Anthony Rae writes 26th March 2018 The closing date for the draft TfN strategy (Tuesday 17th April) is three weeks away, so now’s the time to be planning the submissions that you and your organisations/networks may want to be making. Here’s some guidance from an environmental transport perspective as to how to do this.
Scroll down for information about our template ‘10 Core Responses of environmental transport organisations‘
– The TfN consultation page is here so read through your response options; and also note that ‘Transport for the North has commissioned Ipsos MORI, an independent agency, to collect and analyse the results’ – which tells you that there will be an independent element in the review of consultation responses.
– You will see that TfN and Ipsos MORI are steering consultees towards completing an online consultation survey (‘we are asking stakeholders … to provide their views and complete this Response Form’). The previous TfN webpage also advises that ‘If you would prefer to respond via email you can send a written submission to email@example.com ’ It’s understandable that, for a consultation covering an area and population of the whole North of England, an online form is being used but the question for environmental consultees is: does the survey form adequately encompass environmental issues we’re concerned about? To reach your own judgement on this, you can download a copy of the form here.
– Our judgement is that the survey form does not allow an adequate representation of environmental views (so for example the word ‘environment’ only appears once in the survey questions, and ‘carbon’ or ‘air quality’ not at all), so we are suggesting that environmental consultees should not fill in the online consultation but instead submit their views in their own terms and words by email. But whether you choose to fill in the form is entirely a matter for you!
– Before preparing your own response read through the Strategic Transport Plan itself, and its various associated reports (which you can download from this site) to the extent that you are able. To help environmental consultees review the issues they’re concerned about you can find five ‘commentary’ articles about these at the top of our homepage.
– And then we’ve prepared a one-page ’10 Core Responses from environmental transport organisations’ which summarises the issues about the STP from our perspective. You can download it here. We suggest you use it in two ways: 1 circulate it widely across your membership/networks, and also advise them about the information and advice available at www.transportnorth.org.uk and 2 indicate support for it alongside your own independently determined submissions. So the submission from your own organisation, or your own personal perspective, comes first but then add ‘and we also support the ’10 Core Responses’ document.
You can do this in a number of ways: simply attach the document to your email response, and indicate that you support it (using the wording below); or include a sentence in your email like ‘I/We have read the document 10 Core Responses from environmental transport organisations available at https://bit.ly/2ugh5hK [this is a shortened link to the document] and I/we would like to endorse it. Please consider it as part of my/our response, and I/we want you to have regard to it when revising the STP.’ You can also quote from it within your own submissions but please also endorse it as a whole.
Why does it matter to do this? Because the regulatory statute that sets TfN up actually prescribes how its transport strategy should be prepared. And one of the requirements is that “…In preparing or revising its transport strategy a subnational transport body must … have regard to – … (d) the results of the public consultation.’ And therefore if a large number of environmental consultees all say ‘we want you to take account of this single statement of environmental issues’ then TfN are required by law to revise its strategy to take them into account. And we can ask how or whether they have actually done that.
So this really is important, which is why we’ve tried to make it easy for you to help push the TfN strategy in the right, more environmentally sustainable and carbon reducing, direction.
Download your copy of ‘10 Core Responses from environmental transport organisations’ here.