The big challenges for transport from Labour’s devolution plan

THE NEW Labour government is promising “the most ambitious programme of devolution this country has ever seen”, proposing to let communities take back control of powers hitherto hoarded in Westminster. What might it mean for the transport system and getting England get back on track in cutting carbon and casualties while integrating different modes better?

Criticising what it described as a piecemeal, sticking plaster “Levelling Up” agenda, pursued by the Conservatives, Labour in opposition promised a Take Back Control Bill to boost growth across the nation. Perhaps someone somewhere noticed that a TBC Bill was not the most helpful of acronyms. In the King’s Speech it was renamed as the English Devolution Bill.

This major policy initiative is certain to impact on transport in a number of significant ways – both directly and indirectly – especially with the Government’s accompanying legislation to reform planning and infrastructure delivery.

Certainly while Louise Haigh, the new Secretary of State for Transport, has promised to “move fast and fix things”, the detail of her transport plans beyond the Bills on rail and bus reform, remains to be confirmed. Besides a terrible economic inheritance, the government faces a decade of grappling with what could be called policy or governance debt. In the same way that technical or ‘code debt’ in the IT sector accumulates where easy solutions are chosen over more fundamental resolution of issues, previous ministers for over a decade at the DfT seem to have preferred press releasing soundbites rather than making important decisions. As a result, key strategies and guidance across issues like road safety, Local Transport Plans (LTPs) and network management have not even been updated since the last Labour government. Even where major plans were published, such as on transport decarbonisation and active travel, they were little more than activity feeds rather than coherent and adequate strategies.

So there is a huge amount that needs sorting out, and soon, at the national, local and regional levels. It might be attractive to think what could be called the visible hand of devolution can reduce a dependence on the centre to fix things. Could that turn out to be as dogmatic as faith in the invisible hand of the market, however?

Resources, capacity, processes and skills are required to change things at a local level – and all are arguably in short supply.

What actually is devolution?

Although usage of the term varies by country- and by political standpoint - devolution can be seen as a stronger form of decentralisation and is used interchangeably here. Describing decentralisation as one of the most important reforms of the last 50 years, the OECD believes t often understood as a simple increase in the power of local government[2]”. Indeed in OECD’s ten guidelines for success, clarifying responsibilities comes first. Similarly the European Charter of local self-governance refers to the transfer of responsibilities alongside powers[3]. The OECD study of experience across the globe found that administrative and fiscal dimensions of devolution were as important as political ones, with outcomes depending hugely on the way reforms were designed and implemented.

Labour’s Power and Partnerships plan makes a strong case for empowering local government, based on “better information about their local economies, and more developed capacity for working with local businesses and institutions[4]”. Within days of taking office Angela Rayner, Deputy Prime Minister and Secretary of State for Housing, Communities and Local Government, wrote to local leaders promising “a presumption in favour of devolution alongside a new framework in due course, setting out the new powers and flexibilities available”[5]. But in contrast to international good practice, Labour’s pronouncements have so far focused on ending the hoarding of powers at Westminster, rather than saying anything on specifying extended local responsibilities. The sole exception has been mandatory housing targets that Labour plans to restore. This omission seems odd given the previous focus in New Labour’s 1997-2010 government on the balance between rights and duties, such as the social contract for safer streets set out in its Respect and Responsibility White Paper of 2003.

It’s easy to share slogans or post photos of inspiring infrastructure in other countries to potentially emulate, but the adoption of processes and culture essential for success in so doing is far harder to communicatee. While the Dutch success on cycling is well known, for example, that country’s failure in the early 2000s to progress road safety alongside the move to decentralise power is far less so. High levels of ambition were set by its government, but without clear ideas on how to deliver in the new context, with it soon becoming obvious that municipalities were neither prepared nor equipped to do so. The fundamental problems were found to be a lack of sub-national capacity building and coordination mechanisms across different levels of government as well as insufficient funding[6].

Of the fiscal dimension from the new UK Labour Government, Rayner has simply said “Rest assured, we will ensure that you have the resources to deliver new devolved powers and functions”. That short sentence begs a very big question however. With strict fiscal rules, it remains unclear how much can be delivered in practice. A particular challenge here is the framework of statutory duties for local authorities making some services mandatory, draining ever scarcer funding from existing, let alone new, discretionary powers. The contrast between statutory provision of school and social services transport, and discretionary support to general public transport bus services, is a classic case in point. In this context moving from ring-fenced funding to single settlements without setting out a framework of new responsibilities would in practice mean minimal,if any, additional funding for key needs in many local areas.

Starmer and Rayner meet the mayors in Downing Street

The first-ever meeting bringing together England’s metro mayors was held in Downing Street in the week after Labour’s election victory, Prime Minister Keir Starmer and Deputy Prime Minister Angela Rayner, also MHCLG Secretary, highlighted the new Government’s plans to spread power around the country and roll out new Local Growth Plans to work alongside a national industrial strategy. They recommitted to giving mayors new powers over planning, skills, employment support and transport.

The Government made clear that its ambitions for integrated funding for Mayoral Combined Authorities would be widely available to those who “can show exemplary management of public money.”

A cautionary climate tale

Let’s take another example of a major challenge for local government. With climate change being widely regarded as one of the biggest threats we face, and local authorities having key powers over transport, have they been able to use their knowledge and capacity to accelerate progress faster than the national average?

As a major example, in 2020, London’s Mayor Sadiq Khan pledged to make London net zero by 2030, and in 2022 amended his 2018 transport strategy (the MTS) to cut car traffic by 27% by then. This May he was elected to an historic third term after making climate and clean air key parts of his pitch. This is where aspiration and reality collide, as explored forensically by Mark Frost in his recent excellent LTT/TAPAS article on minding London’s decarbonisation gap[7].

The trouble is that the latest data shows London is way off track meeting its 2018 targets for 2050 net zero let alone the more recent ones seeking to decarbonise by 2030[8]. After focusing his political capital on expanding the ULEZ, estimated to change traffic by “plus or minus one per cent”, the Mayor ruled out smart charging, even though research he commissioned found that the “scale of reductions required...is only possible with some form of road user charging, proposed to be introduced London-wide by the mid-late 2020s”[9]. The 2030 pledge also relied on cutting air travel to half of 2018 levels - despite Heathrow seeing record passenger numbers this month - as well as deploying massive carbon offsetting, a concept increasingly lacking in credibility.

Other research shows the UK needs at least a 20% reduction in motor traffic by 2030 is needed for a net zero 2050 pathway, growing to 50% alongside electrification of nearly all vehicles if brought forward to 2030[10]. With all sectors increasingly off track since then, transport- as the one with the biggest footprint - surely has to cut its emissions even faster.

London is far from unique in its gaps between pledges, targets and delivery. Greater Manchester has pledged to reach net zero by a more realistic 2038 and its progress in delivering an integrated transport system, driven forward by Mayor Andy Burnham, is held up as a model of devolution too. Yet its transport strategy proposes only to stabilise motor traffic, with an 8% cut in car use, despite being one of Europe’s most congested cities and with strong potential for modal shift. Across the Pennines, West Yorkshire, led by the high profile Tracey Brabin, is now consulting on a new LTP, but without information on the success (or lack of it) by the Mayoral Combined Authority and its predecessors in meeting previous pledges. Without evaluation of past policies and delivery with professional scrutiny, the cycle of setting bold ambitions without adequate policy proposals seems set to continue.

This brings into high relief the actual role of LTPs and the absence of any revised guidance on them since 2009. The agenda, and the imperatives, have changed significantly in the meantime, but the last government repeatedly postponed setting out a clear new prospectus for what is required, including the importance of local pathways for decarbonisation. Indeed, although two-fifths of local highway authorities have committed to net zero by 2030 or before, three years ago the National Audit Office (NAO) criticised the government for failing to set any expectations for local ambitions or enable consistent reporting[11]. With the Climate Change Act 2008 only applying at the national level, the independent Skidmore Review delivered last year to former Prime Minister Rishi Sunak recommended a statutory duty on local authorities. The government flatly rejected this, saying that as most councils had declared climate emergencies, there was “already a high level of local commitment”[12]. By contrast a House of Lords inquiry had concluded only a year or so earlier that a key weakness in local net zero ambitions was unwillingness at all levels “to commit to policies that constrain car use”[13].

While there are statutory bodies informing planning decisions and their suitability regarding flood risk, nature and conservation, there is no such input on climate mitigation, despite the threat posed for the future. The only body in existence with relevant expertise to make comment on and hold these local decisions to account is currently the Climate Change Committee (CCC), but its resourcing is far too limited for such a task.

Beyond climate

While the UK is forecast to miss its climate targets, despite so-called world leading legislation and governance being in place for half a generation, the situation is equally bad, or worse, in other policy areas, which lack similar focus and processes. This puts at risk delivery of the government’s missions for safe streets and an a healthier population.

Painting a dire picture about the NHS’s future viability, the NAO recently highlighted that “the extent to which citizens choose to and are assisted to lead active lives...is critical to determining what kind of financial future awaits the NHS”, concluding with a call on councils to deliver clean air and safe streets[14]. In this regard an earlier NAO report revealed how off track active travel ambitions were, and since then new data has shown cycling declining since 2019[15].

Labour has encouragingly signed up to Environment Act 2021 targets on cleaner air with Defra working on a delivery plan on how to achieve them, something on which the last government failed to follow through. Defra research suggests that meeting particulate target requires cutting motor traffic in urban areas by a fifth[16]. In cities like Manchester, as many as 5% of all deaths are caused by this pollution, though not all of it comes from roads. Work on the 2021 Act’s apex target to restore nature is even more limited and especially a challenge for rural local authorities. Just as a single example, while not a protected species, about a third of British barn owl chicks are killed flying over roads, illustrating the scale of the impacts of traffic on nature[17]. Although widely promoted as the solution, the biodiversity net gain concept is designed around landtake and simply fails to engage with the many ways that transport networks disrupt ecological networks.

Then there are human road casualties. Following the lack of road safety leadership by recent governments, many cities and regions have committed to vision zero by 2040, ending deaths and serious injuries on our roads. To be on track London needs to reduce KSI by 70% by 2030, despite progress stalling since 2015 in the capital, and indeed nationally. A reduction in driving, 20mph and Low Traffic Neighbourhoods (LTNs) as the norm will be required in urban areas, but far from enough on their own.

How local need you go?

The appropriate level that powers and policy should be devolved to will vary by and within sectors, but is especially complex for transport because of network effects. Fifteen years ago the Commission for Integrated Transport called for national carbon targets to be divvied up to regional and local levels[18]. The lack of progress since then, and greater ambition and stringency of targets surely make coherence and credibility of governance even more important now. And, if we accept that mandatory housing targets are needed to tackle the housing crisis, should some dimensions of transport delivery be mandatory too, not least as opposition to new housing is often down to fears of traffic impacts?

How then might appropriate targets be set, allocated and devolved to sub-national and local bodies, or even smaller individual communities, and what sort of partnership between the different levels might work to agree them? One challenge here is that urban areas frequently argue that they cannot cut traffic because they face the greatest population growth, while rural areas say modal shift is too hard due to the lack of alternatives to driving. Draft DfT carbon guidance simply said “each authority will decarbonise at a different pace subject to local capabilities, needs and circumstances”[19]. This was never published, whether due to concerns it could supercharge climate legal challenges[20] or ministers u-turning to favour drivers.

Subsequent to target-setting comes the key question of how much flexibility should different levels have to veto projects or policies? Previous ministers proposed an approach with no obvious logic, of curbing the public’s right to object to major road schemes, while restricting local authority powers to deliver LTNs and lower speed limits. Surely where something has a strong strategic fit with missions and targets, but there is no viable alternative, then there should be a presumption in favour of implementation, and vice versa?

The Society of Labour Lawyers argues that the “need to exercise some powers at a regional or sub-regional level must not take powers away from lower levels of upper tier and district authorities” and that “holding of strategic transport powers should not prevent the devolution of, for example, Low Traffic Neighbourhood policy to parishes or communities”[21]. But how does that fit where such interventions are needed to fill the missing link in a congested bus or cycle route? Or where most residents of a borough voted for motor traffic reduction, but a wealthy enclave wants a free ride for their SUVs? This is complicated by the fact that functional economic areas, such as travel to work areas, do not necessarily fit in with existing local authority boundaries, while traffic and transport networks often cross them, complicating allocation of emissions as well as planning.

A local council at work - how will it cope with more responsibilites?

Such issues are set to grow with the spread of the larger combined authorities, favoured by both the former and current governments,setting LTPs for ever larger areas than before. To tackle this, cities like London and Manchester already have boroughs producing local implementation plans for their city-wide strategies. But existing powers of mayoral direction and implementation, such as in the Greater London Assembly Act 1999, have never been fully used.

Devolution and local democracy open up some interesting conundrums in practice. Recent examples include the hole in London’s cycle network in Kensington & Chelsea, and the ripping out of LTNs in Tower Hamlets following a change of political control. Surely the London Mayor could and should have dealt with these matters by deploying his powers, all the more so given evidence of how he was so far off in meeting the targets he had set and been re-elected on. But Mayor Khan refused to intervene in the latter on the basis that local people know best, even though local consultations revealed majority support for the LTN. The only commitment in the Labour manifesto for walking and cycling was to give mayors powers to “promote active travel networks”[22], yet the incumbent in London is unwilling to use existing powers put in place by the last Labour government.

Joining up funding and planning

The importance of partnerships was emphasised in the 2009 LTP guidance , and has been again by Labour this year in its election campaign But in between , many of the structures were either taken out or became outdated. The Levelling Up and Regeneration Act 2023 abolished the duty to cooperate in spatial planning, while the main (highways) network management duty guidance has not been updated since 2004, so predates current structures as well as policy. Though the Transport Act 2000 includes duties to consult and also to have regard to national policy, these require little more than name checking.

With a declining share of the vote taken by the two main parties nationally, neighbouring local authorities may now have increasingly different political makeup, but residents and business still need to travel between them. Stronger duties are surely needed to prioritise delivery of national targets and ambitions, while building good working relationships more locally.

Funding is another challenge, not simply its scarcity but how plans follow different pots. It’s not just the plethora of government funding pots that is the problem but also local funding sources, such as from parking or developers. In London, for instance, more and more boroughs are planning transport schemes funded by parking and enforcement revenue outside their statutory local implementation plans to deliver TfL priorities[23]. This makes it challenging, even for those inside councils, to join up funding, track commitments and delivery against them.

Without new fiscal powers, and while national funding remains tight, how might the ability to deliver local projects be improved? The National Infrastructure Commission and local government have called for statutory long-term funding settlements. So perhaps there is a lesson to be learned from the infrastructure strategies with their performance specifications, such as the National Highways RIS. Targets as well as requirements to deliver, such as unlocking major housing schemes, could be written into specifications and those authorities offering more ambition could expect to a greater share of funding. That would avoid the pitfalls of competitive funding and the lack of ambition of automatic formula funding.

Low Traffic Neighbourhoods have been a focus for controversy and political position-taking

While the Plan for Drivers’ proposal to limit traffic management enforcement as “drivers feel unfairly penalised for using their cars in their local area” was supercharged on conspiracy theories, it did raise an important issue[24]. There is no direct accountability to road users beyond the borders of the authority they are resident in. With emissions zones, parking charges and publicly controlled buses set to proliferate, there is surely a case for some form of regulatory supervision over these activities, just like there is in other sectors. Such scrutiny is surely all the more important in an era of collapsing local news reporting and readership[25].

The Office of Rail and Road (ORR) currently only deals with National Highways not local roads, leaving an obvious accountability gap. Rail reforms are set to move many of its functions to a Passenger Standards Authority. This is surely an opportunity for sensible structural reforms, potentially including the Traffic Commissioners, into a new body. The creation of Active Travel England (ATE) has shown the impact and value that a small, motivated team can have in a short space of time. Crucially it has written in requirements for its oversight of a wide range of related government funding, and graded authorities by capability. But where is the national expertise for buses, demand management let alone integration? That is an issue DfT has fallen behind on given the slow pace of bus and rail reforms up to now, and not simply integration between modes but spanning departmental boundaries, as well as sharing best practice between local areas.

The Commission for Integrated Transport covered all these needs before it was abolished in the 2010 bonfire of the quangos. Broadening what remains of the ORR into an Office for Integrated Transport could fill many gaps and deliver efficiencies as well as accountability. This would require a coherent set of national transport objectives, much like the strategy and policy statement for energy published earlier this year, to guide a future regulator. Before the election, the House of Commons Transport Committee said such objectives were a key priority, alongside “perhaps most importantly, how different parts of Government, public bodies and other stakeholders can work better together to build a transport system fit for the future”[26]. There could also be a greater role here for Oflog, which currently only captures some data on road condition, to collate a far wider range of transport data.

Rethinking LTPs or creating something else?

In the fifteen years since the last guidance on LTPs was published[27], both the extent of policy requirements and the range of plans and strategies they need to align with has grown and is set to continue to. Yet according to research by the Low Traffic Future Alliance, most LTPs are seriously out of date[28].

Authorities with devolution deals are to be required to produce local growth plans to a ten year horizon. How might these be aligned to local plans, which are required to take at least a fifteen year horizon and potentially a different cycle of development? Or infrastructure development strategies, which set out how the new infrastructure levy will be spent - but not other forms of transport funding?

Integration will be needed with LTPs, which were once supposed to be updated every five years. Likewise for Local Nature Recovery Strategies, particularly important in rural authorities, even though no guidance exists on the links between them and LTPs. Integrating management plans for protected landscapes may be needed too where relevant. While local plans are subject to an Examination in Public by the Planning Inspectorate, DfT oversight of LTPs has long ended. Does that make sense or is it simply due a lack of resources? What might be a middle way between top- down control and a local free-for-all? One option could be review of a sample of plans, another seeking supportive challenge from some sort of design panels. Made up of interdisciplinary experts, these can help incorporate wide-ranging objectives and generate a broader range of options at an early enough stage to make a real difference.

Joining up all these issues across plans with different timescales and refresh cycles would be hard, even in well resourced authorities. A particular complication here is that although the spatial planning system is being digitalised, in other words turned into easily reusable data not just cumbersome PDFs, no such moves have been announced for LTPs, related documents for bus and active travel networks, nor it seems other types of plan. And how might the average person or business find out what policies or proposals apply where they live, work or travel often? The Local Government Association is seeking to co-design an enhanced framework for devolution and local growth with the government. Ensuring a wide range of stakeholders will be able to find and engage in the cycles of planning and evaluation easily is surely vital to build wider partnerships and public consent.

Some of the biggest opportunities will be unlocking the alignment of major housing developments with Labour’s ambitions for modal shift. Even where there is already a nearby station, additional capacity may require substantial upfront investment. The link between transport and housing is acknowledged in the new draft National Planning Policy Framework. In many suitable locations for dense development, proposals will require early engagement with Great British Railways about network adaptations, and consideration of potential light rail or other kinds of Rapid Transit schemes that will be needed to facilitate sustainable access ability. France is planning up to 24 regional metros, known as SERMs, primarily by expanding existing lines[29]. This should be the blueprint for unlocking the delivery of sustainable housing at scale and at pace but it is likely to require the creation of a regional outward-looking tier of Great British Railways as well as creative thinking within local and regional government.

Where devolution fears to tread?

Devolution of transport service provision has received lots of air time, but it has largely been about buses. Certainly making the franchising of bus services easier and allowing local authorities to set up their own bus companies are widely supported, though some have called for other responsibilities too, such as minimum services levels[30]. But what should it mean for other forms of transport?

Rail, at least in terms of how it is run rather than any specific improvements to the network, has been a major focus for Labour with its plans for nationalisation of passenger services. The Urban Transport Group has called for a meaningful, statutory role of mayoral and combined authorities in the new framework[31]. A major conflict could emerge between the principle of a unified national rail system where public ownership is the default position as franchises expire, and mayors taking control to integrate local services with buses. That is the model in other countries like Germany and France, which will soon enable regions to tender services to competitors of SNCF. After all, if mayors can choose across the full spectrum from private to public ownership for buses, why not for rail? Few of its passengers may realise but the London Overground is run under a private concession, which is due to expire in 2026, so this could be an early flashpoint. If open access is allowed to continue on the rail network due to its record in driving better passenger outcomes, might there be a role for locally-let concessions too?

A related issue is the planning and consenting process for major transport infrastructure. Besides hardly tripping off the tongue, the National Networks National Policy Statement (NNNPS) seems deliberately named to discourage sub-national bodies’ involvement in infrastructure. The thresholds set by the Planning Act 2008 ignore urban transport schemes, while uniquely privilege National Highways as the sole developer for road based schemes. This has real consequences. A lack of supportive national policy derailed or should that be dewired the Leeds trolleybus in 2016[32], and it remains the largest European city without a mass transit system, although now with options for a tram system being consulted upon. Similarly while cities across Europe are building out cycle superhighways optimised for e-bikes, over here the compulsory purchase and consenting processes make that unviable.

Although the ministerial direction for TfL’s Silvertown tunnel to be consented as a Nationally Significant Infrastructure Project was controversial, the current situation of county councils being able to approve their own major road schemes is far from ideal. There is a growing argument that as road schemes may be nationally significant in terms of emissions, modal shift etc., any such decisions should be taken out of their hands.

There is widespread consensus that infrastructure planning needs to become more spatial, with the Department of Energy Security and Net Zero moving fast to publish a spatial plan for energy. Can transport catch up? It should certainly try to since housing development is arguably more limited by transport than energy infrastructure. Developing such a plan or a new NNNPS, better reframed as an Integrated Transport NPS, should be co-produced with sub-national bodies. To speed this process up, an overarching transport NPS mirrored on that for energy could be produced, but then with regional spatial NPS for integrated transport developed separately.

Finally there is a question about what to do with National Highways. MPs on the Transport Committee examining strategic transport investment heard how many of its schemes were outdated and not aligned to local growth priorities[33]. Meanwhile the way it plans its network does not align to functional economic geography. Birmingham, for instance sits in the middle of five different route strategies even though most journeys on the strategic road network are regional not national. Changing this and switching funding for capital enhancements from RIS3 to modally agnostic regional budgets has been long overdue and is surely vital for Labour’s commitment to modal shift. Beyond that, existing legislation provides for the detrunking of individual roads as well as breaking up National Highways into regional companies. Unless the Infrastructure Act 2015 was amended, the Secretary of State for Transport would remain the sole shareholder, however.

Conclusions

It is certainly clear that the scale and style of change required in local transport can neither be delivered effectively just top-down or bottom-up. Local people and councillors may know best for delivering incremental change in a stable external environment, but radical change in an ever more uncertain world requires fresh approaches. Up to now we’ve been treated to simple slogans about taking back control, nationalisation and the dire situation we are in, without daring to spell out the implications. Now the new government is in place, the difficult work starts on how to join the dots between devolution and many other agendas, and while delivering quickly too.

Transport is an especially difficult policy area, and not just for being biggest in terms of both emissions and household budgets. Much of the greatest impacts, whether positive or negative come from travel ‘between’ not ‘within’ places, so in complex patterns of services and journeys crossing local authority boundaries. We therefore need thinking that is network-based, at least as much as place-based.

One suggestion, to make sense of the growing alphabet soup of devolution, is that English devolution should adopt a key concept of IT and digital innovation, known as ‘a layered modular architecture’. Each part of local government or module should, with this approach, have a clearly defined interface for interacting with other parts. Different layers (both in terms of functions as well as geography) will need clearly defined roles, such as by focusing LTPs on more clearly managing networks and services. Standardised data of inputs, outputs and outcomes is needed, alongside the status and objectives of schemes, to enable rapid monitoring, evaluation and learning, since the degree of change will be too complex to model accurately.

It is not just the solutions that will need to change but the mindsets as well. Decentralisation is going to be an exciting and important journey, but a process that in itself will be challenging too.

References an Links

1. https://labour.org.uk/updates/stories/labours-plan-to-power-up-britain/ (Labour, 2024)

2. https://www.oecd.org/en/publications/making-decentralisation-work_g2g9faa7-en.html (OECD, 2019)

3. https://www.coe.int/en/web/conventions/full-list?module=treaty-detail&treatynum=122 (Council of Europe, 1985)

4. https://labour.org.uk/updates/stories/labours-plan-to-power-up-britain/ (Labour, 2024)

5. https://www.gov.uk/government/publications/letter-from-the-deputy-prime-minister-to-local-leaders- the-next-steps-to-devolution/letter-from-the-deputy-prime-minister-to-local-leaders-the-next-steps- to-devolution (MHCLG, 2024)

6. https://link.springer.com/referenceworkentry/10.1007/978-3-030-76505-7_12 (Springer, 2022)

7. London mayor has a big target for cutting carbon emissions - he needs big ideas to achieve it. Here are five to start with (Mark Frost, 2024)

8. https://www.healthystreetsscorecard.london/2024-results-media-pack/ (Healthy Streets Scorecard, 2024)

9. https://www.london.gov.uk/programmes-and-strategies/environment-and-climate-change/climate- change/zero-carbon-london/pathways-net-zero-carbon-2030

10. https://www.transportforqualityoflife.com/reports/the-last-chance-saloon-we-need-to-cut-car- mileage-by-at-least-20/ (TfQL, 2021)

11. https://www.nao.org.uk/reports/local-government-and-net-zero-in-england/ (NAO, 2021)

12. https://researchbriefings.files.parliament.uk/documents/CDP-2023-0122/CDP-2023-0122.pdf (Commons Library, 2023)

13. https://publications.parliament.uk/pa/ld5803/ldselect/ldbuiltenv/89/8909.htm#_idTextAnchor074 (House of Lords, 2022)

14. https://www.nao.org.uk/reports/nhs-financial-management-and-sustainability-2024/ (NAO, 2024)

15. https://www.nao.org.uk/reports/active-travel-in-england/ (NAO, 2023), https://www.gov.uk/government/statistics/cycling-index-england/cycling-index-england (DfT, 2024)

16. Note on road traffic abatement measures and the “high ambition” scenario in 2040 (Defra, 2023)

17. https://www.barnowltrust.org.uk/hazards-solutions/barn-owls-major-roads/ (Barn owl trust, undated)

18. https://webarchive.nationalarchives.gov.uk/ukgwa/20100116002916/http://cfit.independent.gov.uk/pubs/2009/cct/index.htm (Commission for Integrated Transport, 2009)

19. Draft Quantifiable Carbon Reduction Guidance (DfT, 2023)

20. https://cdn.friendsoftheearth.uk/sites/default/files/downloads/Advice%20to%20minister%20when%20signing%20off%20on%20plan%20%28Mar%202023%29.pdf (DESNZ, 2023)

21. https://www.societyoflabourlawyers.org.uk/take-back-control-bill-briefing/ (Society of Labour Lawyers, 2023)

22. https://labour.org.uk/change/manifesto-accessibility/ (Labour, 2024)

23. https://www.london.gov.uk/who-we-are/what-london-assembly-does/assembly-member-press- releases/mayor-must-use-powers-get-climate-action-london-borough-streets (London Assembly, 2024)

24. https://www.gov.uk/government/publications/plan-for-drivers (DfT, 2023)

25. https://www.theguardian.com/uk-news/2024/feb/02/collapse-of-local-media-leaves-us-all-in-the- dark (The Guardian, 2024)

26. https://publications.parliament.uk/pa/cm5804/cmselect/cmtrans/828/report.html (Transport Committee, 2024)

27. https://lowtrafficfuture.org.uk/challenge/

28. https://webarchive.nationalarchives.gov.uk/ukgwa/20110509101621/http:/www.dft.gov.uk/adobepdf/165237/ltp-guidance.pdf (DfT, 2009)

29. https://www.sncf-reseau.com/fr/le-reseau-de-demain/les-services-express-regionaux-metropolitains (SNCF, 2024)

30. https://www.transportforqualityoflife.com/reports/every-village-every-hour-a-comprehensive-bus- network-for-rural-england/ (TfQL & CPRE, 2021)

31. https://www.urbantransportgroup.org/resources/types/press-release/kings-speech-ambitious- transport-reforms-central-governments (UTG, 2024)

32. https://www.gov.uk/government/publications/leeds-trolley-vehicle-system-order-decision-letter (DfT, 2016)

33. https://committees.parliament.uk/work/7088/strategic-road-investment/publications/ (Transport Committee, 2023)