Policies 2021

January 

Do Department for Transport (DfT) want 100 years of time savings in appraisal?

DfT started a consultation at the end of 2020  on the length of time appraisals should take and the discount rates which should be used.  TPS made it clear in its submission that it should be seen in the context of the significant criticisms and urgent reforms which must follow the Green Book Review.  It was wrong to make adjustments aimed at increasing the BCR of schemes when this whole concept had been so strongly criticised and was subject to a current and fundamental review.

The TPS response is in two parts: a discussion of the key issues, and a detailed response to the DfT’s 11 specific questions in the consultation.

TPS set out its objectives in the response as follows:

• To address the way in which many future impacts are undervalued – although the ones listed in the consultation did not represent the main problem areas.
• To address uncertainty in appraisal and how it varies widely between impacts: this would be an issue in any circumstances but is particularly important given the changes which are flowing from Covid 19.
• To contribute to the reforms identified in the Green Book Review, especially to reflect policies for net zero and levelling up: the latter also needs urgent work to provide a better analytical framework and should be a priority.
• To reform the current system so that appraisal identifies schemes which achieve objectives rather than, as at present, over value schemes which don’t.

TPS suggests a range of solutions in response to this consultation, including:

• an end to the over discounting of environmental impacts and the under discounting of many time values,
• using a range of time periods to reflect this,
• not proceeding with creating larger and even more uncertain BCRs with up to 100 years of non-existent and unmodelled benefits.

It also recommends the revival of the Assessment Summary Table in light of these and other reforms which are part of the joint initiative with LGTAG, CIHT, and RTPI and reported on previously.  Active discussions are continuing with DfT and Treasury.

Read the full TPS response

Read the original consultation document from the DfT

March 

National Planning Policy Framework

In March 2021, the Transport Planning Society responded to the then Ministry of Housing, Communities & Local Government (now Department for Levelling Up, Housing and Communities) consultation on the National Planning Policy Framework and National Model Design Code

Our fundamental criticism was that the proposals do not address the more fundamental changes to the NPPF which the we believe are needed and which we requested in our response to the Planning White Paper. Our comments were made on the assumption there will be a further consultation and/or amendment to the NPPF.

We were pleased the 17 United Nations Sustainable Development Goals (SDGs) were included; also, we that infrastructure and climate change were included as objectives and for any plan to be ‘sound’, it must include sustainable transport. This latter requirement forms the basis for prioritising sustainable transport provision which needs to be made clear to developers, local authorities and the Inspectorate if it is to signal a radical change in approach.

Read the full TPS response  

Read the original consultation document from the DfT  

November

Decarbonising Transport - A Better, Greener Britain – The Transport Planning Society’s Full Response

Following the publication of Decarbonising Transport, A Better, Greener Britain, the Transport Decarbonisation Plan (TDP) by the Department for Transport, the Transport Planning Society wrote a comprehensive response, consisting of more than 25 detailed recommendations. Our response confirmed that TPS believes the plan offers a welcome, all-encompassing strategy for the transport industry to reach Net Zero by 2050 detailing how each mode will get there. We responded to the strategy with reference to our report “State of the Nations: Transport planning for a sustainable future”, published in 2020; which offered 10 recommendations to the government clearly outlining how the transport industry should be moving forward regarding sustainability and decarbonisation, remaining just as important as we go forward into the decade in which we must meet the decarbonisation challenge facing the country and the world.

As a Society we urged the government to follow through on the proposed actions in the TDP as soon as possible. The IPPC report Climate Change 2021: The Physical Science Basis makes for stark reading: climate change is already affecting every region across the globe even at current levels of warming. We stated our believe that the wider population is ready for action: according to a recent poll a third of the British public see the environment and climate change as a big issue for the country.

Given the magnitude of emissions and the size of the error margin in the modelling for car (current emissions: 70MtCO2e) and aviation (current emissions: 40MtCO2e), the most immediate decarbonisation focus must be on reducing society’s dependence on those two modes and on cleaning them, rather than on the proposed rail or bus/coach interventions, which together add up to less fewer emissions (5MtCO2e) than the error margin in the forecasts for either aviation or car. However, we would like to see recognition from the government that electrification of the vehicle fleet cannot be the sole answer, and that reducing journeys, particularly of private vehicles, is crucial.

The Society concluded that the TDP is ambitious in its scope and impressive in many ways, weaving together multiple previous policies into a comprehensive strategy that addresses how each mode of transport will reach net zero by 2050.

Our response identified desirable actions before, during and after COP26:

• Before COP26, we would like to see the government commit to a review of the Road Investment Strategy and the transport appraisal and business case systems, as well as a review of our motoring tax and incentive system in the light of electrification and decarbonisation.
• The forum of COP26 should be used to launch new commitments that build on the TDP, for example, we hope to see the government unveil a commitment to a universal EV charging point standard.
• Looking beyond COP26, in the early years of the decade within which we must cut emissions to keep global warming within 1.5 – 2°C to avoid catastrophic climate change23, action should concentrate on where the case for change is greatest.

Read the full TPS response

Read the DfT's Transport Decarbonisation Plan (Decarbonising Britain – A Better, Greener Britain)