I’m writing from the Extinction Rebellion group in Cheltenham to highlight an important consultation which is currently underway, and to ask if you’d consider putting in a submission. Of course you may already be doing so, in which case please forgive the email.
The consultation is by Gloucestershire County Council on their Local Transport Plan (LTP) 2015-2041. The consultation closes on March 26th.
The LTP can be seen at www.gloucestershire.gov.uk, searching for ‘consultation’, or https://www.gloucestershire.gov.uk/transport/gloucestershires-local-transport-plan-2015-2031/draft-ltp-consultation/ . You’ll then find the Draft Local transport plan, which is the document under review. There are two ways to respond. On the site there is a long form to fill in, and the Council says you can also respond by emailing firstname.lastname@example.org. This is by far the easiest way to contribute. If you do this, please title your emails ‘LTP Review Consultation Response’.
We are very concerned because transport contributes 36% of the County’s CO2 emissions, and so is an important cause of global warming. It’s essential therefore that the LTP really does tackle the problem.
At the headline level, our concerns are that the LTP:
· It is not ambitious enough –The LTP vision is: “A resilient transport network that enables sustainable economic growth by providing travel choices for all, making Gloucestershire a better place to live, work and visit”. We’d like to see something far bolder, like “A transformation in our transport network that meets the challenge of the climate emergency, enabling sustainable economic growth and making Gloucestershire a better place to live, work and visit”. We also say the overall net zero target by 2050 is just far too late.
· It has insufficient emphasis on getting people out of cars – it’s a plan for car volumes to go up by 1% per year rather than deliver a big uptick in cycling, buses, trains, walking. We want to see a much bigger push for change of transport mode. In a County with a population set to grow by 92,000 by2050, we urgently need to get more people out of the car.
· It lacks the hard targets you need to measure progress. This is a crucial flaw and runs throughout the document. For example there are no targets for the rate of rollout of Electric Vehicle charging points, miles of urban cycle lanes, numbers of park and ride schemes, levels of bus use, dates for switching council vehicles away from fossil fuels… and many more. If you read the full LTP, just count the number of specific, measurable, dated targets it contains.
· There is also no commitment to direct real money at the problem, for example by switching some cash away from roads. This is in stark contrast to Councils like Warwick, for example.
We believe that if lots of people who care about the environment contact the Council and speak up, it may have an impact on real spending plans.
Once again, please forgive this mail if you’re already looking at the issue! Given transport is such a big carbon generator, we just thought we should share what we’re doing and encourage others to do the same. The ideal would be if all of the many environment groups in the county responded, and their members did too: then together we really would have a voice.
If you’d like to see our full response, please let me know and I’ll send it across. (Note: 20 March, you can reply using the address info[at]gloscan.org)
With best regards
PS more background follows…
About the consultation
The consultation is specifically taking place ‘in view of the climate emergency’. It was triggered by Gloucestershire’s Climate Change Strategy December 2019 which strengthened the Council’s environmental commitments, raising the carbon reduction target for 2030 from 60% [i] to 80% (compared to 2005 levels), and aiming at net zero by 2050.
The Climate Change Strategy sets out very limited specific targets for transport (committing only to 200 new EV charging points by 2023): instead it says ‘We will reflect our new commitments in our Local Transport Plan, clearly identifying strategies to reduce carbon emissions’.
Some facts about transport in Gloucestershire
· Transport accounted for 36.6% of all CO2 emissions in Gloucestershire in 2017. [ii] Nationally the figure is 28% [iii].
· Traffic volume has already been growing. 2000-2017 on all major roads in Gloucestershire traffic increased by 17%[iv] compared to a national increase of only 2.3%
· Gloucestershire population is to rise by almost 63,000 people (10.1%) 2016 to 2031[v]. By 2041 it is expected to be up by 92,200.
· As a rural county, lots of people have cars. Non-car households are 17% compared to national average of 26%. [vi]
· More congestion is forecast. Department for Transport says by 2035, 24% of all traffic nationally will be travelling in very congested conditions in urban areas (compared to 13% in 2010 baseline)[vii]
What does the LTP say the council will do?
The Local Transport Plan says the Council wants: ‘A resilient transport network that enables sustainable economic growth by providing door to door travel choices for all, making Gloucestershire a better place to live, work and visit’. It should deliver growth and ‘move towards a more sustainable transport delivery model’.
To do this “there needs to be a step change in the way we travel, including significant mode shift in combination with a dramatic rise in the use of clean emission vehicles”
But does it deliver?
The plan covers many areas, for example road maintenance and planning. It also includes laudable initiatives relating to the climate, for example:
· Investment in mass public transport, for example between Gloucestershire’s main conurbations
· Cycle routes for mass cycle use feeding the urban centres of Cheltenham and Gloucester and integrate with the public transport provision
· High quality local walking and cycle networks
· Installing electric charging points including in rural areas.
· Support for ride share
· Work to reduce the number of wasted delivery trips
· … and more ideas.
But hard numeric targets are few – and the ‘monitoring indicators’ relevant to climate change are weak.
This matters because the hard measures will drive Council priorities. Here are some examples:
1. Increase use of cycling The LTP isn’t trying to deliver a radical increase in cycling. It only targets a 50% increase over 16 years (2015-31). Given that currently the LTP says only 5% of journeys in-county are by bike, this will not have a material impact on the carbon target. This does not reflect the fact that nationally (as the LTP reports) ‘only 2% cycle to school whilst 50% would like to’, or the evidence that ‘79% of women want more protected cycle lanes’.
2. Increase use of rail The Plan says train travel will go up, but again not by much. The increase targeted is only 30% over 16 years, despite the growing number of people who travel in and out of the County to work.
3. Increase use of bus The LTP does not have a target for bus use – it just says the plan is to ‘maintain bus access’.
4. Number of peak hour vehicle journeys The Plan says that peak hour vehicle journeys will go up by 1% per annum. If that’s the case there will be 30% more vehicles on the road at peak time by 2050, meaning that the biggest numerical change in the plan by some distance will be the uptick in car numbers.
At its heart the LTP is relying on cars, lorries and buses switching to electric power to deliver the zero carbon future. It is not a plan for radical change in how people travel. And even with the EV switchover, there are no hard targets for getting the infrastructure in place.
· more focus on ‘modal shift’ – fewer cars and more other transport methods;
· more SMART targets, including a massive increase in ambition for electric switchover;
· more urgency;
· committed funding.
[i] The Gloucestershire Sustainable Energy Strategy 2019
[iv] Overarching strategy 12/2.7
[v] Overarching strategy 11/2.3
[vii] Department for Transport’s (DfT) Road Transport Forecasts
Additional information – a view from Transition Stroud
For an additional perspective and more ideas, see Transition Stroud’s response to the Local Transport Plan.