Local Transport Plan 4– Guidance Notes

Introduction

Note- Following comments and feedback new sections have been added, at the end, in indigo – 28/01/24

If you are looking to comment on the East Sussex Local Transport Plan (LTP4), you may find this blog helpful. Hopefully it provides some general guidance. Please remember a short blog cannot address all the issues.

Overall the consultation asks you to score a number of nebulous and intangible statements. For most it is hard to disagree with them. You are asked to provide an overall score on categories that are open to interpretation. These might be  for example – strongly agree, agree …..disagree.

However the questions may cover areas where your response might be more nuanced.

As background you may find this blog on the shortcomings of the consultation process of some relevance.

Governance and Reporting

Most project methodologies such as Prince2 have monitoring, interim targets, reports and exception reporting. Most of these are found in the Council’s Carbon Plan .

Section 9. Governance “ Provide oversight of the delivery of the action plan .. Annual reporting to Cabinet and full County on progress “

For transport an equivalent could be modal share. (The split between cars, walking, cycling ,bus and rail). This could be either around private transport (70%) or perhaps for active travel (walking, wheeling, cycling and buses) (20%). Other metrics such as the share of EVs or carbon footprints are perhaps down to national policy.

There were predicted modal share changes, in LTP3,  but there appears to be no review undertaken. It is also normal for plans and projects to have a ‘lesson learnt’ process at the end. So for LTP4 , following the approach elsewhere , there should be:-

•  5 year interim targets. With perhaps one or two clear definable metrics.
•  Review every 2 years
• Description of the new projects for the following 2 years.

This is described in Theme A Section 4.3 “potentially suitable KPIs [ Key Performance Indicators] …. We will establish appropriate governance to oversee the development, delivery and benefits realisation arising from schemes and policies included in this strategy.”

Action – Request that the governance, reporting and targets are more clearly stated

Modal Shares

In the plan there are a number of scenarios provided. All of them are compared to a 2050 ‘Business as Usual’ scenario . This one below is one of the more ‘optimistic’ of them. All have, to some extent, fewer cars trips and more active travel

You may want to consider, as stated in LTP4, that cycle journeys are recently down. Bus journeys are still not at pre-pandemic levels and the plans for bus lanes have been severely scaled back. There has never been any evidence, of a long term reduction, in the modal share and total trips for cars. This is excluding systemic changes resulting from Covid.

The blog on the dangers of unverifiable modelling may be of interest

Action. Ask for more information how the ‘numbers’ behind the scenarios can be validated

Change of Approach by the Council

Campaigners have seen no evidence, of a change in mindset, as suggested by the LTP4 vision. This month the local bus lane plans have been severely reduced, 20 mph schemes are not considered for wide areas, cycle schemes remain very low, but a priority around cars and large road schemes remains in place

Here is an example from Transport Scotland for a clear direction to reduce national car kilometres by 20%.

The route map does not aim to eliminate all car use. We recognise that would not be realistic or fair, especially for journeys undertaken by disabled people or in rural areas where sustainable travel options may not always be available or practical. Rather, the route map encourages all of us to reduce our over reliance on cars wherever possible and identifies four key behaviours that we want everyone in Scotland to consider each time we plan a journey:

• make use of sustainable online options to reduce your need to travel;
• choose local destinations to reduce the distance you travel;
• switch to walking, wheeling, cycling or public transport where possible;
• combine a trip or share a journey to reduce the number of individual car trips you make, if the car remains the only feasible option.

Action – Ask how the council officers and councillors intend to change their approach to transport to support the scenarios they outline in the Plan.

Pollution and Decarbonisation

There are those who think that the issue of carbon can be addressed by a shift to Electric Vehicles (EVs).  Instead of the LTP’s ‘People and Places’ the alternative of ‘Avoid Shift Improve’ is much more focussed on active travel, de-carbonisation and alternatives to the private car, even if electric.

For parking perhaps propose charges based on either CO2 or else around the size of the vehicle. You may also wish to comment on the extra journeys generated through the proposed large road schemes, such as the ‘duelled’ A27.

One aspiration, featured in this and the previous LTP, was linking ‘Land Use Planning’ and Transport. There is very little evidence for recent housing developments that this is being take seriously.

Action – If you want to encourage less polluting vehicles then ask how they will be encouraged ( E-bikes, e-scooters, and smaller greener cars)

Action – Ask for ESCC to be more positive in planning applications in supporting active travel and buses in the large car-centric housing developments especially in South Wealden.

Cycling and Walking

The Plan has many references to more walking, wheeling and cycling. However consider from data provided by ESCC, only £165k has been spent, on cycle infrastructure in the last 4 years.

Contrast this with 6.61 “Reviewing and delivering the Local Cycling and Walking Infrastructure Plan – which includes a robust pipeline of deliverable active travel schemes for networks and places – ensuring a balance of schemes to support walking, wheeling and cycling.

Whatever is written in the LCWIP and in the Council’s budget book, the actual spend on cycling is negligible. The plan ’admits’ that those cycling once a month, in the county, have dropped, in 5 years, from 15% to 10% and is now well below the England average

In terms of walking there has been progress . However  schemes that might help active travel such as 20 mph, Low Traffic Neighbourhoods , modal filters and School Streets require a change in approach from officers and councillors.

Action 1) Ask for evidence of investment, not from the Budget Book, but of actual schemes they will build.

Action 2) In the Health Impact Assessment how the general health of the population will be prioritised . This is around reducing obesity, lack of exercise and multiple chronic conditions

Scenarios

The problem of predicting future levels of traffic, is that even with no interventions, the  so called ‘Business as Usual’ (BAU) in 2050, is different to now. Here is an example from Transport for South East ( TfSE). This is

from their BAU of 2050.  Then the various others scenarios are on top of this. In other words how much the trip balance will change, from BAU, with various interventions. (Note the icon with a cycle is for walking as well)

So the BAU is likely to be similar for East Sussex.  Here are various scenarios from LTP4. Unless one of them is chosen then there is no effective track on progress. This may suit the Council as no real accountability exists. Plus  the option of having 5 year reviews is then less valid. 

Targets

Once an agreed scenario, as above, is agreed there has to be a clear plan to get there. This is called ‘backcasting’ and is the opposite of forecasting. (How do we get there v what might happen). In the image below it shows how it should be broken down into smaller time periods. Perhaps every 5 years.

So in LTP4 there are many schemes and policies but there is no guidance, for readers, as to what would deliver the most change. During the initial workshops there were requests, to provide details as to how the algorithms generated the various scenarios . Otherwise it is a ‘black box’ with outputs that the public have to take on trust. Change would partly be achieved  by the schemes and projects listed in LTP4. (Of course some change will also be through National Government). Otherwise you may mention, in your consultation reply,   certain schemes that sound good to you, but actually  deliver less, in terms of overall change,  than another good alternative. 

The targets could include :-

  • modal shares
  • pollution NOx PMx
  • road traffic incidents
  • children specific  – such as trips to school
  • transport poverty of each council , (that shows Eastbourne to be nearly the worst in the South of England.)

Ideally ones that are already recorded and for which there are comparisons across the UK. 

Cars

If the most important consideration is reducing carbon then moving from the ‘Internal Combustion’ to Electric Vehicles will do this. Especially within the county where the manufacture and disposal is elsewhere as is most of the  electricity production. 

However cars are getting bigger and heavier each year. ( 0.5 cm wider p.a) . They no longer fit in car parking places.  Brakes and tyres create PM2.5 pollution. When in the road they make passing harder and this increases congestion and road damage. Smaller, lighter cars need to be encouraged. Currently an EV charged at home is cheap per mile and this may encourage even more road miles.  If you think road charging might reduce congestion look at this reportAs mentioned earlier ‘Avoid Shift Improve’ would encourage alternatives such as more micro-mobility. 

Paul Humphreys EEAN -Transport Group

Can We Trust Transport Modelling?

Are you intending to comment on East Sussex County Council’s Local Transport Plan 4 ( LTP4). For those who want to review the proposals the future projections for transport look good. Predicted to have fewer car trips whilst buses, pedestrians and cycling numbers are all up. That is  good news! …. but as a reminder LTP3 had similar aspirations

Perhaps now is the time to ask why planners are generating such positive scenarios, that you may feel are not achievable. The predictions are derived from complex algorithms. Often the process is described as a ‘black box’. The definition of which is ‘a complex system  whose internal workings are hidden or not readily understood’ . That makes anything it produces as hard to verify

Let us examine the accuracy of such models. From a lay person’s perspective the optimistic scenarios, over the last 10 years, never seem to have been delivered.

This table below , with 19% fewer cars trips, is from the LTP4. Some scenarios deliver an even larger drop in car trips. [As background, on a number of the workshops it had been asked, if some explanation could be be provided as to how the ‘black box’ generated these outputs]

In sharp contrast, in LTP4 it does admit that, across the county, the number of residents cycling has reduced by around 33% in 5 years. Plus there was a large decrease in bus provision over 20 years and even with an increase in funding, bus passengers are only 90% of pre-Covid numbers.

The largely ‘positive’ models are endemic throughout the planning process. Over the last 10 years many focus on a 10% ‘modal shift’, away from cars, towards buses and cycling. However these predictions then feed into other local plans and permeate through the whole planning process.

As an example ESCC’s ‘Hailsham, Polegate to Eastbourne corridor ‘, from 10 years ago, predicted a 10% reduction in modal share for cars. This scenario is then used by developers, on that key route, to show the extra traffic, from their developments, will be offset by the modal shift this original report had predicted. The example used here is taken from the Transport Assessment for Hindsland in Willingdon. (see Tables 6.2 and 6.3)

Method of Travel – Currently (left) and with planned improvements (right)

Notice that the developers take current traffic data and then adjust to the new modal share. So that cars, including passengers, are down from 80% to 70% and this would suggest traffic levels will be lower. To compensate, for the lower private transport, there is an increase in bus trips from 4% to 9%. That is a 125% increase, alongside  an increase for cycling up 150%. But there has never been a demonstrable increase in either.

This general approach, to overstating modal shift, is also seen in Eastbourne, by developers, on schemes such as the Magistrates Court and TJ Hughes. The positive transport assessments, produced around higher levels of active travel, seem to satisfy both developers and councils. They do not alter the reality.

Now look at Black Robin Farm (SDNP/23/04238/FUL). Aecom ,in their transport review for Eastbourne Borough Council, provided a comprehensive analysis of transport options. Their algorithm produced –

The reality check is that for Eastbourne 5% of trips are by bus  and on the Downs nearer 10%. However there is no explanation as to how 50% Public Transport could ever be achieved. Plus in this scenario cycling at 4% would be an increase from an original estimate of 1,000 to 4,000 trips p.a. Cynics might think the data was to convince South Downs National Park that there would not be a high demand for car parking. Based on the  100,000 visitors predicted p.a.

Many of these models have shown to exaggerate the modal shift away from private cars. To provide reassurance, models need to be validated, to see how accurate they were. The Government’s Transport Analysis Guidance (TAG)  “provides an overview of good practice in planning the evaluation of transport interventions to ensure robust evidence can be collected about the difference that they are making in practice. It is intended to support evaluation planning and stronger business cases for a range of transport interventions in terms of mode, type of intervention” Model guidance from Govt

In summary we are asked to take on trust the ‘black box’ approach, that transport planners are using, when our lived experience would suggest something different. Perhaps now is the time to reassess the accuracy of the predictions. If you have doubts then make this clear in your comments for LTP4 and question them about their methodology

Paul Humphreys EEAN Transport Group

Should Strategies be Realistic?

How should local government present their plans for a greener future? Is it better for them to be realistic or else have a vision that, with only limited interventions, will not be achieved? Let’s look at transport but the same is applicable for other carbon strategies.

The various local government organisations, adopt different approaches, as to the strategies they produce. Transport for South East in their modelling, do not hide away from scenarios where active travel (buses, pedestrians and cycling) actually declines. Below is a projection for 2050 called ‘Our Route to Growth’. [Note the cycle logo includes pedestrians.] Following their recent consultation, TfSE agreed to slightly modify their Investment Plan. However the point is, their models are indicative of what may happen, and not necessarily what campaigners might like.

The more problematic approach is when local government, include in their plans, what you would like, but there is no past or future evidence that these will happen. As an example, there are repeated references to the reduction of cars in local borough and county plans. This is against the backdrop of East Sussex County Council predicting, in their A22 A2290 review,  an increase in traffic of 15% from now to  2039.

So in the new draft Eastbourne Local Plan, it refers to a 15% reduction in car journeys. This is extremely optimistic. As is elsewhere, a 10% modal shift from 70% trips by car to 60%. This is in the ‘Hailsham Polegate Eastbourne corridor’ and would be offset by a 150% increase in cycling, 125% in bus trips and 60% more walking. Even those who have little experience in transport, will realise, what a colossal task this would be. As background, there has never been a decrease locally in car trips. Plus cycling and bus trips have reduced over the last twenty years.

So what can be done to prevent unrealistic predictions. TfSE have a clear requirement to monitor and evaluate any targets. This could be used elsewhere, to hold any predictions to account, such as large reductions in car journeys.

In summary, campaigners should request that ‘over ambitious claims’, although they may initially be welcome, should have a realistic delivery plan behind them

Paul Humphreys EEAN – Transport Group, Bespoke, Cycle East Sussex