|23 June 2005
Senior Transportation Planner
Essex County Council
Draft Local Transport Plan
I wish to register the comments of the Association of British Drivers (ABD) on the draft Essex Local Transport Plan 2006-2011. It is unfortunate that the ABD was not invited to be part of the consultation process in the early stages of developing the LTP. As one of the few organisations representing the interests of motorised road users, I believe the ABD should be one of the stakeholders in the process. I hope this will be the case in future consultations on transport issues.
As the draft LTP has only been made available for comment very recently, there has not been sufficient time to prepare as comprehensive a response as I would like. Also, it is clear from the layout of the feedback form that comments are sought mainly on the adequacy of the LTP document itself rather than on the policies contained therein. Since the ABD has not been afforded an earlier opportunity to comment on those policies, I have not confined my comments to the questions asked on the feedback form, which I have reproduced below against each of the LTP chapters. Instead, I have made comments on the policies themselves where necessary.
I hope that the ABD's comments will be given proper consideration in finalising the LTP.
Association of British Drivers
Does this section provide a clear enough picture of how we see the future of transport?
The ABD welcomes the county council's recognition that 'the car will remain central to lifestyles'. However, the ABD is concerned that this statement may be little more than lip service and many of the council's policies will work against car users. The word 'sustainable' and its derivatives appear frequently throughout the document, but this concept means different things to different people. It would be useful if the LTP included a definition of what the council actually means by it. Also, in the council's vision statement, the term 'active citizenship' is used. Such nebulous phrases need to be defined or, better still, be replaced with plain English.
Does this section provide a useful summary of the contents of this document?
The summary gives a reasonable overview of the contents of the document. The ABD's comments on specific policies are set out in the sections below.
Does this chapter give enough background information on the LTP process in general?
Is it clear how we have approached the development of the strategy?
In section 1.5 (Consultation and Engagement) it states that over 400 stakeholders were consulted during the 18-month development of the LTP. Who were these stakeholders, how many represented motorised road users, and why was the ABD not included? Also, towards the end of that section, reference is made to meetings with 'a variety of stake-holders' to develop an Essex 'Community Strategy'. How were these stakeholders selected? One of the themes identified in these meetings is said to be that 'constructing large infrastructure is no longer an option' in tackling congestion, a position that the ABD does not support - and it is noted that the LTP actually includes proposals for some major new road building, albeit that the ABD would like to see more, and for road safety purposes as well as congestion relief.
2 Regional & National Context
Does this chapter give sufficient detail of the role of Essex within the region and the UK?
There are no issues in this chapter that the ABD wishes to comment on that are not covered elsewhere, e.g. the definition of 'sustainable'.
3 The Character of Essex
Does this chapter give an accurate and fair portrayal of Essex?
Are there any other characteristics in relation to transportation which we should highlight?
The ABD takes issue with some of the statements made in section 3.2.5 (Environment). In the third paragraph, figures are given for the percentage of emissions attributable to transport that affect air quality. These include 21 per cent of carbon dioxide (CO2) emissions. It should be noted that CO2 is not an air quality issue, as it is not detrimental to health (except in very high concentrations in enclosed spaces, as it does not support respiration). Also, it should be made clear that the 21 per cent figure applies to man-made CO2 emissions, which amount to only around 3.5 per cent of the total CO2 in the atmosphere at any one time. Hence transport accounts for less than 0.8 per cent of total CO2 emissions.
No figure is given for the proportion of PM10s attributable to transport, presumably because their concentration is heavily dependent on meteorological conditions, i.e. the wind can blow in PM10s from continental Europe if it is coming from that direction. Since PM10s are one of only two pollutants that are ever likely to exceed air quality threshold levels, the LTP should make it clear that the scope for reducing them through local action is limited.
The ABD does not accept the widely proposed hypothesis that man-made CO2 emissions are contributing significantly to climate change. Putting that aside, however, the last paragraph in section 3.2.5 should recognise that the vulnerability to flooding of low lying coastal areas of Essex is due in no small measure to the phenomenon of 'glacial bounce', i.e. the sinking of south-east England as north-west Scotland rises, following the end of the last Ice Age. Essex will continue to sink in relation to sea level, therefore, regardless of whether sea level rises overall.
4 Challenges & Opportunities
Does this chapter give enough weight to the unique challenges that Essex faces?
Are they sufficiently well explained?
Some statements and proposals in this chapter are of concern to the ABD. In section 4.2.2 (Managing Congestion), it is stated that the county council will seek to undertake the enforcement of moving traffic offences at the earliest opportunity. The ABD opposes such a policy, as experience of decriminalised parking enforcement and the safety camera partnerships shows that enforcement effort becomes driven by a desire to meet targets for the numbers of penalty notices issued, rather than obtaining compliance. As a result, flexibility and common sense in the enforcement of regulations disappear. For this reason the ABD opposes in principle the concept of an enforcement agency relying for its existence on income from the penalties it applies.
In section 4.3.2 (Improving Air Quality), one proposal for improving air quality is the reduction of speed limits. The ABD opposes the use of speed limits for anything other than genuine road safety purposes. Furthermore, the effect of speed on emissions differs between pollutants, so reducing speed limits may actually lead to higher emissions in some cases. The county council also seeks to encourage modal shift from cars to public transport, but many buses emit far more pollutants than cars. Some roads in central Oxford, for example, have very poor air quality because of the number of buses that use them, even though cars are banned.
In section 4.4.1 (Risk of Accidents) the county council sets out its casualty reduction targets. These are heavily weighted towards combined figures for killed and seriously injured (KSI) casualties. The ABD has concerns about the use of KSI figures, as there is growing evidence that apparent reductions in serious injuries are more as a result of reclassification than real reductions. The official definition of a serious injury includes, for example, any fracture, however minor, and any stay in hospital as an in-patient. Changes in medical procedures may result in fewer casualties being kept in hospital, and the ABD is concerned that pressure may be brought to bear on police officers attending accidents, to reclassify borderline injuries as slight instead of serious, in order to meet targets. Over the last ten years or so, fatalities nationally have stopped falling while serious casualties have apparently continued reducing. This means that the ratio of fatal to serious injuries is increasing, reversing the long-term trend before that time. There is no logical reason why this should be the case, as passive safety of vehicles and medical skills continue to improve. The LTP should acknowledge that KSI figures may give a misleading picture of casualty trends.
In section 4.6.1 (Declining Community Environments), under the sub-section on landscape and biodiversity, it is claimed that large infrastructure improvements such as new roads can, among other things, have negative impacts on air quality and biodiversity communities. It should be noted that new roads can also have positive impacts in these areas: free-flowing bypasses, for instance, can relieve town centre congestion, leading to reduced emissions overall; embankments, cuttings and verges can, as they mature, provide undisturbed habitats for plants, insects and small mammals.
Under the sub-section on noise and climate change, the claims about emissions of CO2 and N2O causing global warming, which will lead to rising sea levels and more extreme weather, should be couched in less definite terms. These are not facts, they are unproven, and there is a growing body of evidence that climate change is an entirely natural process.
In section 4.7.1 (The Growth Agenda), under the sub-section on commuting both within and outside the county, there is a statement that 'modern society is more prepared to commute longer distances to reach places of employment'. While there are many reasons for this, one that could perhaps be mentioned is the increase in stamp duty on house sales imposed by the current government. While national transport policy claims to seek ways of reducing the need to travel, stamp duty is an active deterrent to a mobile workforce, especially in the South East where house prices - and congestion - are at their highest. The county council should seek, along with other local authorities, to bring this contradiction to the attention of central government.
5 Essex Transport Strategy
Does this chapter give a clear picture of how the County Council can address the challenges in Chapter 4?
At several points in this chapter the LTP states that the adoption of maximum parking standards can be used to tackle congestion and improve accessibility. While the ABD recognises that the county council is constrained by government policy to adopt such parking standards, we believe they will be ineffective and store up problems for the future. It is only necessary to visit older residential developments in urban areas to realise that lack of off-street parking is no deterrent to car ownership. Even if improved choice in public transport services and facilities for walking and cycling are able to persuade people to change mode for some trips, there will always be trips that are only practical by car and council policy must reflect this.
The chapter describes several strategies for delivering accessibility, including walking, cycling and motorcycling policies, but there is no mention of delivering accessibility through better roads. Yet the list of major infrastructure proposals in table 13 includes the Cross Valley Link from a proposed Chelmsford North Eastern Bypass, specifically to improve access to Broomfield Hospital.
Under strategies to tackle congestion, one feature of the Traffic Management Strategy is shown as a review of all speed limits and traffic regulation orders. The ABD would welcome a review of many of the unnecessarily low speed limits imposed in recent years that cause needless delay to traffic and the criminalizing of safe drivers. We are concerned, however, that speed limits are only ever reviewed downwards, so we would welcome a statement in the LTP to clarify the intention of this aspect of the strategy.
The intention within the Traffic Management Strategy to take on the enforcement of moving traffic offences from the police is opposed by the ABD, for the reasons given under Chapter 4, above.
Under strategies to promote air quality, one of the three main objectives of the Traffic Management Strategy is 'to facilitate the appropriate use of the different types of road and environment'. Clarification is needed as to what this means in practice. Speed management, including a review of speed limits, is also listed as a means of promoting air quality. As already stated under Chapter 4, the ABD is opposed to speed limits imposed except where a road safety benefit can be demonstrated.
Under strategies to create safer roads, one of the four key groups of road users to be targeted by the council's road safety policy is 'speeding' drivers. The LTP should define what 'speeding' means within this context. The ABD accepts that speed that is inappropriate for the prevailing conditions causes danger and is best tackled by education and training programmes. Merely exceeding a statutory speed limit does not automatically cause danger. The ABD is concerned that much of the speed limit enforcement undertaken by the Essex Safety Camera Partnership is targeted at locations where drivers exceed the limit without causing danger. The partnership is able to do this by exploiting the flexibility of the rules within the cost recovery scheme.
The LTP states that the council will work more closely with representation groups and forums such as the Essex Motorcyclists Forum. The ABD would welcome the opportunity to be included among these groups.
6 Area Transport Delivery Strategies
Does this chapter help to give a clear picture of the five area strategies of the County?
Is there any extra information which should be provided for each area?
In the section on congestion and air quality, the ABD welcomes the council's intention to improve traffic flow by removing unnecessary restrictions on roadspace on key radial routes into town centres. The ABD hopes that this will include an objective analysis of the impact on congestion of bus and cycle lanes and will remove those that produce an overall disbenefit to free movement.
The paragraph on safety on inter-urban routes suggest that these have high numbers of accidents 'due to the range of vehicles using them and the speed at which they travel'. It should be noted that, other things being equal, accident numbers will be higher on heavily trafficked roads than on those that are less well used, but accident rates will be lower. Assessments of relative risk need to be made, therefore, on the basis of whether accident rates are above the average for the type of road and traffic level. The LTP statement suggests that the county council is wedded to the idea that speed reduction is the automatic solution to accident problems. The ABD strongly disputes this and calls for detailed analysis of accidents that have actually occurred to enable appropriate action to be identified in individual cases.
Similar concerns apply to the paragraph on safety for rural areas and small towns, where speed reduction is listed as the first action required.
The ABD is disappointed that there is no intention within the LTP to improve the A414 to dual carriageway standard between Chelmsford and the M11. This improvement is required not just on capacity but on safety grounds. Where single carriageway roads become overloaded, especially where they have alignments with good forward visibility (such as the section between Ongar and Writtle), lack of overtaking opportunities due to oncoming traffic lead to frustration and impatience, which can lead to accidents. These are then often attributed wrongly to excess speed, when it is actually lack of opportunity to travel at normal speeds that is the problem.
Similarly, Canvey Way between Sadlers Farm and Waterside roundabout is in urgent need of dualling, but there is no scheme in the LTP programme apart from a vague commitment to investigating improved access to Canvey Island.
7 Delivery Programme
Does the split of our programme across the five area strategies appear to be appropriate (see table 31)?
Will the programme of measures outlined help us to achieve our objectives?
The ABD acknowledges the difficulties of obtaining adequate funding for transport improvements and that spending has to be prioritised. That said, the figures in Table 31 show that, where cutbacks from optimum spending levels have to be made, they are proposed to fall disproportionately on measures to improve the road network. For example, under the budget heading for tackling congestion, the amounts expected to be available for quality bus partnerships and bus and rail interchange enhancements are 100 per cent of those required, while for the traffic management strategy the figure is only around 77 per cent. The ABD supports improvements to public transport services and interchanges but, given the reality that a high proportion of motorised trips are and will continue to be made by car, this should be reflected in the allocation of funding.
8 Targets & Performance Management
Do you think the targets we have set seem appropriate?
Will they help us to achieve our objectives?
Are they realistic?
The ABD's concerns about the use of KSI figures in monitoring the success of road safety policies are set out under Chapter 4, above.
The main indicator of air quality given in Table 38 is the number of area-wide vehicle-kilometres. This presupposes that emissions are directly related to traffic levels. This is not the case, as different levels of congestion for the same level of traffic will lead to different emission levels. Furthermore, the continuing introduction of tighter emission standards for new vehicles will see further improvements in air quality despite increases in traffic. The chart on delivering air quality on page 166 contradicts the table, showing increases in the numbers of bus passengers on selected routes as a desirable intermediate outcome of the air quality strategy. If increases in bus passengers resulted in more buses on the roads, this could actually be detrimental to air quality, as explained under Chapter 4, above.