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Good day my good friend.

Today’s newsletter is a break from the usual format. In that it entirely consists of my personal response to the Integrated National Transport Strategy Call for Ideas. It contains some points that I hope chime with you, and what you expect me to say to government.

If I were to summarise my response, it would be in the words of Yoda from The Empire Strikes Back:

Do, or do not. There is no try.

We know what is needed to achieve an integrated transport system. We just don’t do it. We need to stop talking, and just do it. To do that requires a fundamental, system level restructuring of how transport is planned. Without which, any initiative will fail.

Enjoy.

📕 I have co-authored a book on Mobility-as-a-Service, which is a comprehensive guide on this important new transport service. It is available from the Institution of Engineering and Technology and now Amazon.

💼 I am also available for freelance transport planning consultancy, through my own company Mobility Lab. You can check out what I do here. 

🔊 The Ideas Called For

If you wish to get straight to the ideas, I have highlighted in bold the section where those ideas are. But if you will entertain me, I will first explain my rationale for these ideas, which will go a long way to achieving an integrated system.

I will start this response by saying something that is not often said in responses to consultations. Your team at the Department for Transport is full of clever people, and you know what needs to be done to put people who use transport and their needs at its heart, and empower local leaders to deliver integrated transport solutions that meet the needs of their local communities.

I will not spend this time listing all of the schemes that you need to deliver. You know things like truly integrated ticketing, enhanced mobility hubs, engaging the most vulnerable, flat fares, expansion of metro and tram systems in the largest cities, and people-centred streets are the things that people need to see to know this strategy is being delivered.

So my response will go much deeper than this. It will offer to you ideas for deeper reforms that are needed to accelerate the delivery of schemes that are necessary and needed, and to make an improvement to people’s lives as a result. After all, even the best looking homes are undone by ineffective plumbing. That is the fundamental problem that has faced transport in the UK for years.

The UK transport network as it is currently constituted does not work for delivery. Decision making and funding is highly centralised, one of the most centralised in the world according to the OECD. But in addition to that, there is no consistent policy on the delivery of transport improvements. From a review of policies from national governments and national agencies, the total number of strategies is significant, not even counting Local Transport Plans and Local Plans produced by Local Highway Authorities and Combined Authorities.

In some instances, more dedicated policy towards specific issues (e.g. decarbonisation) or specific modes (e.g. rail) may be justified. And there is some consistency between policy documents. But this picture shows a complexity in the policy landscape that leads to situations whereby the direction on transport delivery can be best summarised as “everything, everywhere, all at once.”

This does not assist in delivery. In fact, our governance structures ensure that all of the worst practices when it comes to the delivery of significant, transformative change, are baked into delivery. This includes, but is not limited to, focussing consultation on what is required by statute as opposed to what makes a meaningful change, impact assessments taking place at the end of planning processes rather than having matters like equalities and biodiversity impacts ‘baked in’ at an earlier stage, and endless political interference post decisions being made.

Our system of governance and delivery needs to radically change in a manner that embeds effective project delivery from the outset of schemes, and trusts local leaders with delivery and giving them the means to deliver. As well as fixing obvious failures in the market. Consequently, my suggestions primarily focus on changes in strategy, governance and legislation, as opposed to practical tasks to deliver.

Recommended strategy focus – crystal clear missions

The INTS needs to have a crystal clear focus on what it wants to deliver, specifically focussing on outcomes that are reflections of systemic change that are within transport’s control. Achieving wider outcomes like improved health and economic growth are important, but by focussing the attention of the strategy on matters that transport can deliver, it focuses the strategy on tangible delivery.

Consequently, the strategy should have 3 specific missions:

• Achieve modal shift towards public transport and active travel, as measured in average trips by mode per person per year as measured in the National Travel Survey. This will have a direct benefit on health in terms of use of active modes, improve the quality of places and streets, and reduce carbon emissions.
• Reduce transport-related social exclusion, as a percentage of the population at risk as measured by the TRSE measure produced by Transport for the North. This will focus effort on the aspects of social exclusion that transport can most meaningfully affect, while centring the needs of vulnerable groups.
• Satisfaction with non-car modes of transport, which will likely require a new measure based upon the approach adopted by Transport Focus to its satisfaction surveys on rail, buses, and strategic roads. This could also have a deeper dive on the needs of the most vulnerable populations.

Each of these missions can be considered within the context of achieving wider goals. However, it is critical that the INTS focusses on what transport can achieve. This provides a focus for professionals in the understanding that what they are doing achieves wider goals and not just transport goals. These 3 missions are at the nexus of achieving such goals.

Specific ideas to focus transport governance on delivery

Place a statutory duty on Combined Authorities, Local Transport Authorities outside of Combined Authority areas, National Highways, Network Rail, Airport and Port Operators to facilitate integrated infrastructure and services in their areas

This will likely require an Act of Parliament to deliver, but is probably the most critical thing needed to place integrated transport at the heart of what transport delivery bodies do. It will place a statutory duty on public bodies and major infrastructure operators to act as co-ordinators and facilitate the integration of infrastructure and services within their areas.

Similar to the requirements under the French loi d’orientation des mobilités (LOM) law, organisations should have a broad and powerful duty to co-ordinate services, whether in joint ticketing, timetabling, or through common standards of services provided to customers. The reality is that in doing so, such organisations will have to be mindful of the commercial sensitivies and requirements of private operators, and they should be required to consider such things as part of development of policy and initiatives. However, in exercising this function, they should demonstrably seek to achieve the goals of local, regional, and national policy.

This requirement should apply to Combined Authorities (as well as an expanded remit of Transport for London), Local Transport Authorities in areas not covered by Combined Authorities, National Highways, Network Rail, Airport and Port Operators.

With regards to service operators, a duty to co-operate to help the above operators meet their statutory duties should be integrated into licencing and funding conditions. For example:

• Local bus services (including demand responsive services) should have such a condition included as part of approvals to operate routes given by Area Traffic Commissioners, or as a condition of claiming the Bus Service Operator Grant. This could also extend to Community Transport Operators where they operate ‘public’ services.
• Franchised passenger rail services can have such a duty included as a standard condition of the franchise agreement, with financial penalties for breaking it. In areas where Combined Authorities play an active role in franchising, this can be facilitated through that process.
• Open access rail operators can have such a duty included as part of track access agreements, for stations that they serve on their routes. Further work on defining the scope of this would need to be undertaken by the Office of Rail and Road.
• Shared bike and e-scooter schemes would need the establishment of a licencing regime, where Combined Authorities, Transport for London, and Local Transport Authorities can licence shared bike and e-scooter schemes within defined geographical areas, with a licence condition being such a duty to co-operate.
• Car Clubs could also be subject to such a licencing arrangement, should the Department for Transport be so minded to do so. But an alternative could be to place conditions on operators using car club parking bays designated by Traffic Regulation Order to support such a statutory duty, including integrating into shared ticketing schemes.
• Local taxis would have such a requirement included within licences issued for a set geographical area. However, a more effective measure would be a significant re-writing of taxi and private hire vehicle legislation, to place such a duty as central to local operations as well as tackle outstanding matters associated with operators like Uber.
• Integrating with ferries and domestic aviation to islands will be a more challenging proposition, given international rules associated with maritime and shipping. The Department for Transport should therefore work with such operators to identify opportunities to incentivise integrated travel. The experience of Solent Go shows that this is possible, if challenging.

Retention of a proportion of Business Rates ring-fenced towards integrated transport improvements

The current Business Rate Retention Scheme allows for up to 50% of Business Rates raised locally to be retained by local councils. As of December 2024, the Business Rate Retention Scheme is being reviewed, with a new assessment of need and resources, and a reset of the 50% retention mechanism by April 2026. This provides a significant opportunity for consistent, long term funding to be secured for integrated transport schemes from organisations that, arguably, stand to benefit the most from a fully integrated system.

The Department for Transport should press the case that the remaining 50% of business rates should be retained locally for the sole purpose of improving transport infrastructure and services. Reductions in congestion and improvements in accessibility from this investment will help the Treasury achieve economic development goals, and provide Combined Authorities and Local Transport Authorities with much needed and consistent revenue to deliver integrated transport improvements.

The current 50% of funding retained provides a core funding stream for local councils for services such as adult social care, something that should be retained. It is time to go one stage further, and use Business Rates to fund improvements to infrastructure and services, to the benefit of businesses. It is estimated that this will provide a relatively consistent £12.5bn in funding every year for such improvements.

A matter that the Department for Transport should look at with some urgency is the matter of fair distribution of such funding. This reflects the reality that some local authorities have a high concentration of businesses, whereas others do not, while transport need does not scale in a similar way.

Integrated Transport Funding to be provided through single blocks lasting 10 years

The preferred approach is to give local authorities and Mayor Combined Authorities the powers to raise their own funding to deliver significant transport improvements. But this does not mean that transport authorities and delivery agencies will not receive funding from central government. But the short-term nature of this funding precludes future planning for significant programmes of work.

The existing Integrated Transport Block needs to be substantially improved. Not only must it be ring-fenced for transport improvements and funding significantly boosted, but this funding needs to be allocated in 10 year funding commitments agreed by the Department for Transport, subject to changes in annual inflation.

Where local authorities have been bold and taken on additional sources of funding to deliver transport improvements, it should be encouraged to spend this Integrated Transport Block on scheme development. Should the Department for Transport or the Treasury seek oversight of this spending, such development work could be subject to the usual business case development process. But wherever feasible this should be avoided so as to speed delivery.

More radically, such an approach could also be applied to the RIS and Control Period processes of National Highways and Network Rail.

Transition BODS into TODS

Any transport organisation that is publicly licenced in some way should, by default, offer up data on its operations – notably timetables, real time location data, and fares – as open data, via an API. The Department for Transport has experience in developing a system to facilitate this, the Bus Open Data Service. This has enabled bus operator data to become much more easily accessible, and widely used by third parties.

Rail, taxis, community transport, car share, bike share, shared e-scooters, local taxis, domestic ferries and domestic aviation must be subject to the same open data rules as local buses are. No operator licences or contracts should be awarded by government of any type unless such data be available as standard. Recognising the fact that smaller operators may still struggle with their technological capabilities, dedicated support could be made available for a period of up to 5 years to boost their capability.

The requirements needed for this have been known for many years. There is no more excuse for delay.

Establish a Major Projects Accelerator

Occasionally, integrated transport needs significant infrastructure projects to deliver transformational change. Notably new tram and mass transit projects in cities, new railway lines, and significantly enhanced mobility hubs at major transport hubs such as stations and airports. But the UK seems institutionally unable to deliver major projects in a timely manner.

Currently, the Infrastructure and Projects Authority provides technical assurance for major projects across government (of which transport and energy projects form the biggest share), as well as maintaining the infrastructure pipeline. Nominally with the aim of improving delivery. This needs to be expanded much further, with the aim of taking major projects from ideation to opening within 5 years.

The Treasury has indicated its willingness to streamline planning legislation and restrict judicial reviews so the consents process is much more streamlined. But this does not need to be at the expense of community engagement and environmental assessment. Both of these factors can be built into the development process of schemes without compromising quality, so long as they undertaken at the correct times and meaningfully input into scheme development at an early stage.

This accelerator should establish a core technical capability within government to deliver major transformative projects. It should establish early the process for delivering such major schemes within a 5 year time period, and rigorously test that model through delivery. It should be staffed with highly experience professionals with extensive experience in the delivery of major infrastructure projects, supplemented by domain expertise where applicable to ensure effective project delivery. Such a function should also operate on the principle of taking time to plan such schemes, before accelerating their actual delivery.

This function could also be made available to other organisations who wish to accelerate the delivery of their Major Projects, especially in cases where they lack the capability to deliver. While this accelerator can also share learning, experience is the best learner, so the opportunities to develop wider capability in major project delivery should be undertaken by this accelerator.

There may still be instances where major projects are not delivered within 5 years, due to procedural matters or on-site conditions not anticipated during planning. While any acceleration in delivery is welcome, the accelerator could also be tasked with providing advice to government on improvements in process and delivery necessary to further accelerate delivery. With government being required to respond to these recommendations.

Furthermore, as such projects are politically sensitive, government could seek to establish a cross-party committee to provide oversight of this accelerator. As well as associated political guidance.

The strategy should contain a commitment to establishing this, offering major integrated transport projects as a test case.

Simplify the block exemption rules for integrated ticketing in public transport

A block exemption from the Competition Act 1998 for integrated ticketing is provided by The Competition Act 1998 (Public Transport Ticketing Schemes Block Exemption) Order 2001. While it provides a broad-based exemption for integrated ticketing schemes, this is subject to numerous tests to ensure that the spirit of fair competition between operators is still sought. While the hurdles to delivering integrated ticketing schemes legally are not onerous, simplification of these rules will both reduce barriers and change the focus of the legislation away from being wary of integrated ticketing towards it being an essential requirement on operators.

This will likely be achieved either through a new legal order under the Competition Act 1998, or an amendment to the Competition Act 1998 included within the Bus Services Bill. This would nullify the existing regulations and replace it with the following:

• Placing statutory duties on public transport operators to participate in multi-operator ticketing schemes within the Local Transport Authority areas which they serve. Such multi-operator tickets can be facilitated by the Local Transport Authorities themselves, or be joint schemes between operators and facilitated by them
• All public transport operators have a legal right to request to be included within other integrated ticketing schemes within the local authority areas they serve, whether facilitated by Local Transport Authorities or operators. Operators cannot be refused entry to such schemes on competition grounds.
• Placing a statutory duty on Local Transport Authorities and / or Mayoral Combined Authorities to facilitate the introduction of integrated ticketing systems in their area, covering public transport services and further ‘last mile’ services (e.g. bike share) as they deem necessary.

This is based on the assumption that, while franchising of buses may be popular, a substantial proportion of bus services will be privately operated. At least in the near future.

Conclusions

All of these actions are of varying degrees of complexity, but are necessary to restructure transport governance in a manner that delivers our intended outcomes. Matters such as stalling productivity, increasing inequalities, poorer health, and climate change necessitate urgent action, something that simply providing more funding for schemes will not achieve.

It is time to do, or do not. There is no try.