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Dear Department for Transport,

Responding to the DfT Policy Paper, Decarbonising Transport: Setting the Challenge

London Living Streets – https://londonlivingstreets.com/ – is the campaigning group of residents, operating across London as a whole, of the national charity, Living Streets – https://www.livingstreets.org.uk/. As a voluntary branch of the leading organisation articulating the perspectives and needs of people who walk many of their trips and wish to walk more of them, we are responding to the DfT’s Policy Paper, Decarbonising Transport: Setting the Challenge.

We would like very much to take part in the upcoming Stakeholder engagement process that the DfT wishes to have in preparing its proposals for Decarbonising Transport.

We will confine ourselves largely to Road Transport.

Comments on the thinking in this Paper so far as Road Transport is concerned:

(Our policy proposals are in bold/underlined)

1. The ongoing assumption of a huge growth in Total Kilometres travelled by road vehicles — 35% by 2050 (over 2018 baseline) – this despite arguing for mode shift to Public Transport and Active Travel (Figure 9).
   Owing to the significant disbenefits of travel by motor vehicles (inc. energy consumption (see 2 below), air quality (see 2 below), road casualties, public health (discouraging people being active) and their negative impact on community and social interaction, The DfT ought instead to be seeking a reduction in both the total number of motor vehicles as well as the total distance they travel annually. These overall reductions should of course vary, having regard to the type of vehicle – buses, delivery vans, private hire vehicles, HGVs, private cars etc.
   
   We would argue that in the light of the Covid-19 crisis and the longer term changes that may result in travel demands, a review of these assumptions is required.
   
   In particular, the number of buses and the distance they travel should indeed increase as people are encouraged to make greater use of public transport. But, precisely because, as DfT makes clear, motor cars generate over half (55%) of the entire transport sector’s carbon emissions (Fig. 3), their present number and the distance they travel should be reduced. Cars, of course, are the single most space-inefficient method of transporting people in urban areas, as well as occupying huge quantities of public space as result of 25% of them (some 8 million) being parked on streets over-night (Para. 2.6).
   
2. Electric Vehicles by themselves will be far from sufficient to address the challenge of the Carbon Emissions generated by Road Transport
   
   Electric Vehicles are not a Zero Carbon mode of transport. Their CO₂ emissions will only become significantly less than diesel and petrol vehicles to the extent that their sources of electricity become entirely renewable. And mining and processing minerals for the metals their construction require and ‘rare earth’ elements for their batteries, transporting these, and the actual manufacturing process itself will all continue to generate significant CO₂ emissions.
   
   Electric Vehicles on average currently generate more Particulate Matter than their petrol or diesel equivalent (from road surface wear, tyre wear, and their brake linings) because of their greater weight. It is ultra-fine particles, along with Nitrogen Dioxide, that damage people’s health in built-up areas on a massive scale and, inter alia, exacerbate existing respiratory problems.
   
   Substituting EVs for petrol and diesel vehicles does little to reduce the externalised costs of motor traffic borne by urban populations – road danger, physical inactivity, community severance etc.
   
   Furthermore, without bringing forward the date for a ban on fossil fuel vehicles, we must remain sceptical how fast EVs are likely to replace them: Current uptake of EVs remains miniscule. The total number is only 230,000 out of 32 million vehicles (Para. 2.4) – or less than 1%. In 2018, only 1.6% of new vehicles bought were EVs (Para. 2.9), this despite the Government subsidising their purchase via the Plug In grant (Para 2.13). Indeed average CO₂ emissions per mile from cars and vans have risen over the past 3 years (2016-2018) because of the surge in buying SUVs which now comprise 21% of new car sales. (Para. 2.7)
   
3. Not paying attention to the fall in Fuel Duty revenue that must occur as EVs replace petrol and diesel vehicles.
   
   The only realistic solution to this problem, as has been argued by various economists for some years, is some form of Road User Charging. National Road Transport policy must urgently address this issue with a view to swift adoption.
   
4. Overlooking the range of external costs that motor traffic, regardless of carbon emissions, imposes on urban residents 
   
   The Government has finally recognised the health-damaging impacts of poor Air Quality, and certain cities are taking advantage of the funds beginning to be available to remedy this.
   
   But there are several other external costs, including: Road Danger; the Discouragement of taking Physical Exercise by daily walking and/or cycling; Noise; and Community Severance. These costs, financial and other, are borne by members of the public who experience these externalities. But public authorities, notably the NHS but also the police, other emergency services and local authorities, are also burdened with the extra financial costs such externalities cause.
   
   Any new national Road Transport policy must take full account of these externalities and set out how Government proposes to address them.
   
   In our view only a Road User Charge will make a real difference; something the DfT is already beginning to accept in relation to HGVs. Widespread introduction of Workplace Parking Levies would, however, be another major contribution to Decarbonisation.
   
5. Walking & Cycling are modes of transport, particularly within towns and cities, that could be used for the high proportion of journeys that are relatively short.
   
   The Department for Transport has already recognised the importance of walking and cycling to health, air quality and decarbonisation in its Cycling and Walking Investment Strategy, and needs to build on these foundations through increased investment in active travel.
   
   To see what has already been achieved in some other countries or cities, the Netherlands, and cities like Copenhagen and Paris, are examples, of the investment needed to transform urban road infrastructures. Low-cost interventions such as Low Traffic Neighbourhoods can also make a major difference to the quality of urban life. We would note the success of relatively low-cost interventions in the London borough of Waltham Forest where a number of Low Traffic Neighbourhoods have now been delivered as part of the Mini-Holland funding from TfL. Their benefits are wide ranging¹ and include improved levels of walking and cycling including by children, improved performance by the local economy, improved air quality, lower road casualties and indeed quantified increases in life expectancy. Low Traffic Neighbourhoods can be delivered by modal filters in the form of planters or even concrete blocks and so can be very low cost.
   
6. No measures are contemplated to end out-of-town car commuters driving in to work on a daily basis (and/or to shop), and clogging up town or city streets. More generally, DfT must develop specific policies to reduce hugely the current overwhelming dominance of the Car in Commuting to Work.
   
   Currently (2018), as the Paper shows, 68% of all workers in Britain travel to work by car. Many of these are drivers who live within the urban area where they work; but there are many who choose to live out of town and drive in from the surrounding smaller urban centres and villages.
   
   In London, by contrast, only 27% of workers travel to work by car. This London achievement, the result of decades of serious investment in public transport, ought to become the national target by 2050.
   
   This has huge implications for radical shifts in transport investment allocations which any national Transport policy must reflect – away from ‘predict and provide’ and building or ‘improving’ yet more motorways and trunk roads, and towards transforming our urban road infrastructure to enable the buses to provide passengers with integrated, less time-consuming travel; the reallocation of carriageway space towards trams and light rail; as well as infrastructure transformations to enable safe and comfortable Cycling and Walking.
   
   Bus travel, in particular, has collapsed. Only 5% of all journeys are now being made by bus (Para 2.21). Yet buses are not only hugely more space efficient than cars, but the whole bus sector generates less than 3% of all transport sector emissions. Rail (where the number of passengers has doubled since privatisation – Para 2.33) is even more efficient, producing only 1.4% of all transport emissions (Para 2.30). 
   
   We look forward to the Department’s Bus Strategy later this year.
   
7. There is a need for a quantum shift in transport Investment sums required to meet the DfT targets – ‘help make public transport and active travel the natural first choice for daily activities’; ‘support fewer car trips through a coherent, convenient and cost-effective public network; and ‘encourage cycling and walking for short journeys’. (Figure 1)
   
   The DfT has recognised the need for an increase in investment in Active Travel public spending from £250 million a year (Para 2.62). The Paper quotes ‘The £100 billion of additional infrastructure announced in the Conservative Party manifesto for the renewal of roads, rail and other infrastructure’ in December 2019 (Para 2.66).
   
   Significantly increased investment should be made in walking, cycling and public transport, in line with the recommendations of Living Streets and other members of the Walking and Cycling Alliance.
   
8. The target date to achieve Zero Carbon Emissions in the Transport Sector by 2050 will not avoid dangerous Global Heating: 
   
   The year 2050 is a whole generation away. In the view of most Climate Change scientists, this is far too relaxed a target date for countries to pursue if the planet is to avoid serious Global Heating by the end of the century.
   
   At the very least, DfT should plan interim targets for the reduction of Transport emissions with for example 5 year intervals.
   
   These Carbon reduction targets, in turn, need to be translated into investment targets for building additional public transport infrastructure at scale, as well as road infrastructure transformations to enable significant increases in cycling and walking rates.
   
   Further, there will need to be financial incentives of various kinds to accelerate the transition away from fossil fuel vehicles in favour of EVs and vehicles powered by other non-carbon- emitting propulsion systems.

Further national policy-relevant comments, specifically from our perspective as an organisation articulating what people on foot need from our roads infrastructure – whether walking their whole journeys (trips) or only part of longer journeys made by public transport or other modes (stages).

Based on our experience and expertise, we urge the following:

1. The need to recognise, at both national and local authority levels, the already existing extent, and potential for expansion, of Walking as a mode of transport for short trips in our villages, towns and cities.
   
   Walking and Cycling are, it must be emphasised, the only actual Zero Carbon modes of travel. Any national transport strategy focussed on getting Carbon emissions down to zero must therefore pay particular attention to how to get far more short journeys undertaken by these modes (walking up to 2km and cycling up to 8km).
   
   Active Travel nowadays is widely recognised by transport professionals. Currently many more people walk short trips or stages, than cycle. Walking requires no specialised equipment, is open to all regardless of income and forms an essential part of every journey – including public transport journeys. But walking is often overlooked in infrastructure and planning decision-making.
   
   There is also a massive disconnect between local transport and land use planning. As Transport for New Homes have highlighted, opportunities in new developments are routinely missed to create Walking- and Cycling-friendly environments, thereby entrenching car dependence into the future.
   
   We note the rarity of specific Walking Plans drawn up by highway authorities, let alone their making specific budgetary appropriations to create the walking-enabling infrastructure investments and behaviour change programmes required. While Walking is often notionally placed at the top of the hierarchy in many Transport Strategies, the stated mode hierarchy is routinely ignored in practice.

2. Transforming our urban road infrastructure in ways that enable Walking as a mode of urban transport for short distances – ie.significant investment in changing, reallocating and improving the existing road infrastructure and public realm of our towns and cities so as to make, in DfT’s words in this Paper ‘Active travel the natural first choice for daily activities’.
   
   This is essential in order to make Walking short trips, or stages in longer trips (to bus stops, railway stations, tram stops etc) the obvious and easy choice for people to make.
   
   Paying attention to the infrastructure changes that Walking requires also means ending the current over-reliance on encouraging behaviour change (convincing people of the benefits of walking). In our experience, local authorities typically engage in such programmes to avoid the ‘harder’ decisions around reallocating road space away from the longstanding de facto prioritisation of (especially private) motor traffic, and in favour of Walking and Cycling (which, as noted earlier, are the only trulyZero Carbon modes) as well as public transport (notably bus lanes and tram tracks).
   
   Here we will mention some of the most obvious infrastructure-related investments that Walking requires:
   • Pavements (rapid repair to a high non-trip hazard standard; dropped kerbs; as part of planned infrastructure changes, or at locations where there is a desire and need to increase the ‘place’ function footway widening can be undertaken, including at commuter hubs and other interchanges, shopping streets and schools; upgrading paving materials used; and banning pavement parking);
   • Road Crossings (number of; location; safety of design; pedestrian wait times; amount of time allowed for pedestrians to get across; Countdown indicators; installation of new Zebra-style pedestrian priority at all intersections of side roads with main roads (following the outcome of the results of the TRL study into the experimental crossings in Manchester);
   • Residential Streets with the infrastructure pedestrians need (quality lighting; seating at intervals; pocket parks, planters and other greening);
   • Lower traffic speed limits with 20mph as the default in built-up areas;
   • Local Town Centre and other shopping streets (wider pavements; traffic-free community hubs for local markets; seating; drinking fountains; greening; removal of clutter);
   • Low Traffic Neighbourhoods (the widespread use of mode filters particularly where rat running has non-local traffic passing through a residential area). These have a major advantage of being potentially very low cost to deliverand can be combined with greening projects such as parklets and the use of planters (as modal filters).
   • School Streets;
   • Signage.
3. Reducing the volume of motor traffic in our urban areas if Walking is to become the default mode of travel for short urban journeys:
   
   Building walking-enabling infrastructure is not enough on its own. Town and city dwellers will continue to be deterred from choosing to travel on foot even very short trips, or stages in longer trips, so long as our urban streets remain overwhelmed by so much traffic, the vast majority of which is private cars. The disbenefits of this dominance (ie. the external costs imposed on the rest of the population by so many private cars in urban areas) include: health-endangering air quality (contributing to the premature deaths of tens of thousands of people annually); road danger (with pedestrians and cyclists now bearing a far bigger load of road casualties than the drivers and their passengers in cars); the prevalence of obesity, over-weight and other health problems arising from lack of physical activity (due to urban residents having sedentary jobs, or not using Active Travel modes for regular journeys such as the commute to work); community severance and loneliness (as older people and young children, in particular, are deterred from going outside and walking and seeing other people on our streets); and noise. Again we would assert that a review of travel in towns and cities is required following the Covid-19 crisis and that greater emphasis should be placed on active travel and a reduction in the impact of the dis-benefits that travel by motor vehicle causes.
   
   What measure could most effectively reduce the dominance of our urban streets by motor traffic? In addition to all the policies we have suggested in this response above, we would like to conclude by highlighting one measure whose time, in our view, has come.

Road User Charging: This is much the most effective approach to reducing the dominance of motor traffic in urban areas. In our view it would be the fairest way of managing what is a scarce public resource and should be set in place with an aim of reducing overall urban traffic volumes and supporting public transport (within the guidelines of safe social distancing):

• This is because it affects everyone using motor vehicles.
• It also generates funding for investment in enabling sustainable travel modes (public transport, walking and cycling).
• Road user charging enables drivers to pay more fairly and more fully for the external costs imposed on the community as a result of their choosing to drive, rather than using public transport, or walking or cycling.
• The savings to the NHS and social care system – as a result of lower volumes of traffic leading to greatly reduced road casualties, as well as the likely reduction in numbers of people prematurely suffering from a range of conditions brought about by exposure to poor air quality or lack of routine physical activity – would be immense.
• Sophistication and Flexibility as to Purposes and Charges: A sophisticated Road User Charging scheme would set the level of charges varying with regard to a number of factors, including type of vehicle (and so its carbon footprint, production of Particulate Matter etc); how much it is used (ie. distance travelled in the town) and where; and at what time of day the driver chooses to use it (e.g. increased charges at peak travel times) etc. In order to support active forms of travel, a pricing weighting could be given to discourage short journeys by motor vehicle (ones that could be most easily substituted by walking or cycling). The London Congestion Zone, introduced in 2003, is an existing (albeit simple) example. And London’s scheduled (Autumn 2021) extension of its Ultra-Low Emission Zone (ULEZ), which targets in particular more polluting vehicles) is another. Several other English cities are already contemplating their own schemes. The Centre for London has already produced a detailed scheme specifically for London which offers ideas for DfT to consider. (Centre for London, Green Light: Next Generation Road User Charging for a healthier, more liveable London, 2019. https://www.centreforlondon.org/reader/green-light/

We look forward to taking part in the Stakeholder engagement process. We would be happy to respond to any requests from the Department to provide more detailed information on any of the points made above.

Yours sincerely

Jeremy Leach

Chair, London Living Streets

DATE 7^th May 2020