Response to Consultation on Exemption Regulations Under Section 54 of the Transport (Scotland) Act 2001 by The Scottish Policy Group of The Institute of Logistics and Transport

1. Introduction.
This response paper sets out the Institute of Logistics and Transport's (ILT) comments on the Scottish Executive's consultation on their proposed exemption regulations under Section 54 of the Transport (Scotland) Act 2001. The paper starts by discussing the proposed background policy criteria and also provides a commentary on the groups highlighted in the consultation document. This is then followed by responses to each of the questions raised in Annex A of the consultation document. The paper then concludes with some general observations which the ILT believes are also worth considering.

2. Policy Criteria.
In general the ILT agrees in principle with the Scottish Ministers policy criteria for charging schemes, however the last criteria ("that a range of public transport improvements are in place before charging is introduced, with further improvements to follow") suggests charging schemes will only work if enhancements to public transport are provided first. In certain areas it is not always necessary or indeed feasible to have improvements to public transport prior to introducing charges. The success of the London charging system, among others across the world, have shown dramatic results are achievable without such preliminary measures. Furthermore, the criteria suggest only public transport improvements should be introduced, and does not mention other types of improvements including traffic calming and control.

3. Schedule of Vehicles Exempt from Charges
In general, the vehicles to be exempt from paying charges described in the Schedule are reasonable and suitable candidates. However, care is needed to ensure this does not become a prescriptive list of vehicle categories and trip purposes which must be exempted. Clearly, the exact nature and form of exempt vehicles will depend on the characteristics of the area for which charges are being proposed. A 'one-size fits all' policy may be wholly inappropriate to allow for the variations and differences of areas across Scotland. The ILT would therefore suggest this Schedule be the absolute minimum list of exemptions (and be explained as being this) with suitable allowances for Local Authorities to add to the list to take cognisance of their local geographical and demographical environments (subject to providing an appropriate explanation and evidence to support their requests to expand the list).

4. Comments on Question 1.
The ILT believes there are additional vehicles which should be included in the national minimum list of exemptions from road user charging schemes. These are set out below along with their justifications and likely impacts.

What should they be?

- licensed taxis and hire cars;
- licensed bus services including inter-urban coaches operating to an advertised timetable; and
- scheduled services (e.g. contracted school transport, dial-a-ride, etc).

The above would be subject to meeting environmental impact standards as may be identified by the local authority (e.g. emissions, size of vehicle, etc).

Why should they be exempt?

These are part of the public transport system.

What might be the impacts of this?

Very little impacts on traffic levels, congestion, noise and emissions would occur because of the above exemptions. Greater use of these additional vehicles would result in less use of private cars, the main cause of congestion.

5. Comments on Question 2.
The ILT would suggest there are groups of people, classes of vehicles and types of activity that should not be exempt. These are outlined below.

What should they be?

- private cars, except those identified above, and those defined by the local authority were special considerations apply (e.g. doctors, residents of sheltered housing, etc).

Why should they not be exempt?

The purpose of road user charging is to reduce congestion and also encourage travellers to change their travel behaviour including change mode, the time of travel and/or reconsider the need to make their journey. Figures supplied in the Transport White Paper in defence of both road user charging and workplace parking levies indicated that 30% of car journeys are unnecessary and that private cars are the main cause of traffic congestion.

What might the impacts of this be?

Private cars are the largest single mode of transport and cause of traffic congestion, noise and emissions. The National Economic Research Association (NERA) and the Confederation of British Industry (CBI) have estimated congestion to cost between £7billion and £15billion per annum (at early 1990's prices and congestion levels), borne by the general public and commerce. Clearly, any reductions in traffic congestion would have a significant positive impact to this situation and since private cars are the largest cause of congestion targeting them would have the single biggest affect on alleviating the problem.

6. Other Comments.
The ILT would highlight the fact that the list of exemptions might be different at various locations and indeed at different times of the day. It might be necessary to target charges using price differentials for different modes and travel times in addition to daily and seasonable variations.

7. Concluding Remarks.
This response paper has summarise the ILT's comments on the Scottish Executive's consultation on exemption regulations under Section 54 of the Transport (Scotland) Act 2001. The ILT is grateful for the opportunity to express its views on this important legislation for Scotland's transport strategy and would urge the Government to expedite the proposals as quickly as possible and encourage and support Local Authorities to implement appropriate road user charging systems for those areas where such measures would clearly improve the detrimental affects of excessive traffic levels. Every effort must be made to avoid unnecessary delays in bringing forward plans to deliver charging systems to the most congested parts of Scotland.