Although there appears to us to be a lack of ambition and clarity of vision, the document does contain many commendable aspirations, several of which are supported in substantive proposals. For example, we understand the need for an Earl Shilton by-pass whether or not traffic increases from its present levels (2.73), also the Melton Mowbray By-Pass which will bring developer funding (4.205). We support the way in which several of the most serious Air Quality black spots are addressed and the further focus on our improving road safety record. We also support the projects with the Highways Agency on Kegworth and at the A46 at Syston. We also support the Leicester Bus Corridors (4.41) where they will contribute to improvements in air quality and reductions in traffic. Some of the proposals have benefits on several measures, such as the LITS scheme which solves Air Quality, Traffic Impact and Road Safety problems as well as meeting economic objectives and hopefully enhancing public transport provision. Yet it is notable in the text how the structure of the Plan breaks up these complimentary objectives so that multiple benefits are seldom apparent. Perhaps this can be corrected in the final Plan.

Accepting the positive, the purpose of this report is to highlight what we see as problems in the Plan, which has to meet the high aspirations of Leicestershire people.

We start with the declared aim, supported by all stakeholders to reduce congestion. This is further refined by Policy 44 of our Regional Spatial Strategy (RSS8) [see Appendix 1] which requires traffic reduction and in that respect we fail comprensibly. The "predict and provide" approach was abandoned comprehensively more than 10 years ago because by building more roads we simply created more traffic releasing a spiral of increased traffic and very heavy costs. The call for a Kibworth by-pass, occasioned by increased traffic on that A6 route, is evidence of this. It is apparent to all serious practioners that traffic reduction is essential to reduce both congestion, air pollution and carbon targets

The approach of Draft Provisional LTP2 offers very few credible alternatives to car use but instead largely addresses congestion through road network improvements. Aspirations for increased use of other modes are insufficiently supported by proposals.

Air Quality, the Plan says, will improve by about 3% a year in reduced NO₂ levels despite a typical annual growth of around 2% a year in traffic (2.31). In the East Midlands, however, latest figures (EMRA State of the Region Report) indicate recent annual growth of over 3% vehicle kms per year. With the cost of motoring relative to earlier years being low, the increasing car ownership, and without measures to limit traffic, this seems a conservative estimate.

Matters become worse if new homes are added to the equation. Each Plan year, LTP2 tells us that traffic on Leicestershire roads will increase by 21,000 vehicle movements generated by new house building. The effect may be mitigated by focusing these new homes on built up areas, yet these are the very areas which are most congested. this has not been taken into account in traffic growth projections.

So a major concern is:

Both the indicators on congestion (3.75) were absent from the scrutiny edition of the Plan. It is difficult to see how an improvement can be effected in Central Leicestershire by measures proposed, although the second Indicator should show a considerable improvement in traffic flow with the LITS project.

Greater linkages should be made with Local Plans and emerging LDFs. of increasing development is occurring or planned in the Bardon and Coalville area, which requires north/south traffic relief. City fringe areas such as Oadby, Wigston, Birstall, Glen Parva and Glenfield are also going to require attention in the Plan period.

Traffic network improvements on Central Leicestershire and elsewhere in Leicestershire are welcome but in the longer term run the risk of opening up latent demand to fill the capacity created. In that respect they are temporary solutions which, like the discredited approach of "predict and provide" can end up creating more traffic, more pollution, more congestion and lost time in tackling the root problems.

There is an absence of work in the Plan on cross boundary connections and an over-emphasis on bus against other quality modes of public transport. Given the proposals, bus and cycle output indicators are highly optimistic. In the case of cycling it is very difficult to identify any measures in the Plan that will begin to increase usage from its present static position without vigorous promotion. Bus passenger figures are reliant upon Quality Bus Partnerships and we believe that the advantages of Statutory QBPs should be addressed. Bus Partnerships should be established in Coalville, Melton and Market Harborough.

The age and quality of bus fleets has declined since 1994 and it will require partnership working of the highest calibre to reverse this.

On rail transport we support the integration of the present Ivanhoe route into the main network as long as the service is not truncated. Stations at Blaby, Thurmaston, East Goscote and Kibworth are supported in line with the policy of integration. The future of South Wigston station should be defended.

On Ivanhoe Stage 2: National Forest Line Leicester to Burton/Trent (4.33), we must remember that the MultiModal study for this region supported greater use of rail and we must promote and build partnerships to continually advance the case. There is no vision of using economic growth as a factor for National Forest Line; but it is also for essential improvements to reduce poverty, promote inclusion and develop a more flexible labour market.

Great hopes are placed on decreasing traffic on radial routes into the city with the third major Park and Ride site (4.35). However, no site is identified and it is unclear whether, especially with past abortive experiences, this is realisable in the timescale of the plan if Aylestone Fields is not available.

There is developing evidence that large Park and Ride sites do not produce the overall traffic reduction expected and, where congestion is reduced new traffic is ready to take its place. Surveys have suggested that they encourage car use in preference to through journeys on bus or train. Crucially it is unclear what level of subsidy would be applied to the service and what affect the associated bus service would have on the network.

We would not wish to neglect the economic case for Park and Ride, but whilst this may improve prospects for Leicester city shopping this needs to be balanced against the consequences of reducing the catchment area of our own market towns in Leicestershire.

There is an urgent need to complete work on assessing all TROs, prior to a new parking management scheme. There are no measures to utilise the proposed Decriminalised Parking regulations to manage traffic better.

Since the number of School Travel Plans increased by 25% in 2004/5 (4.44) to a total of 46%, we believe that a higher target should apply to reach 100% coverage within two or three years. Our target for 2005/6 is already for a further 39%. Schools generate huge traffic problems and are one of the most common highways complaints of residents to their councillors. Having installed Travel Plans, we expect these to have a progressive effect, which demands continued monitoring and assistance by professional staff. The Plan does not identify the net effects in traffic reduction and improved safety of the current School Travel Plans.

We do not believe that travel plans should be restricted to employers of over 250 people, since this would not approach a sufficiently large proportion of the working population (3.95, 4.56). A more tactical approach is needed to address the needs of workers in small companies, often on large shared sites where there are many small companies which aggregate to a large population.

In our present labour market bus services for shift workers are increasingly important, yet services over a greater length of day and week seem absent from the plan.

Travel to and from health services needs to be addressed more fully (3.43 and 4.97)

Although our Road Safety record is improving, every death or serious injury is a tragedy and we would like to see more 20mph limits in the county, particularly outside schools.

The greatest challenge of our age remains unaddressed in the Draft Provisional LTP2. The relevant paragraph simple states: "A short text to be written linked to target for overall traffic levels" (4.197). Here is a hint that Carbon outputs will be linked to targets for overall traffic increases projected, but there are no targets for traffic reduction. We return to the beginning of this paper, therefore to reiterate the problem. This is a paper bound in with an unquantified but certain increase in traffic volumes in Leicestershire which will increase Carbon gases and do nothing to mitigate the very serious effects of climate change ant effects on reducing congestion are likely to be short term.

Road transport contributes 43% of CO₂ emissions in Leicestershire standing at 2,077 Kilotonnes per year from NAEI 2002 figures. Britain is committed to reduce carbon emissions by 60% by 2050 yet LTP2 plans to increase traffic volumes in the plan period.

In order to address our responsibilities to meet lower climate change carbon targets, LTP2 ought to include some measurements or audit of carbon emissions for major proposals. It is too late to do this in the Provisional Plan, but we would urge this to be included in the Final Plan. A particular mitigation measure that we would also urge is in the area of carbon sequestration. In everyday language this could be about acquiring land for tree planting in order to digest the CO₂ which our policies are creating. If the land, such as set aside, can be acquired such future woodlands would be widely enjoyed by Leicestershire people.

The Regional Assembly, with Government, public and local bodies, and service providers, should work together to develop and implement measures for behavioural change to encourage a reduction in the need to travel and to change public attitudes toward car usage and public transport, walking and cycling. Such measures should be co-ordinated with the implementation of other policies in the RTS and in Local Transport Plans, and will include:

Development Plans, future Local Development Frameworks and Local Transport Plans should also include measures to encourage an increase in walking and cycling. Such measures should include the provision of safe routes, convenient access to buildings and sufficient secure cycle parking in new developments.

In developing proposals for the next round of Local Transport Plans, all Highway Authorities should examine the feasibility and appropriateness of introducing fiscal measures to reduce car usage.

Particular consideration should be given to introducing such measures in the region’s Principal Urban Areas, and to environmentally sensitive areas experiencing high levels of traffic or traffic growth.