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ITEM EX8
EXECUTIVE
– 4 SEPTEMBER 2002
REGIONAL TRANSPORT
STRATEGY
Report
by Director of Environmental Services
Introduction
- In June 2002 the
South East England Regional Assembly (SEERA) published a draft revised
Regional Transport Strategy (RTS) "From Crisis to Cutting Edge" for
consultation, a copy of which is in the Members’ Resource Centre. This
will form part of guidance to local authorities on how their transport
and land use policies should assist in addressing the priorities within
the region. This report includes the comments of the Director of Environmental
Services on the consultation draft, and recommends that these form the
basis of the County Council’s response to the consultation.
Background
- The RTS forms
part of the guidance published under the Government’s ‘Regional Planning
Guidance (RPG) 9 – South East of England’, the remaining part of the
guidance being made up of the Spatial Strategy, also produced by SEERA.
(The area covered by SEERA runs from Buckinghamshire and Oxfordshire
in the north down to Hampshire in the south and across to Kent in the
east (see Annex A).) The latest version of adopted RPG9 including a
chapter on the RTS was published in March 2001. However, due to issues
of consistency with national guidance, the Secretary of State requested
that SEERA undertake an early review of the RTS. This review has led
to the consultation draft RTS which is the subject of this report.
- The importance
of the RTS should not be underestimated. The Regional White Paper ‘Your
Region Your Choice’ and the Planning Green Paper ‘Delivering Fundamental
Change’ clearly set out that the Spatial Strategies and Regional Transport
Strategies published by the Regional Assemblies are likely to gain statutory
status as soon as parliamentary time allows. In addition, if current
proposals for reform of the Structure Plan process, including the introduction
of new Local Development Frameworks, go ahead, then the RTS will have
an increasingly important role to play in the direction and funding
for transport projects in the future and these plans will have to accord
with the RTS.
Overall
Comments
- On the whole,
the RTS is an easy and accessible document to read bearing in mind the
complex nature of the subject. There are numerous difficulties in devising
a single strategy which covers an area as diverse and varied as the
South East, from the pressured Thames Valley, the importance of international
links in and around London and the ports in the south, through to the
large investments necessary in the Thames Gateway to enable redevelopment
and regeneration. The vast majority of the policies within the document
are in line with current County Council policies in the Structure Plan
and Local Transport Plan (LTP), including supporting the East West Rail
initiative.
- However, there
are a number of areas of the strategy which appear to contain policies
which are of concern. There are also a number of generalisations about
the applicability of the policies and measures that are being promoted.
For example, Policy T21 contains a proposition that Local Transport
Plans should ‘use Freight Quality Partnerships as the most appropriate
mechanism for promoting vitality of urban and rural areas by securing
more efficient distribution of goods, whilst protecting the local environment
and amenity’. While this is undoubtedly true in some areas, the use
and effectiveness of such partnerships is still under investigation,
and their general effectiveness is not proven. A number of more minor
points are listed in Annex B to this report. The remainder of the report
will focus upon those issues which I feel have the greatest potential
impact on the County Council and the county at large.
A34 Multi
Modal Study (MMS)
- Multi Modal Studies
(MMS) were set up in the Government’s Transport White Paper of 1998
‘A New Deal for Transport – Better for Everyone’. The aim of the MMS
is to investigate area-wide strategic transport problems on or with
all modes of transport and to seek solutions to those problems. Five
studies were due to be undertaken within the SEERA area, four of which
are already underway. The outstanding study is that for the A34 north
of Southampton. The commissioning and undertaking of the studies originally
fell to GOSE, however this has now been passed to SEERA. The A34 MMS
is of paramount importance to planning transport provision in the County
due to the wide and varied roles of the road from the very local, through
the regional up to the trans European. The treatment of the A34 corridor
will have consequences for the County’s Transport Networks Review and
for the long term transport strategies for Abingdon and Didcot.
- It is very disappointing
that the A34 MMS is not mentioned in the main section of the RTS on
such studies (Para 1.5) nor is it shown on map 1.1 which shows the MMS
areas although it is mentioned on a few occasions throughout the remainder
of the document (such as para 6.37). It would appear that SEERA is not
taking the issues surrounding the A34 MMS as seriously as they could,
and I fear that it may possibly be overlooked. This could have potentially
serious impacts on the wider transport implications for the county,
and reduce the opportunities which would otherwise be forthcoming by
working even more closely with all the agencies involved in developing
a MMS.
Mobility
Management Plans
- Mobility Management
Plans (MMP) are new documents which have been developed by SEERA and
are set out for the first time in this strategy. The concept appears
to be aimed at ensuring ‘an integrated approach to managing the demands
for movement that aims to adjust, over time, people’s patterns of travel
in a way that ultimately gives greater choice in the mode of travel
available for their journey’ (para 7.8). However, the concept of MMPs
is confused within the document: policies T1, T6 and T15 illustrate
how a MMP appears to be taking on the role of a Transport Networks Review
at the County level, an Integrated Transport Strategy at the town level,
and a Transport Impact Assessment at the local level. It is very unclear
what SEERA considers the actual role of MMPs to be. At the very least
we would expect an annex explaining exactly what SEERA means by a MMP,
what it should contain and the exact relationship with the LTP.
- Of potentially
greater concern is the confusion and inconsistency that may arise should
the RTS gain statutory status and these issues are not addressed in
the Government’s guidance on the next round of full LTP (2006-2011).
This could leave authorities with the issue of choosing to follow either
national or regional guidance. Due to the potential impacts that MMPs
may have, I would suggest that, if SEERA believes that there is a need
for this type of assessment, it should be lobbying the Department for
Transport for its inclusion in the next round of full Guidance to LTPs
so as to ensure conformity and clarity. Otherwise the RTS is potentially
placing an extra burden on authorities within the South East, and affecting
our competitiveness with other regions. It would be more appropriate
for such policies to request that the Department for Transport include
MMPs in their guidance on LTPs.
Charging
- The ability for
local authorities to introduce congestion charging was contained in
the Transport Act 2000. This included options to apply charges on a
single road or group of roads or area wide. Whilst the LTP contains
no proposals for charging and the issue is unlikely to be considered
until the next plan period (2006-2011), the RTS covers the period up
to 2016. SEERA has taken the view that in the period up to 2016 it may
be necessary
to introduce charging and has developed policy on this. This in itself
is a controversial position to take and its is unclear on what basis
this conclusion has been reached. However, I have the most concern regarding
paragraph 7.40 which states: ‘a preliminary assessment of the characteristics
of the region suggests that parts of the Western Policy Area, and in
particular within the Thames Valley, might be the most appropriate area
to focus upon’. This gives me great concern on a number of points. Firstly
the process of preliminary assessment has not been made clear or been
consulted upon. Secondly, the area which may benefit from a charging
regime may change over the lifetime of the RTS, therefore it would seem
prudent not to name an area. Thirdly the powers to introduce such a
charging scheme lie with the local highway authorities involved and
not with the regional body. This is to ensure that the introduction
of a local charging scheme is linked to the development and operation
of schemes to satisfy unmet local transport needs. I consider it inappropriate
that such a suggestion should be made in a regional document unless
and until agreement has been reached with the appropriate highway authorities
on both the principle of charging and the related policies and proposals
which would be funded through any charges.
- Possibly the most
concerning issue is that the consultation strategy in the RTS contains
a statement that SEERA will come to a view regarding charging and include
this with the full RTS submitted to the Secretary of State without further
consultation. This comment is also included in a number of other policy
areas (paras 7.23 on Mobility Management Plans, 8.12 Freight, 14.15
Targets and Monitoring). I consider that, given that in each case the
strategy is dealing with complex and potentially controversial issues,
this lack of consultation on the final policies is unacceptable.
Tiers
and Finance
- The document as
a whole has a large number of issues relating to different tiers of
government, and SEERA appear to have overlooked the fact that the vast
majority of the area is subject to two tier administration. A number
of policies contain the statement ‘… local transport plans and/or development
plans…’. This is bound to cause a great deal of confusion between the
responsibilities and impacts that the RTS will have upon LTPs, the Structure
Plans and District Local Plans. The role of the RTS and each authority/plan
needs to be made explicit in the document to ensure that there are no
areas of ambiguity of role once the Strategy is adopted. It is unlikely
that such a lack of precision would be considered acceptable in a Structure
or Local Plan.
- Finally, attention
also needs to be brought to the potential impacts that policies may
have on revenue as well as capital spending. A number of policies have
direct requirements to set up facilities which this Council currently
does not support. A typical example is presented by policy T15 which
calls for the setting up of ‘an integrated and comprehensive travel
planning advice centre’. The revenue implications of establishing and
running such a facility could be high. The strategy needs to clearly
make the case at the beginning of the document that to achieve some
elements of the RTS there is a need for greater revenue commitments
than at present, and that without these there are a number of policies
and proposals which are likely not to be implemented. Whilst these issues
are mentioned in the strategy (paras 9.16-9.20) and by Policy T22, I
believe that this issue needs to be given increased prominence in the
strategy and that where appropriate, policies likely to have revenue
consequences should include a relevant caveat.
Conclusion
- In conclusion,
the strategy as a whole is balanced and reflects the majority of the
policies contained in both the Structure Plan and LTP. There are a number
of individual issues I have highlighted in this report which raise concern
and which, I believe should form the basis of the Council’s comments
to SEERA on the strategy. In particular SEERA should be requested to
consult upon any amendments to the Strategy prior to submission to the
Secretary of State so as to ensure that authorities are able to comment
on any changes or updates to the document.
RECOMMENDATIONS
- The Executive
is RECOMMENDED to:
- agree
to the report forming the basis of a written response to SEERA
on the draft Regional Transport Strategy, with particular emphasis
on the points on the A34, Mobility Management Plans, Congestion
Charging and Finance; and
- request
that SEERA holds a further consultation on any changes to the
Strategy prior to submission to the Secretary of State.
David
Young
Director of
Environmental Services
Background
Papers Nil
Contact
Officer Peter Mann Tel Oxford 815479, Andy Barton Tel Oxford 810461
August
2002
ADDITIONAL
COMMENTS
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Para
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Comment
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6.14
Safety,
both actual and perceived, has an influence on people’s lives in
a variety of ways. In transport terms, this relates to fear and
experience of road traffic accidents, fear of crime when travelling,
particularly on foot and public transport, and fear for one’s own
safety when walking, cycling or motorcycling.
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The
text should refer to powered two wheelers and not just motorcycles.
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7.18
Where
the application of this approach results in charges being increased,
the additional revenue raised should be used to increase access
by non-car modes.
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This
fails to recognize the different functions and responsibilities
in a two-tier local authority structure.
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POLICY
T17
Development
plans and/or Local Transport Plans should identify ceilings for
the maximum level of car parking associated with new development,
provided these are linked to an integrated programme of public transport
improvements.
POLICY
T18
Development
plans and/or Local Transport Plans should:
- adopt maximum
levels of parking provision for non-residential developments,
linked to an integrated programme of public transport improvements,
that are between 30% and 100% of the maximum level of provision
set out in PPG13;
- include
policies and proposals for the management of the total parking
stock within transport hubs that are consistent with these limits.
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There
should be greater clarity for two-tier local authority structures.
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POLICY
T19
Local
Transport Authorities should ensure that their Local Transport Plans
submitted to Government in 2005:
- identify
those major travel generating developments, both existing and
proposed, for which Travel Plans should be developed;
- require
all major travel generating developments to have a Travel Plan
agreed and implemented by 2010;
- include
proposals to establish Transport Planning Advice Centres as part
of the Mobility Management Plan associated with the transport
Hubs.
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This
type of request should be included in national guidance, and not
just covered by those LTPs in the South East.
With
no definition of ‘major’ it is difficult to see how much work this
may involve – however applying this policy to exisiting developments
will be difficult. In addition, a local authority cannot easily
‘require’ a Travel Plan to be agreed and implemented on an existing
site.
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14.11
Drawing
upon the results of the work undertaken in reviewing the availability
of existing baseline data sets, the following set of key and headline
indicators are proposed for monitoring the performance of this Strategy:
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Great
care needs to be taken in setting indicators and collecting data
to ensure that local authorities are not overwhelmed. For example
an indicator on road traffic needs to be assessed in relation to
what’s being planned in certain areas, i.e. if traffic flows on
the trunk road network decrease (through pricing etc), this may
not indicate a successful strategy, if traffic levels within a hub
(e.g. Oxford) are increasing and hence quality of life is deteriorating.
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