Created; < 06-01-04, Revised; 12/05/2020, 01/03/2020

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Consultation response. 26 October 1997

A response by: 

Eric Parkinson, 

xx, xx xxx, 


Kent CTxx xxx

This full response is intended to augment the initial items sent via email in an earlier communication. 

For clarity, I will respond on a point-by-point basis in the prescribed order from paragraph 34 of the document itself. An email copy will also be sent so that any text may be accessed for editing into other documents. 

(copy sent to 

I am willing to supply evidence and to act in an advisory capacity to Mr Prescott and his colleagues should he, or his advisors so wish. 

1. Are the aims we have set ourselves in paragraph 10 the right ones? Do they miss anything important? 

The objectives are broadly correct. Promoting environmental objectives must come through education and by society being enabled to make links between actions and consequences in order to make informed choices. 

Enhancing the vitality of town centres must be achieved by promoting access by light rail NOT by use of the current models of short range park and ride. Short range park and ride promotes car use for the fundamental long range sector of journeys and only supplies low energy public transport for the shortest distance. It conveys the wrong message to motorists. It suggests that they can drive long distances and then do a little bit of the journey, that noticeable bit in towns, on public transport and they are being “green”. Nothing is further from the truth. 

Bus-based short-range park and ride also rings towns with car parks for idle cars. We need land for food in the next century, not land for car parks. 

Air transport does not receive detailed attention. The fastest-growing travel sector--and enormously polluting--is air travel. Travel to airports should be by train and bus. Tax airport car parking provision. Increase the Air Travel Tax and let carbon taxes do the rest. 

2. What balance should there be between "sticks" and "carrots" to achieve our aims? 

The balance of sticks and carrots is delicate, but the financial sticks must be used to subsidise and thus promote the carrots. Potential money raised from speeding fines, from taxing non-residential private car parking spaces and increasing taxes on company cars should be ring-fenced for sustainable transport measures. It should support buses, trains and trams that are so good, so frequent and so reliable that we--you and I--WANT to travel on them. 

Can we conclude that neither works without the other?


3. Recognising that funding available from the public purse is strictly limited, how best do you think our transport systems could be improved? 

I do not work from the premise that funding is limited. It is entirely a matter as to how the fiscal cake is cut and the perception of national priorities. 

One over-valued national priority is defence spending. We should come to terms with our place in the world. In the words of Corelli Barnet (1997) “we should therefore accept the reality that Britain is now just a middle-sized state within the European Union. We should fix our defence budget as no larger percentage of GNP than that borne by our most effective rivals in world markets” (The Sunday Times News Review, p.5 Sunday, 26 October)

Funding IS available and funding for sustainable, integrated transport is vital to our common future. Apart from funds diverted from defence spending, the Government could raise finance from increasing taxation on company cars, from non-residential private parking spaces and on fuel duties. 

Spend the money on extending the rail network and considering bi-modal use with heavy and light rail applications using the same infrastructure. 

Electrify all routes. 

Re-open the branch lines. 

Use IT to provide interactive user-friendly timetables--with touch-maps NOT pages of tables. 

Use IT to interlink electric bus services with heavy and light rail services. 

Promote “station car” (i.e. electric short range hire car at rail stations) concept for unique difficult journeys. Promote facilities for short range electric car hire. Add car hire data to user-friendly travel maps. If I want to travel from Canterbury to Manchester, I should be able to plan all aspects of my journey by public transport at the touch of buttons on an interactive map in Canterbury before I travel. 

Use IT to link taxi services into the network. 

4.To what extent should we be looking at the potential for restraining use of the car, van or lorry? How would any such restraints operate, and what would the effect be on personal mobility or national and regional competitiveness? 

Restrain use by making company car drivers bear the FULL cost of motoring. 

Restrain use of cars by taxing non-residential private car parking spaces. 

Increase fuel duty. This will discriminate against road haulage which is six times less efficient than rail freight. Add Policy Planning Guidance (PPG) that assists planners in promoting industrial development next to rail terminals NOT motorways. 

Use IT to develop wagon load flexible rail freight efficiency--as used in New Zealand. Personal mobility need not be compromised--only the way the journey is carried out. 

In para. 16 of the consultation review, park and ride is mentioned. It is noted that “we will want to look carefully , for example, at the potential of park and ride facilities” 

And so the Ministers should. Short range, bus-based park and ride is a barbed tool with induced effects which go against the grain of road traffic reduction and less reliance of the motor car. The research of Parkhurst (1996) will be recalled. I note salient points for Ministers to consider.... 

Key findings from Oxford, York, Bristol, Nottingham, Shrewsbury, Maidstone, Norwich, Worcester, Chester. (Parkhurst 1996.) 

Short range park and ride: remains the case that vacated capacity has been refilled; many of the cars parked at park and ride sites have, in some way, to be regarded as additional to the traffic on radial roads..... (p.21) a minimum, it is not the case that car trips have been permanently removed from the city. (p.21) 

 ...once expanded to provide a significant share of the city’s parking policy, user dependency is engendering and it becomes politically unacceptable to remove it anyway... (p.21) 

In the City of Canterbury a bus-based short range park and ride scheme is being introduced. To the shame of the city council--which hopes to expand the scheme with government money, the current out-of-town car parks serve people who have abandoned public transport by train--and now use cars instead. The “easy parking” of park and ride also generates more traffic. 

A survey--the council had not conducted one-- was carried out by Canterbury Friends of the Earth. They then performed a modelling exercise to see what other means of transport could have been used instead of building a park and ride facility.

In their findings, they note that with regard to favouring sustainable options--such as rail and bus, rather than promoting unsustainable car-led short range park and ride, a dispersed long-range rail based platform was used as a modelling tool to see what alternatives could have been used at Wincheap (the second park and ride site in Canterbury).

Preliminary analysis of the data, suggested that 52 of the respondents--56%--actually had trip origins that began within four Km. of rail stations and would have had direct trains to Canterbury. Many of the respondents could have walked or cycled to rail stations.

The data further suggested that a further 16% of users had trip origins within 4 km of stations --but with the disadvantage of a change of trains at Ashford. 

72% of users could have been served with existing infrastructure! 

Yes Ministers, a good hard look at bus-based short range park and ride please! A final thought from the Parkhurst (1996) research..... 

“To date, bus park and ride schemes have been less able than rail schemes to assist in the development of the overall public transport network” (p.27) 

5. What roles should be played by pricing, fiscal policies, and regulation to achieve our aims?

 Role of Government fundamental. 

Use taxation to raise finance from “unsustainable human activities”--that is tax high energy activity such as air travel and over-use of cars. Shift taxation policy from direct taxation to indirect taxation. Consistently increase use of carbon tax as a taxation form similar to VAT. 

Levy the carbon tax so it taxes ALL aspects of lifestyle. 

Eventually replace VAT with carbon tax to restrain high energy, high pollution activity and promote new energy sources and energy efficiency. 

6. What can we do to reduce peoples' need to travel?

Use of IT. Email communications. Video links and conferencing. 

Promote use of supermarket delivery services.

Promotion of neighbourhood schools and university education catering for local markets. Where there is travel involved, promote low-energy modes such as cycling. 

To some extent, I am not sure we need to reduce peoples need to travel. Who are we to decide on “needs” anyway? The issue is low energy travel. If even more of us travel greater distances, but do so with greater and greater spatial and energy efficiency (ie surface public transport) , then what is the problem? 

7. Would transport policy be enhanced by adopting a range of transport "targets", against which to assess progress? If so, what form should they take? Should they be national, regional or local? 

Targets for reducing traffic --road AND air--should be set at all levels. 

The traffic targets must apply to town and countryside. 

Implement Road Traffic Reduction Bill 2. 

8. Should Government develop new funding mechanisms or income streams for transport? If so, what form should they take? 

Funding should be made to justified bids for light rail/ tramway projects and complementary electric bus services. These services must be able to carry cycles. Formula funding should set be against bid criteria including indices of air pollution, vehicle use density, vehicle speed etc. For finance see point 5. 

9. Against the background set out in paragraphs 15-24, which aspects of public transport do you think it is most important to improve in order to persuade more people to leave their cars at home and use public transport instead? 

High speed long range rail, with good seamless services into Europe. 

High quality light rail and electric bus with capability to carry cycles. 

High density of reliable services. 

10. What practical measures would bring about more use of less environmentally damaging forms of freight transport such as railways, inland waterways and coastal shipping? Could the Government's freight grants scheme be improved further, and if so how? 

Simply add the carbon tax factor. It discriminates against high energy transport modes. Tie the freight grant mechanism into planning procedures. New warehousing and industrial estates should ONLY be considered on brownfield land adjacent to rail facilities. 

11. How can the contribution of ports and airports to regional and national competitiveness be enhanced without detriment to environmental objectives? 

To what extent do airports contribute to national competitiveness?  How is this offset by environmental damage?  If I see packs of beans on supermarket shelves flown in from say, Kenya, is this in anybody’s best interest? Kenyans need local food. We do not need the global air pollution from life-expired jets cruising the skies with bags of beans on board, do we?

I question the value of airports and the growth in air traffic. 

At airports, tax the car parking spaces--the wasted acres around Heathrow/ Gatwick/ Birmingham. Achieve an integrated transport policy by improving rail access to airports. Set right the wrongs of the past. Dis-invest in roads. Build new rail lines. Build them on existing roadways e.g. the widened parts of the M25----then there is no controversy about new routes. 

12. How can we actively encourage more environmentally-friendly vehicles and fuels, the development of less environmentally damaging technologies and innovations which reduce the need to travel? 

Carbon tax. Tax the undesirable and innovation will follow. Britain needs to diversify its industrial base. Perhaps we could topple the supremacy of the defence industry and diversity into “clean” manufacturing activities. Little Denmark has not done too badly developing energy management systems and wind turbines! 

13. How can we integrate land use planning and transport more effectively, with a more strategic approach, so as to cut unnecessary journeys? 

Through the PPG’s. Plan rail and waterborne freight facilities as “industrial villages” Stop absolutely all out-of-town development. Out of town development polices induce car- dependence and waste valuable land with low density facilities interspersed with car parks.. Adopt a policy of “the right business for the right place”. We should have none of this park-and -ride nonsense on farmland around our towns. 

High quality farmland MUST be retained to feed future generations. 

The Royal Commission on Environmental Pollution , Report 19 ( RCEP 1996) made the point that “ there should be a strong presumption against converting greenfield land to other uses” (para. 10.17) and that “....the adequacy of soil resources is a global issue. Serious forms of soil degradation are apparent in many other countries. The task of managing the UK’s soils wisely has to be viewed against the probability that increased food production will be necessary in temperate countries to meet the rising world demand from a rapidly growing population and in the face of serious shortages of water at a global level” (para. 11.3) 

14. How can we ensure, for example through the taxation system, that the prices faced by transport users more accurately reflect the wider environmental and social costs? 

Carbon tax. 

15. What is the appropriate role of national, regional and local levels for the provision and regulation of transport? What role should be played by passenger transport authorities or executives, or by voluntary co-ordinating bodies such as planning conferences? 

Vital that passenger transport executives are given powers to co-ordinate regional seamless polices. 

16. What changes might be needed to the ways local authorities receive capital funding for transport, to encourage the development of integrated transport policies at the local level? 

Give them the power to raise funds from taxing non-private car parking spaces and the authority to collect all revenue from speeding fines. 

17. Is there, as suggested in the previous Government's paper "Transport The Way Forward", a role for making greater use of economic instruments to influence how people choose to travel, such as increasing the price of public parking, possibly taxing companies' car parking provision, and charging for the use of roads? How should the receipts from such sources be used? 

Yes definitely, but am not sure that road pricing will work. How will drivers of foreign vehicles be billed for road use? I also have reservations about a road-pricing surveillance system in which potentially ALL vehicles can be traced at ALL times. I do not want Big Brother looking over my shoulder in all aspects of my life. Tax non-residential private car parking spaces. Local receipts should be devolved to the PTE’s who will determine and allocate to local/ regional needs. The Lex Report on Motoring (1993) notes that half of all parking in our cities is private, non- residential and that some 83% of car drivers entering cities have private spaces. . That is a lot of car spaces and lot of potential tax. 

18. What should be the role of urban traffic management measures? 

Limit speeds. Urban roads need a 25 MPH limit enforced absolutely. Use IT to collect evidence re. speeding with cameras. Use finance raised for PTE’s Other routes should have a 40 MPH limit. Motorways a 50 MPH limit. This reduces pollution, saves lives and reduces the competitiveness of road transport to the benefit of low energy sustainable modes. Do NOT fund or implement short range bus based park and ride schemes. They increase car dependence and increase traffic beyond the urban mass. 

19. How can we achieve economic growth which is less road traffic intensive, while still taking account of the role of national, regional and local transport policies in promoting national and regional competitiveness? 

Promote local, regional and international rail use. Build second rail channel tunnel/ causeway to improve flow of traffic to Europe. 

Channel Tunnel will “peak out” in the not-too-distant future. Regional Eurostars will add to capacity problems. 

Replace deep network of London Underground with surface light rail-- trams. 

The LUL deep network is unsafe, expensive and discriminates totally against the mobility impaired. Trams would be cheaper and safer. Displace London road traffic with trams. Let us have quite, safe, fume-free streets.

20. In circumstances where demand exceeds road capacity at certain times, what priority might be given to scarce road space and how might that be delivered? It has sometimes been suggested that priority should be given to emergency vehicles; buses, coaches and taxis; goods vehicles; and disabled motorists - are these the right priorities? 

Yes they are. But more goods should travel by rail and 44 ton trucks should be stopped now. Also, perhaps we need to investigate “Piggyback” combined rail and road traffic more fully for smaller as well as large vehicles. 

21. How can we best take account of the differing accessibility needs of urban and rural communities? 

For Urban communities, improve urban access by light rail and electric bus. Light rail is particularly effective for new investment in city centres where fixed-route facilities assure the developers that high quality transport links can be provided. Dense, high intensity city centres, (Rogers 1995) with less road traffic should be more pleasant to live in, and thus will be a counter-magnet to the residential drift to the countryside. 

The rural population has doubled in 40 years. This has been because of cars. People have moved out of cities because of the traffic for example--dismissing the fact that they are part of the problem and that they carry the problem of road traffic into the formerly quiet countryside. Dispersed park and ride might be part of the solution. In this model, short range journeys are taken by electric car to assembly points on rail and bus routes. The longest leg of the journey is taken by low energy bus or train. Re-opening old rail routes would assist in this process. I have fundamental objection to the conversion of old railtracks to busways in that these cannot carry freight.

In the long term we may be forced to ask ourselves to what extent rural living as we currently understand it is sustainable. . 

22. How can we increase the awareness of transport users about the consequences of their choices? 

Education, Education---- and carbon tax. 

23. How can we best ensure a high standard of safety across all modes? 

Use of combined passenger/ freight safety executive with far-reaching powers. 

24. How can we ensure that policies designed to establish environmentally sustainable transport systems are compatible with the Government's wider aims for social inclusion? 

Density and quality of provision and attractive pricing. Subsidise public transport with funds from private and company motoring, including those all-important non-residential private car parking spaces. 

25. How can we best promote the transport needs of disabled people? 

Low floor buses, trams and taxis with ramps as standard. 

Provide parking where alternative sustainable modes--low floor tram and bus--are not yet available. 

26. How can we best take account of the transport and accessibility needs of all sectors of society, including the young and the elderly? 

By attractive pricing, safety, quality and frequency of sustainable low energy modes of travel. By planning policies that promote intensive use of high density city centre facilities--not car-led urban sprawl. 

27. What should the role of transport be in delivering the national air quality strategy, reductions in acidifying pollutants and our climate change commitments? 

Fundamental. Carbon tax, carbon tax, carbon tax. Let low energy transport measures such as electric railways displace the fossil fuel dinosaurs. At the same time we need to invest in wave and wind power projects--particularly offshore wind turbines. Also invest in nuclear fusion technology. And do not forget the damaging effects of air travel. The general public is unaware of the environmental consequences of air travel, locally or globally. .

Yours sincerely,

Eric Parkinson.