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Transport for the North Decarbonisation Strategy – Our Response

Over summer 2021, Transport for the North consulted upon their decarbonisation strategy. Our response to the consultation is below.


Decarbonisation Strategy - draft for consultation

Dear Transport for the North,

We are writing in response to the consultation on the draft Decarbonisation Strategy from Transport for the North. Thank you for the opportunity to comment on this important policy issue. We need to see urgent and decisive action on the climate crisis in the form of coordinated action across and between the UK regions.

We welcome the draft strategy and its emissions reduction pathway to net zero. We would like to see the strategy strengthened to deliver the cuts in carbon emissions required across the transport sector and for this to involve commitment to meaningful engagement with other planning issues across the North, including land use, commerce and energy.

Although the electrification of the fleet is a key component of decarbonisation, the strategy currently relies too much on this as a means for reaching net zero. This is problematic firstly because electricity generation is currently primarily from fossil fuel sources and therefore electrification transfers emissions from tailpipe to power station. Secondly, whilst electrification reduces tailpipe emissions, it does not tackle other sources of air pollution from vehicles, including tyre dust, which has been estimated to be more damaging than pollution from exhausts[1]. Thirdly, electrification does nothing to reduce other externalities associated with the use of private motor vehicles, which include congestion, land use pressure, and the health impacts of sedentary living.

Fourthly, from a social justice point of view, the requirement for individuals to own a car to participate in society and access employment, education, health care and other services, is socially excluding. This combines with factors such as air quality and transport noise, which tend to affect poorest communities the most, to create a transport system that is characterised by unfairness. A decarbonisation strategy should seek to mitigate, rather than deepen, inequalities in transport provision and planning.

In order to move beyond a focus on electrification of private vehicles, and therefore address these externalities, the strategy needs a strong focus on modal shift and the creation of attractive, affordable and accessible options that facilitate sustainable mobility and, where possible, reduce the need to travel. We would like to see full consideration of the well-established toolbox of ‘sticks’, including parking charging, road and congestion pricing, clean air zones and other restrictions, as well as the ‘carrots’ of promotional campaigns and investment in excellent public transport and active travel options.

This means recognising that rail in the North is often unattractive, expensive, and unreliable; and that there is a need to invest in better facilities, more services, and electrification of lines. Buses also play a key role in facilitating sustainable travel, and there is a need for coordinated action to ensure that towns and cities are able to offer affordable and attractive networks that connect with other public transport, and that rural areas are not excluded from bus connectivity.

Freight is also an important consideration. More attention needs to be given to transferring inter-city freight to rail and to managing local deliveries through sustainable options such as cycles and e-cargo bikes.

We are pleased to see the inclusion of 15-20 minute neighbourhoods. This requires more substance, however: how, for example, are they linked to Local Plans to reduce the need to travel? With development increasingly car-centric, what policy levers will be used to reverse this trend?

Active travel is an essential component of low-carbon mobility and the strategy needs to provide detail on how walking and cycling fits into its decarbonisation plan and how towns and cities in the North will be encouraged to become places where people want to travel by foot and cycle. It is well understood that the main barrier to cycling is fear of danger from other road users and it is well understood that what makes the biggest difference in encouraging people to cycle is high quality, separated cycle infrastructure. Conurbations in the North need to be supported in developing such networks, and there is a role at the regional level in facilitating the development of medium- and long-distance routes. This will better enable walking and cycling, particularly to provide alternatives to car journeys under 5 miles.

We trust that you will take these views on board when finalising the strategy and look forward to seeing the revised version.

Yours Sincerely,

[1]https://airqualitynews.com/2020/03/09/air-pollution-from-tyres-1000-worse-than-from-exhaust-claims-s tudy/

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