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This is a response from Herefordshire Sustainable Transport Group (HSTG) a campaigning organisation that advocates for clean and socially-just transport facilities in Herefordshire.

The proposals set out in the 'Decarbonising transport: setting the challenge' paper are a welcome step forward. However what is needed is a giant leap forward, (apologies to Neil Armstrong), and a totally new approach. The threats posed by climate change are manifestly real and have to be addressed with a degree of urgency and leadership not shown so far in UK government policy.

The ideas set out in the Decarbonising Transport paper are incremental and hobbled by business-as-usual vested interests. They will undoubtedly accelerate a reduction in greenhouse gas emissions, compared to current policy, but this will not be anywhere near fast enough to avoid the most serious consequences of climate change. In this case, “Winning slowly is the same as losing” – and it is no longer possible to solve the climate and ecological crisis using today’s systems.

Climate change policy on transport and across the economy/society needs to be recast to treat the problem as an emergency. Lessons can be taken from the response to the coronavirus pandemic, in particular:

  • Government identified the issue as of the highest priority and pledged to “do whatever it takes” to contain the problem. Legislation was enacted to provide the basis for emergency government interventions.

  • Largely effective efforts were made to communicate the issue to the public and to secure their commitment to accept very disruptive measures like lockdown, social distancing and the cessation of public events and hospitality.

  • Unprecedented levels of public financial support were made available to maintain an operational heath service and to avoid the most serious social and economic impacts.

  • Government accepted that policy had to be informed by science, and was flexible in adapting policy to changing circumstances and new evidence.

  • Government funded a crash research and development programme to develop solutions to the health crisis.

In short, Government intervention was applied in a manner consistent with the seriousness of the threat from the coronavirus pandemic. Tough choices had to be made and changes were pushed through in the public interest even when they were disruptive and unpopular for many. The same cannot be said for the approach taken to date on the climate crisis, or policies to decarbonise transport.

Strong interventions are required as a matter of urgency to cut all emissions, especially transport emissions where so little progress has been made. Unfortunately many of the extant plans and proposals are actually making things worse, in particular road building - which we return to later.

An overriding requirement is for the UK Government to manage the situation closely and favour direct interventions rather than continuing to be reliant on a lightly regulated market driven approach. Outsourcing such a crucial aspect of the UK’s future to commercial interests is no longer acceptable. The Committee on Climate Change must be empowered to set mandatory targets for emissions reductions; progress must be reported annually to Parliament and open to public scrutiny, with the Secretary of State and the Prime Minister taking responsibility for meeting the targets.

The system for appraising transport schemes must be brought up to date to give much higher weight to all environmental impacts including greenhouse gas emissions.

To ensure that no sources of emissions are ignored, the UK’s emissions inventory must be reset to include all sources, including international aviation and shipping.


A clear focus must be on cutting emissions deeply in the short term, rather than achieving a specific level of emissions at a distant date like 2050. What matters are cumulative emissions, and early cuts are of far greater value. That indicates we ought to strive to squeeze out emissions from the existing transport system in the immediate future, and not rely so heavily on technical changes that won’t necessarily be delivered or be taken up quickly - if at all.

As part of that we must recognise that transport emissions reductions won’t solely be gained from systems changes or technology upgrades, e.g. the type of engine in a car, but importantly they will arise from individual personal actions and choices. Steps to encourage or to incentivise ‘behaviour change’, or to mandate it, are largely absent from the proposals in the Decarbonising Transport paper. For example we would question why there is no intention to promote a public education campaign on eco-driving, or to encourage modal shift from planes to trains and from cars to active or public transport. Nor is there anything to persuade car owners to cut back on mileage, to buy smaller cars or to have their cars serviced properly.

Omissions from the discussion in the Decarbonising Transport paper that fall into this category include:

1. Reducing the speed limit on all roads including motorways to 60mph

It has been estimated that a combination of a 60mph limit – or 110km/h - plus smooth eco-driving could reduce car and van emissions by 10-12% ( There is reportedly public support for this - (Flash Eurobarometer Report, no. 312, Future of Transport) indicates that about two thirds of EU citizens are willing to compromise a car’s speed in order to reduce emissions. Public support is of course crucial, especially as it is clear that many car drivers break the existing speed limits - government would need to frame such a regulation very clearly in the context of emissions savings in the short term to address climate change, and to avoid further, perhaps more intrusive, measures like fuel rationing and restrictions on mileage driven. The subject of eco-driving should be given emphasis in the Highway Code and made a part of the driving test examination.

2. Re-structuring Vehicle Excise Duty to influence car usage as well as choice of car

The charging mechanism for road use should be based on distance travelled, time of day, location, and level of emissions and impact on the environment of the vehicle. In other word, road pricing. Variable, distance-based charging would reflect the impacts of individual journeys more accurately and would give stronger messages to motorists that car use is linked to climate change.

3. Increasing duty on road fuels to encourage motorists to conserve fuel and reduce emissions

For the tenth year running the March 2020 budget statement froze fuel duty rates. This is not only starving the exchequer of much needed income - the Institute for Fiscal Studies estimates the loss at £5.5billion a year since 2010-11 from failing to increase fuel duty in line with inflation – it also doesn’t incentivise better driver behaviour or journey planning to save fuel.

4. Improving the fuel efficiency of new petrol and diesel cars

EU regulations intended to drive down average emissions of new cars have not been effective enough. Cars have got bigger and heavier, offsetting gains in engine efficiency. With full control of legislation on car efficiency from 2021, the UK should require a faster decline in average emissions per km., over the period up to 2030 and require car manufacturers to build in systems which record the real-life mpg economy of new cars, and have that reported in the annual MOT test as an advisory for the owner.

5. Re-structuring Air Passenger Duty to curb demand for flights and to incentivise more efficient use of planes

The environmental impact of flying is not fully costed. There is public acceptance of this - passengers are prepared to fund (rather questionable) privately operated carbon offsetting schemes. Instead passengers should pay extra into the exchequer through APD where the money can be more accurately targeted at measures to genuinely offset emissions. A base level of APD should be levied on a per-plane basis rather than on a per-passenger basis to incentivise airlines to achieve higher loading factors. A supplementary APD should be levied on passengers flying above a threshold number of times per year to moderate demand.

6. Taxing Aviation fuel and applying VAT to flight tickets to moderate demand for flying.

Incentivising a modal shift from flying to rail particularly for domestic trips must be part of the effort to decarbonise transport. An estimate in 2010 concluded that £12.4 billion was spent on air travel in the UK to all destinations. Applying the current VAT rate of 20 per cent that would raise £2.48 billion. Added together, if VAT and fuel duty were applied to the aviation industry, a total of around £10 billion would be raised.

7. Banning the practice of ‘fuel tankering’ by airlines

This practice is used by airlines to benefit from differential fuel prices across countries: in order to reduce the need to refuel, or avoid refuelling altogether at the flight destination, aircraft carry more fuel than actually required to reach their destination. Researchers have concluded that one in five of all European airlines' flights involves some element of fuel tankering, and it was estimated that in 2018 British Airways generated an additional 18,000 tonnes of CO2e through this practice. Eurocontrol, the body which coordinates air traffic control for Europe, has calculated that tankering in Europe resulted in 286,000 tonnes of extra fuel being burnt every year, and the emission of an additional 901,000 tonnes of carbon dioxide. (

8. Maintaining and improving local bus service subsidies

Rural bus services in particular are declining, and many routes are just hanging on but with very inadequate levels of service. This discourages patronage and as a consequence revenues fall. At the very least, subsidised services must be preserved and not allowed to decline further. Preferably more of the currently non-subsidised services should be given financial support to stop them failing. Otherwise car-based trips, emissions and possibly car ownership will increase.

9. Providing higher levels of financial support for rail travel and new stations

Travel by rail should be encouraged in order to reduce car and plane use for journeys within the UK. Re-opening old lines, adding new stations and keeping fares down should be a part of the decarbonisation plan. A new round (4) of The New Stations Fund should be opened without delay and with increased sums on offer.

10. Ban pavement parking

This is already banned in London and now in Scotland but not in England

Pavement parking is a huge free gift to car drivers, it deters walking trips, it undermines Park and Ride, and it encourages car drivers to search around towns and cities looking for free car parking (meaning more miles driven, more air pollution, more carbon). It is also a serious hindrance to pedestrians, disproportionately impacting older people, those with a disability and parents with young children.

11. 20mph speed limit for urban areas

Introduce and enforce a 20mph speed limit on all streets and roads where people live. This would give a huge boost to walking and cycling as well as protecting children and encouraging walk/cycle trips to schools and this contributes to decarbonisation

20mph is recommended by the World Health Organisation and endorsed by 1700 delegates at the Stockholm conference in Feb this year:

Stockholm Declaration

“Focus on speed management, including the strengthening of law enforcement to prevent speeding and mandate a maximum road travel speed of 30 km/h in areas where vulnerable road users and vehicles mix in a frequent and planned manner, except where strong evidence exists that higher speeds are safe, noting that efforts to reduce speed in general will have a beneficial impact on air quality and climate change as well as being vital to reduce road traffic deaths and injuries;”

There are undoubtedly many further actions and policy changes that could be taken forward to trim emissions, allowing us to make much needed progress in advance of the potential bigger wins from new technology such as EVs or hydrogen-fuelled alternatives. More emphasis should be given to work and school travel plans, car sharing schemes and car club.

The Decarbonising Transport paper does recognise that modal shift from car to bike would make a valuable contribution to emissions reduction. E-bikes can extend the viable distance for cycle commuting and could encourage people who are not ultra-fit to take up cycling. Government could quickly stimulate a rapid growth in cycling by providing grants for e-bike purchase.


1. Road building. The most obvious example is the national programmes of road building, which will generate considerable greenhouse gas emissions from construction; is very likely to lead to higher operational emissions from vehicle travelling further and at higher speeds; and is likely to mean an increase in trips and distance driven, and therefore emissions, because of the induced traffic effect.

Given the significant carbon debt created by the construction of all major infrastructure projects, and the implausibility of construction processes becoming zero carbon in the near future, if at all, it is imperative that the transport appraisal methodology is adjusted accordingly.

In the 2015 report commissioned by the Committee on Climate Change, University of Leeds proposed a methodology to estimate the carbon footprint of major infrastructure construction. The rule of thumb is approximately 1 kgCO2e per £ of infrastructure spend - after wage costs are deducted. The authors used a figure of 42% for wage costs for road schemes, so for the Majors road programme costed at £6.5bn the estimated carbon footprint is about 2.5 million tonnes. For RIS2 at a construction cost of £14bn the footprint estimate is over 5 million tonnes.

2. HS2. The developer’s own assessment shows that this project will only become ‘carbon neutral’ by the end of the century. And that estimate makes very optimistic assumptions about modal shift from other modes to rail, particularly from flying. The project should be paused and re-appraised taking account of the likely long-term effects of the coronavirus pandemic, particularly the uptake of on-line alternatives to business travel.

We note that the most recent report from Infrastructure and Projects Authority said about HS2: “Successful delivery of the project appears to be unachievable. There are major issues with project definition, schedule, budget, quality and/or benefits delivery, which at this stage do not appear to be manageable or resolvable. The project may need re-scoping and/or its overall viability reassessed.”


1. Bring forward the end of petrol / diesel cars

To continue the theme of making emissions reductions as early as possible, we suggest that the government set 2032 at the latest for the sale of new petrol, diesel and hybrid vehicles AND the import of second hand vehicles of this type.

Additionally the use of such vehicles should be banned from 2040. Unless use is also banned well before 2050 many such vehicles will continue to be on the roads in the decade up to 2050 (a plausible lifetime for new cars is 20 years especially for owners who are not attracted to the alternatives or who find them less practical, or who simply can't afford anything other than a second hand cheap vehicle).

The move to phase out fossil fuelled cars should not just focus on replacing them with electric or hydrogen powered cars, there must be a parallel and far greater effort to reduce the number of cars on the road by significantly improving public transport and making active travel more viable and attractive. Town planning has a contribution to make too.

2. Town Planning

Development control should be strengthened so that large housing schemes are only built if they have effective - not token - arrangements for public transport and active travel to avoid car-dependency. Communities should be made more local so that more essential facilities are accessible by short journeys able to be made without using a car.

Transport for New Homes' charter makes the point very well.

Carlos Moreno’s ideas on hyper urban proximity – the “15 minute city” are also very apposite and would help reduce transport carbon emissions and social cohesion. For example, “It is therefore a question of bringing the demand of the inhabitants closer to the offer that is proposed to them, of ensuring functional diversity by developing social, economic and cultural interactions, of ensuring substantial densification, while increasing spaces for public meetings and mixing, of optimising the range of services via digital technology and collaborative and sharing models, of turning the streets into spaces of carbon-free mobility by walking or cycling, of reinventing new hyper-proximities, of rediscovering biodiversity where we live by encouraging short circuits”

See also Prof John Whitelegg’s 2016 book “Mobility” arguing that society has to ditch its attachment to forever moving further and faster in the pursuit of ‘progress’.

3. Rail electrification

Government must restart the electrification programme, and get on with decarbonising rail lines across the country. The scale and pace of rail electrification must increase to drive down carbon emissions and air pollution in towns and cities. Rail is currently the greenest major form of transport, but will lose that leading position unless the Government commits to a rolling programme of electrification. Funds should be ring-fenced under a long-term settlement to ensure rapid progress can be made.

Rail freight is already the environmental choice for freight movement. Electrification is the only proven technology to decarbonise rail freight, and Government must start a rolling programme to electrify key routes, supporting private sector investment in new locomotives.

4. Light Rail

Increase investment in and development of ultra-light tram systems for small cities and towns. This is especially the case where routes are already available and in public ownership, e.g. Hereford. This demonstrates the effective and sustainable use of existing resources. This was highlighted in the 2019 Department for Transport call for evidence on the opportunities available to introduce new Light Rail Systems or other rapid transit solutions into towns and cities in England.

5. Deliver on the commitment to improve bus services

This government’s stated ambition is to ‘secure a long term sustained improvement in bus services’ and it has created a National Bus Strategy for England. That strategy now needs deep and immediate strengthening if the bus is to continue to play a vital part in the move to decarbonise transport.

Such strengthening demands a continuous high level of financial support and a removal of the restraints to developing an integrated network imposed by the 1986 Deregulation Act. Frequency of service and fares are the two most important elements in encouraging people to use buses. Timetabling needs to adjust to new work patterns as the standard 9-5 working day becomes less common. Evening and weekend services are crucial to retain customers and avoid them ‘giving up ‘ and buying a car.

Local authorities should be requested to develop their own local bus strategies and in rural areas to experiment with a mix of conventional and demand responsive services. A continuous publicity campaign to encourage bus service use is desperately needed.

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