Oxford Civic Society

Response to Oxfordshire County Council

draft Local Transport Plan Policies

February 2010

General comments

As drafted, the policies discuss travel and transport as if they were a set of discrete and disconnected activities, whereas integrated travel – the seamless journey – depends on efficient interface between individual transport modes.

Oxfordshire County Council (OCC) already has extensive policies to address many of the government’s five overarching transport goals – policy T1 of the County Structure Plan, for example, addresses ‘Sustainable Travel’. There are also policies for travel and transport which were developed as part of previous Local Transport Plans. Clarification is needed, as to how the draft LTP3 policies relate to the county council’s existing policies, and to its adopted objectives for LTP3.

The objectives that the county council has adopted for the LTP3 plan period support the government’s five goals. Some aspects of the adopted objectives are however hardly touched upon in the draft policies, and it is difficult to imagine how the policies can help the county council achieve many of its objectives.

Policies whose life span is expected to be 20 years need to address forthcoming challenges – not just an increase in the population of Oxford and Oxfordshire, but carbon reduction, increased energy prices and instability in energy supplies, as well as an increasingly elderly population – all these need to be addressed, along with opportunities to manage demand, reduce the need to travel, and to enable electronic communications via the internet to make information widely available and enable people to make better informed choices. Furthermore, the policies need to be sufficiently adaptable to enable travel modes like light rail, electric traction and suchlike to make a contribution when appropriate in the future.

A number of the policies refer to ‘new developments’. They will represent only a small proportion of the built environment in Oxfordshire, and the policies need to be applicable to the needs of existing communities as much as to new developments.

It is surprising to find policies on ‘Disability’ buried so deep within the policies, especially given the strong legislation that underpins inclusivity in the travel environment.

Some of the ‘policies’, we felt were really statements of technical processes that would be adopted. It would be useful to separate these from policies, perhaps to a supporting section describing the processes and tools that would be used to help deliver the policies.

The Society recommends that specific policies are developed, to address the challenges to the ways we travel that will come from climate change and energy supply issues. It is also suggested that the policies are re-shaped to better  address transport integration and traveller choice, and to ensure that travel opportunities are available to the whole population including the young and the old. Because of the considerable dominance that freight vehicles can exhibit, additional policies should be written to address the challenges of managing and providing for freight vehicles.

The policies will demand new skills and new ways of thinking from county council staff and from their consultants. Within the business processes, should be the training and retraining of staff to equip them to deliver the policies of LTP3. Policy D2 refers to

OCC providing disability awareness training for all appropriate staff. The same principle should be extended to staff briefed with designing any facility which involves provision for people travelling sustainably, especially people on foot and on bicycles.

Lastly, a glossary is needed, to ensure that all readers are clear about what specific terms mean; as well as giving fuller descriptions of the technical processes to be adopted.

Comments on the Policy sections 

We have prefaced each section with our general remarks, followed by discussion of the section’s individual policies.

1. Network Management  

As written, the emphasis appears to be on accepting growth in motorised traffic as being the inevitable and only outcome of increasing population. There are planning policies and travel demand techniques that can address the way we travel, and the reallocation of road space away from mechanised vehicles needs to be described.

Additional Network Management policies are required – addressing the reduction of motor traffic volumes by reducing the need to travel, by enabling travellers to have real choice of walking, cycling and public transport, by reducing single-occupancy car use, e.g. through road user charging, workplace parking levies etc., and by re-allocating road space to non-motorised travellers.

Policy NM1. The policy does not address non-highway travel such as on off-road cycle paths, Greenways and suchlike. We suggest enhancement to read ‘…manage the use of the road networks efficiently to reduce congestion and minimise disruption and delays to the travelling public’.

Policy NM2. This is more a mechanism than a policy, and it makes no reference to where it will be provided. The wording ‘and available’ should be added so that the statement reads ‘…timely, accurate, consistent and readily available’.

Policy NM3. This goes without saying – but it needs to specifically embrace the fact that vulnerable road users’ needs will be incorporated into all junctions and crossings, including roundabouts. It should refer to the government’s published road user hierarchy. The priorities in assessing ‘effectiveness’ need to be stated.

Policy NM4. This is an operational  statement rather than a policy and should be moved into a section containing such statements.

2. Highways Asset Management  

As written this excludes off-road facilities, and needs to embrace those.

Policy HAMP1. This is an operational  statement rather than a policy and should be moved into a section containing such statements. It needs clarification so as to read (e.g.) ‘…maintaining those parts of Oxfordshire's transport networks for which it is responsible’.

Policy HAMP2. This could usefully be described in a glossary. The balance to be exercised between the two parts, value-added and community-led schemes, needs to be described

Policy HAMP3. . This is an operational statement rather than a policy and should be moved into a section containing such statements. It could usefully be related to the section on Waterways. See comments under that section on maintenance of waterside paths and tracks.

3. Highway Network Development

To reflect the multi-modal function of travel systems, the section should be re-titled ‘Transport and Travel Network Development’. The section needs to embrace that in all instances the county council will first look to measures to reduce the demands made by motorised vehicles on the road network.

A statement is also needed at some point, that the county council will consider and promote alternatives that facilitate choice in the ways people travel.

A further statement should be provided, that the county council will work with other planning and transport authorities to reduce the need for long distance travel (and hence reduce the need for network development and contribute to reducing congestion and CO2).

Policy ND1. The policy needs to specify what is meant by a ‘growing county’. The term is too vague to enable meaningful policies to be directed towards it. The relationship between road and rail networks also needs to be acknowledged.

Policy ND2. The policy should be enhanced to embrace the priorities expressed within the government’s published road user hierarchy (as in the Manual for Streets). The policy should be prefaced by an intention to consider and promote alternatives that widen the range of desirable travel options before considering whether network development is required.

4. Public Transport Services 

As framed, this section is about bus services. The section on rail services should be included here. The section also needs to acknowledge that people need to get to and from public transport, and to relate to policies for access to bus stops and rail stations.

The section makes no mention of issues about which the Society has made previous submissions, specifically on:

• Bus service connectivity in Oxford
• Introduction and extension of orbital city bus services
• Improved connectivity between bus and rail services

Policy PTS1. The policy needs to better address the county council’s role in identifying access needs in different communities and developing solutions appropriate to the communities. Buses are not the only potential provision – car sharing , taxis, car clubs, on-demand services – all need to be embraced in the policy.

Policy PTS2. The policy needs to address the development of mixed mode journeys – for example by enabling bicycles to be parked at bus stops, and carried by bus at off-peak times. The policy also needs to address broader issues of accessibility; for example, by determining the times of day and days of week on which certain standards will be provided. It needs to recognise that standards may apply at different times and on different days. An ‘accessibility standard’ should be developed, against which each community’s needs can be assessed.

Policy PTS3. The strategy should include rail etc.- a Public Transport Services Funding Strategy.

Policy PTS4. Needs expanding to include rail; ‘OCC will support the development of a network of community transport schemes to complement and supplement the county's network of scheduled bus and rail services’. Examples of what is meant by ‘community transport schemes are needed, possibly described in a glossary.

Policy PTS5. As with other policies, the term ‘high quality’ is meaningless without a definition of what the term means. All public transport should be ‘high quality’. The policy should apply to existing as well as new developments.

Policy PTS6. Reword, to read ‘OCC will work with public transport operators to introduce improvements to ticketing arrangements and inter availability to make travel easier, particularly where these reduce boarding times.’

Policy PTS7. Reword, to read ‘OCC will work with bus operators and other partners to ensure that good quality information is readily and publicly available and that this contributes to increasing the attractiveness and reducing the cost of public transport.’

Policy PTS8. Policy should be expanded to include wider opportunities for multi-modal journeys via Park& Ride, e.g. parking and cycling.

Policy PTS9. Policy needs to define ‘coach services’; to include accessibility standards for supported coach services, e.g. to eliminate the steep stairs experienced on many coaches; and to embrace sustainable options for access to/from coach services.

Policy PTS10. Policy needs to clarify issues surrounding workers’, patients’, visitors’ access to health service facilities, including local surgeries. Issues such as convenient walking and cycling to surgeries, cycle parking at surgeries, as well as bus access to surgeries, need to be included in the policy.

Policy PTS11. Reword to read ‘OCC will encourage the use of public transport vehicles that meet high emissions standards and low carbon footprints.’

5. Public Transport Infrastructure

As with the above section, the focus in the draft policies is on bus service infrastructure, and should be broadened to address matters such as access to rail stations by all modes.

Policy PTI1. The policy does not at present discuss integration with other transport modes. There are also potential policy conflicts – transport policy should be about the movement of people and goods – this is not the same as vehicles. Conflicts will emerge when the needs of people on foot or on cycles need to be balanced against the needs of people on public transport.

Policy PTI2. We suggest rewording, ‘High quality, welcoming infrastructure for public transport passengers at key interchanges, Park & Ride sites, (delete ‘main’) railway stations and other places where people (delete ‘might’) change from one mode of transport will be created.

Policy PTI3.We suggest rewording, ‘Up-to-date, comprehensive information about public transport services provided by all operators, and links to ticketing technology …’

Policy PTI4. The policy should be widened to embrace redevelopments and the ‘retro-fitting’ of ‘real choice’ into the present built environment.

6. Rail 

Rail is public transport, and should be included in the Public Transport Services and Infrastructure sections as appropriate.

The government has recently announced the requirement for rail service franchises to include station access plans, and the policies should reflect this.

The Society has commented in the past about the need for improved access to/from Oxford station. Station access (especially by carbon-free modes) needs to be specifically addressed within the policies.

The policies need to embrace interchange between rail and other modes for multi-modal journeys (e.g. via the proposed Water Eaton station) and to support new services – East West Rail to Milton Keynes and beyond; re-opening of the line to Witney as recently advocated by the Association of Train Operating Companies.

Policy R1. This policy should include considering re-opening lines that are at present closed.

Policy R2. A description of a Quality Rail Partnership; the difference between that and a Community Rail Partnership; and why Oxfordshire can only support a Quality Partnership, would be helpful.

Policy R3. Rewording suggested, ‘OCC will seek opportunities to integrate rail services and improvements with other local transport improvements to increase the use of rail, including for freight traffic.’

Policy R4. Rewording suggested, to include electrification of other lines (e.g. to permit through freight movements between Southampton and the midlands).

7. Cycling

Cycling is not a stand-alone method of travelling. It is used in conjunction with other ways of travelling, and the policies should acknowledge this. Cycling is already popular in Oxford and promotion of cycling, by itself and in conjunction with other modes, will enable mode shift to take place.

The Society recognises that cycling in Oxford will perhaps always be more popular than elsewhere in Oxfordshire, and suggests that specific policies to reflect this should be developed for Oxford.

A ‘dual network’ of cycle routes has already been proposed for Oxford, to address the needs of people who are inexperienced cyclists, as well as those who are experienced. The policies should support provision of this network.

Policies should also address the needs for training for members of the public who wish to increase their cycling skills.

We suggest the following additional policies:

‘ OCC will make cycling, together with increased use of public transport, one of its top transport priorities for Oxford.’

‘ OCC will ensure that safe and continuous cycle lanes of standard width are designated or created on all major routes used by cyclists, with clear indications of priorities at all intersections.’

‘OCC will increase the provision of parking facilities of a variety of standards for bicycles, to meet demand.’

Policy CY1. This is not a policy. A more meaningful statement, for Oxford at least, would be that schemes previously approved but shelved would be implemented.

Policy CY2. Suggested rewording to reflect the potential to produce modal shift for part if not all of a journey.

Policy CY3. The policy should be repeated for people on foot, in the ‘Walking’ section.

Policy CY4. The wording needs to be simplified to ‘OCC will promote cycling’.

Policy CY5. The focus of the county council should be on facilitating as well as encouraging greater levels of cycling.

8. Walking

Walking is the glue that joins our journeys together. A seamless journey depends on the ability to walk to the bus, the train, the car park, the cycle rack. Policies should reflect the important role of walking as connections in trips using mechanised modes, as well as walking for the whole journey.

Policy W1. To describe walking as a ‘fun’ mode is to devalue it. We suggest removing this description, replacing it with. ‘OCC will promote walking for its efficiency, as a link to vehicular travel, and as a healthy carbon-free method of travelling’.

Policy W2. Supported.

Policy W3. This is a business process and not a policy.

Policy W4. No comment.

9. Road Safety 

Policies which require the vulnerable road user to act to avert the threat of injury from motor vehicles are not consistent with the policies which saw 20mph limits introduced across Oxford. Additional policy is required that recognises the benefits of extending 20mph speed limits to Oxford’s bus routes, being where the interaction between vulnerable road users and cumbersome large vehicles is mostly to be found.

Policy RS1. This is a business process and not a policy.

Policy RS2. This is a business process and not a policy.

Policy RS3. This is a business process and not a policy. The use of the word ‘accident’ should be avoided.

10. Motorcycling & Motorcycle Safety 

Motorcycling in the city can be quite different from motorcycling elsewhere in the county. We suggest that this be acknowledged in the policies; it is doubtful whether it is wise to promote Oxford as safe and welcoming to motorcycles. In the city there are issues surrounding motorcycle parking, as well as the riding of motorcycles.

There is inconsistency in the wording of the two draft policies, between promoting the county as ‘safe and welcoming’, and a focus on reducing the current high casualty rate for motorcyclists.

Policy MCS1. No further comment.

Policy MCS2. No further comment.

11. Travel Planning 

The policy on reducing car use needs to be on reducing the wasteful use of cars (e.g. by addressing the single-occupant car), and on the counter-productive effects of congestion caused by their use, and not be on addressing a particular journey type.

Policy TP1. We suggest it is right to address congestion around schools, but that this is not necessarily addressed by attempting to modify the ‘school run’ in isolation from other factors.

Policy TP2. We suggest extending the policy so as to include personalised travel planning, as used in the Sustainable Travel Towns to achieve modal shift.

Policy TP3. No comment.

12. Parking 

An omission from this section is any treatment of cycle parking. This underscores the need for a glossary, as well as the need to provide policies on cycle parking, as well as on motorcycle parking.

There also needs to be a policy to limit on-street car parking in any area to levels that will not result in pavements being appropriated for car parking. This needs to be backed up by support for car sharing clubs and a policy to provide reserved or preferential on-street parking spaces for car club vehicles.

Policy P1. It is unclear what this means. There should be a policy that in Oxford city centre OCC will restrict on-street car parking as a means to manage car journeys.

Policy P2. No comment other than to request that off-street car parking should be limited in Oxford city centre. See comments elsewhere on a policy for CPZ’s across Oxford.

Policy P3. A policy to introduce consistent and complementary controlled motor vehicle parking zones across Oxford is needed. The policy makes no mention of consulting the wide range of street users, including those who pass along the street on foot, at the early stages of scheme design.

13. Street Environment and the Public Realm 

The policies would be usefully strengthened by encouraging community-led, low cost street design changes.

An additional policy is requested, committing OCC to introducing more shared spaces (using concepts like ‘Home Zones’ and those recommended in the Manual for Streets) in residential areas.

Policy SEPR1. Supported

Policy SEPR2. Supported

Policy SEPR3 . This is a business process rather than a policy.

14. Disability 

It is surprising to find this subject ‘buried’ within the document. Inclusive design is at the forefront of design principles for the built environment, and the Disability Discrimination Act and Disability Equality Duty place specific obligations on public bodies in respect of inclusive design. We suggest that these policies should be stated at the front of the document where the principles of inclusive design can underpin other policies.

Policy D1. Supported.

Policy D2. Supported – needs extending to those staff and consultants working on schemes that affect people travelling sustainably.

15. Freight and Distribution 

In view of the potential for freight vehicles to dominate the transport environment, policies for the highway network should address this class of motor vehicle separately.

Policy FD1. Suggested that the policy be modified to read ‘OCC will support moves to facilitate the transfer of freight movements from roads to rail or water, including the development of new and existing intermodal exchanges, where this would not cause unacceptable local problems.’

Policy FD2. Supported.

Policy FD3. No comment.

Policy FD4. No comment.

Policy FD5. Suggested that the policy be modified to read ‘OCC will not support any increase in overall permitted size or weight of lorries, and will take action to encourage the use of smaller vehicles making deliveries in town centres and in residential areas.’

16. Public Rights of Way and access to natural green space 

The PROW policies are supported. Consideration should be given to enabling people from Oxford to access the PROW network without having to use cars.

17. Taxis and Private Hire Vehicles 

Taxis are major polluters. The county council should pursue active policies that reduce the noise and air pollution, as well as the carbon emissions from taxis.

Taxis and conventional public transport - bus and rail – have complementary roles in enabling journeys to be made. Policies need to reflect those roles and enable linkages between taxis and public transport to be improved. The pollution caused by taxis accessing Oxford station along congested streets should be addressed by a suitable policy.

Policy TPHV1. Needs to recognise that taxis produce noise and air pollution.

Policy TPHV2. We suggest rewording to expand policy, ‘OCC will liaise with licensing authorities on the provision of taxi rank capacity and minimising conflicts between taxis, public transport, cyclists and pedestrians’.

Policy TPHV3. No comment.

Policy TPHV4. Why restrict this to taxis? It is equally applicable to other public transport.

18. Air Travel 

OCC should be encouraging individuals and groups to make journeys by sustainable modes, and the policy should be extended through all sections of the LTP3 policies.

Policy AT1. It is not clear whether it is within OCC’s remit to single out air travellers, when the draft policies do not address all other journeys. Also, we suggest rewording the policy, ‘OCC will encourage individuals to make journeys by sustainable modes, particularly for (delete ‘domestic’) trips within mainland Britain and to/from western Europe, rather than air travel.

Policy AT2. There should be no increase in aircraft noise and pollution over Oxford.

Policy AT3. Supported - but who are OCC’s ‘aviation partners’?  We suggest expanding the policy to read ‘… to reduce airborne pollutants, including carbon dioxide and noise’.

Policy AT4. No comment.

Policy AT5. ‘OCC will promote the use of more sustainable transport modes to access air travel’. As with AT1, why limit this policy only to air travel? Promotion of sustainable travel should underpin all LTP3 policies.

19. Waterways

There appears to be potential for conflict between development of waterways for freight, and their development for recreation and leisure. The policies need to address such potential conflicts.

There is also a need to confirm standards for maintenance and provision of recreational footpaths and cycle tracks beside waterways. Usable surfaces are an essential requirement for paths and tracks in water-side environments.

Policy WW1. No comment – other than to ask whether this is a practical policy.

Policy WW2. No comment other than to ask, why only for waterway schemes? Could not funding be sought for rail development schemes?

Policy WW3. No comment except to ask, why only for waterway schemes? Could not OCC support strategies and initiatives that help to tackle crime on the county's travel and transport networks?

Policy WW4. Should this not address the maintenance of waterways (river and canal) towpaths?

Oxford Civic Society

February 2010