along routes where a large number of people want to travel from one same place (such as a residential area) to another same place (such as a city centre) at the same time (such as morning and evening rush hours). It is a myth that this will ever comprise a high percentage of journeys because many people's travel requirements are not so simple.

Many aspects of the public transport system are unsatisfactory. London still has not fulfilled the Cross Rail project, and with a few minor exceptions, the Underground network would be recognisable to anyone stepping straight out of the 1930s. It is hardly surprising that the system is creaking under the strain of commuter traffic.

Good public transport will cost a great deal of money, will involve far more regular services than have been the case in the past, and levels of comfort need to be improved. Air conditioning, now common in cars, is still considered a luxury in buses and trains, and too many passengers are unable to find a seat. This is not acceptable.

(C) Planning
Congestion can also be tackled by de-centralisation — a successful policy followed in the UK since the beginning of the Century, with the Garden City movement. This has succeeded in taking millions of workers and their families out of grim 19th Century urban slum areas to green suburbs. Modern cities such as Milton Keynes have thus avoided the problems of congestion, whilst offering very high levels of quality of life to its residents.

The result is that private gardens now cover an area the size of Leicestershire and are acknowledged not only to provide a pleasant living environment for the humans, but also a habitat for a wide variety of plant and animal life.

The ABD finds it regrettable that the present Government appears to have forgotten the lessons of history over urban planning, by reverting to a 19th Century policy of encouraging urban cramming.

3. Provision of Revenue
Neither road tolling nor work space parking taxes represent an efficient means of raising revenue. Both will require extensive resources to impose and administer, especially any form of electronic road tolling. Both will be deeply unpopular, both will therefore require considerable efforts to enforce them. We have highlighted some of the potential problems below.

The ABD believes that it is high time that more of the enormous revenue already received from road users was re-invested in all types of transport, public and private, passenger and freight.

The fact is that the fuel duties levied by the Government already bring in over £20 Billion per year, yet cost little to collect, virtually nothing to enforce, and until now at least, have largely been accepted by the public. Whilst in no way accepting the case for further fuel duty rises, it does at least represent a cheap and efficient way of raising revenue.

The cost of setting up and administering these taxes, charges and tolls has been estimated at many billions of pounds. This will all be wasted money, from which society will derive no benefit. We want to see that money spent on REAL improvements to our transport system.

Serious Disadvantages with the Government's Proposals

Not only do we not accept the Government's reasons for pushing ahead with the proposals, we also consider that there are a number of serious problems and disadvantages that have yet to be addressed:-

Work Place / Commuter Parking Taxes
Surveys have shown that a car parking space at work is more highly prized than any other benefit — more so than shops nearby or air-conditioning. Employers will be reluctant to reduce spaces, a step which would alienate staff. The taxes will be paid, but at a cost to business competitiveness and jobs. Research in Germany has also shown that civil servants who commute to work by car were less prone to absenteeism than those who travel by other means.

Many staff live in places where there is no adequate public transport link, and often some distance from their places of work. Working mothers and fathers often have to combine commuter trips with taking children to and from school — and car travel is the only practical way of doing both in one seamless operation. They would be unfairly prejudiced if driving to work became too expensive or difficult.

Severe difficulties will be experienced in determining which spaces are to be subject to the new tax, and which are not. If charges are set at a high level, this will lead to a whole new area of tax planning, avoidance, evasion, controls and enforcement. There will inevitably be considerable expensive litigation on this subject, tying up local authority legal departments, and using up resources. It will be difficult to differentiate between different types of space. There will, in effect, be no sure way of deciding which spaces are for visitors/customers and which are used by staff, especially as this will change not only from day to day, but from hour to hour. Some workers will no doubt evade the rules by parking in one shoppers' car park for the morning and move the car to another for the afternoon.

Shift workers and those who have to work long or anti-social hours would be prejudiced due to the lack of regular public transport outside normal working hours. This will be especially so for women, or for those who have to travel through inner- city areas, who may not want to use public transport late at night for reasons of personal safety, even if it is available.

Many industrial areas, retail and business parks are well away from town centres, and in areas where there is little or no public transport, and in many cases never will be. The workforce at such places often comes from far and wide — anywhere within a one hour drive time. Employers have invested in such sites in good faith, and they cannot now be wished away, even if Government policy would not now allow them to built new. Industrial sites even now are likely to be well away from town centres. Their employees need to be able to drive to work and park their cars there.

A large number of employees may need to use their cars on regular or irregular basis. Provision will need to be made for them. The taxation proposals would hit them unfairly.

Towns that introduce parking taxes are likely to be at a disadvantage as against those that do not. That is in one sense healthy, since competition will ensure that in the end the most popular and successful system would win, but at a massive cost to the businesses situate in areas subject to the tax.

Such a tax is sure to receive very stiff opposition in rural areas and smaller towns particularly, where they will be seen as unwanted and unwarranted interference in local affairs. There is scope for serious conflicts to arise between employers, staff, local authorities and even between neighbouring local authorities over such taxation policies.

Taxes on long term parking at railway stations would of course lead to many people who currently switch to cars for the whole of their journey. This would be regrettable since the "Parkway" Station has been a major success for integrated transport in the UK for 25 years, especially in the congested south east.

Road Tolls — Motorway
This is a dangerous policy, because motorways were designed and built to take traffic off less suitable roads. There is no doubt that there will be considerable diversion to less suitable roads, with increased traffic levels experienced in towns and villages who have enjoyed decades of peace and quiet.

Motorways are our safest roads, so there would be bound to be an increase in fatalities as a result of motorway tolls. This matter caused so much concern when previously considered that the House of Commons Transport Committee Report on "Charging for the Use of Motorways" (published July 1994) concluded:-

"It should be the aim of policy to ensure that as much traffic as possible , particularly goods traffic, uses the motorway system" (para 175)

"..until the Government can demonstrate clearly how it proposes to deal with the question of diversion, the tolling of motorways should not go ahead" (para 184)

and.. "Taking all the relevant factors into account, we believe the Government will have to provide a great deal more information before Parliament and the public can be persuaded that the [Green Paper's] proposals for electronic tolling are either desirable or workable" (para 196) There is no international correlation between motorway speed limits and casualties, but ALL countries that impose motorway tolls suffer more casualties than those that do not. (ABD research )

PACTS is currently considering this issue from a road safety point of view.

The other major objection is that it will inevitably have to be an electronic system, which will cost Billions of Pounds to introduce, administer and enforce, probably in the face of considerable public adversity. Since it seems unlikely that the Government would spend the money to install in-car decoders, motorists would have to purchase these: a major disadvantage especially for the less well off, for those who only use the motorway network occasionally and for the growing number if foreign registered vehicles on our roads. Many less well off motorists, especially pensioners, rely and enjoy their cars, and there has to a great danger that they will be priced off the road, leading to more, not less, social exclusion.

We remain deeply concerned at the civil liberties implications of a system that can track all movements. Civil liberties groups have been surprisingly quiet, on this but it is dangerous in the long term for the state to possess such detailed information about the whereabouts of all citizens on a routine basis.

Motorway tolling will be deeply unpopular across the country, and there will be a heavy political price to be paid by the Government that adopts it.

Urban Road Tolls
Serious problems will be faced by long distance travellers if faced by any system other than a congestion-causing toll booth. With both electronic schemes, and permit cards, tourists, business people and visitors will be faced with strange and probably incompatible schemes as they travel from one area of the country to another imposing a serious brake on mobility, and considerable inconvenience. Areas that adopt such schemes are likely to be avoided by many who will find the schemes too complex or expensive.

Towns are likely to be severely distorted by the position of gates to tolled areas, with much increased traffic, trade and congestion outside of the toll cordons, and economic damage to those within it. Considerable planning pressures are likely to build up in those areas, despite new planning guidelines. Town centres are likely to suffer badly unless shoppers are exempted from any charge.

Experience with tolling in Oslo suggests that commuters tend to pay the charges, but shoppers are deterred from entering the central area.

Again there will be very considerable local resistance to such schemes, which may lead even to civil disobedience at the extreme. In any event, administration and enforcement will be very expensive, and take up a lot of local resources.

All these new taxes will be inflationary and take money out of the productive economy. They will be discriminatory, and the proposals as they stand seem to offer no protection against unscrupulous local authorities, as there is no statutory ceiling on the amount that can be charged.

The charges will inevitably cause endless anomalies, causing great social injustice. Many families in particular will be forced to make very detrimental changes to their way of life when coming to terms with a new, unresponsive and hostile transport regime.

Importance of Proper Local Consultation
We believe that, before any local authority should be allowed to present any scheme for approval to the Ministry it should first have been the subject of a full and impartial study, then of local debate, and should then face approval at a local referendum. Because of the nature of the proposal, and possible effects, approval should only be given if approved by a majority of all those in the locality who are eligible to vote. This is to ensure that there is real local backing and would ensure democratic legitimacy to the scheme.

There is a danger that the debate will otherwise be hijacked by a small, organised but unrepresentative minority, who may not be aware of, or concerned, about the full effects.


We would welcome further involvement in this consultation.

This response may be published or quoted.

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