Transport for the North – Draft Strategic Transport Plan and Independent Integrated Sustainability Appraisal Consultation

The Liverpool City Region Mayoral Combined Authority welcomes this opportunity to comment on both the Draft Strategic Transport Plan and the Independent Integrated Sustainability Appraisal. The Liverpool City Region Combined Authority (LCRCA) was established in May 2017, following the election of Steve Rotheram as the LCR’s first directly elected Metro Mayor. The Mayoral Combined Authority draws on new powers and funds that were made available through the 2015 Devolution Deal and follow-on deal in 2016. These powers include strategic transport planning across the City Region (including the management and maintenance of a Key Route Network of local roads), alongside economic development and regeneration, housing and spatial planning, employment and skills. It also exercises powers over a devolved and consolidated multi-year funding package. Transport and connectivity are core elements of both our Devolution Deal and the Liverpool City Region Growth Strategy, along with the Mayor’s commitment to becoming a zero-carbon city by 2040. This response is submitted by the Mayor of the Liverpool City Region, on behalf of the LCRCA.

1. Transport for the North’s vision and objectives. As a constituent member of Transport for the North (TfN) and having worked closely with TfN colleagues during the development of the Draft Strategic Transport Plan (STP) and its supporting documents, we are able to say that we fully support the Plan’s vision and objectives. We would also like to confirm that the LCRCA is absolutely confident that it is able to contribute significantly to the achievement of this vision. This is because it benefits from a large number of the important economic centres identified in the Northern Powerhouse Independent Economic Review (NPIER) as well as the prime and enabling capabilities identified in the NPIER and the STP. When combined with its international reputation, its geographical location, its increasing ability to contribute to a growing visitor economy, its resources and its undoubted potential to attract investment, the LCR feels it can contribute significantly to economic growth across the North and, in turn, help rebalance the economy. The comments offered below are, we feel, constructive in nature and should help contribute to the develo0pemnt of the Final STP. Whilst the Plan’s objectives on pages 12 and 13 are interdependent, ‘Transforming economic performance’ is probably the primary driver of the Northern Powerhouse concept and, hence, should perhaps take precedence in the list. It may also help the reader if the links between the intended outcomes of each objective (“this plan will…”) could be strengthened and referenced throughout the STP to demonstrate clearly how they will be delivered.

We really welcome the visibility the Visitor Economy sector has in the STP in terms of its value to the Northern Economy, and that transport forms a core part of the overall visitor proposition. However, it could possibly do a little more to recognise the growth potential that exists within this sector, given that the North holds some of the most-visited cities in the UK, together with internationally significant national parks, sporting venues and cultural attractions, and that without transformed transport linkages to these areas, their potential growth will not be realised. It also acts as a substantial aid in leveraging inward investment across all sectors of the economy in the North. 2. Transport’s role in driving the North economy Whilst the STP quite rightly recognises that the North needs to capitalise on the potential of all its cities, towns, economic centres, this aspiration needs to accord with what is still an Emerging Vison for the Northern Powerhouse Rail Network and not put any of its key cities at any relative disadvantage in terms of transformed transport connectivity, especially when compared with the vision of the original One North proposition1. With respect to transport links to other parts of the North and the UK being critical to local long term success, the LCR will work with TfN and DfT to determine how this might be achieved. It will also continue to work with TfN on analysing available data sources to ensure they are applied appropriately and fully understood. For example, it is important to understand whether Rail Freight analysis explicitly recognises the potential for the North’s ports to play a more important role in national logistics than at present (for example by easing future demand growth on congested southeast infrastructure) or whether the analysis is trend-based, such as linking freight to population growth or to growth of the prime economic sectors (prime capabilities) identified in NPIER. Clarity here is important, since the increased use of Northern Ports is a key area of concern for the Liverpool City Region, with the potential for the North illustrated by the diagram below:

1 www.manchester.gov.uk/download/downloads/id/22093/one_north.pdf

It is important that the forecasting of future transport demand in a transformed Northern Economy, which is currently predicated on population and business growth, adequately encapsulates growth from tourism as this may impact on areas with a heavy reliance on the visitor economy or on cities with a particularly dominant visitor market. The LCR accepts the three identified roles below that TfN considers will help to drive the economy, and the associated agglomeration benefits, but a number of comments are provided for both information and consideration. It is fully accepted that the STP is a strategic document and hence is unable to reflect all data or information that partners may consider to be relevant but the LCR would be willing to discuss any of the comments below with TfN colleagues as many have originated from the content of the draft STP and have not necessarily been the subject of discussion before: Connecting people i) “In 2011, almost 500,000 commuters travelled over 30km to work in London – double the number who commute that distance across all six major city regions in the North.” The analysis may wish to acknowledge that it is possible that this might, in part, be a function of the high cost of housing in proximity to central London. ii) “A relatively small proportion of the North’s population commutes by rail.” This is true in comparison with London, but low levels of rail commuting tend to be seen across UK. Whilst not dismissing the potential for rail to achieve a greater share, and indeed other public transport modes, it would be interesting to understand how the analysis considers the effect of the congestion charging zone, for example. Likewise, the analysis could

usefully highlight where rail already has a much higher share, such as that achieved on corridors served by the Merseyrail network. iii) A “seamless travel experience” is dependent not only on integrated timetabling and journey opportunities but also full integration between modes. This is an important aspect, as such integration forms a key part of the transport mix in the economically successful comparator areas such as the Randstad in the Netherlands. We would also like to see reference to connectivity by sea to the North. Investment in a new cruise liner terminal in Liverpool will clearly need good road and rail access if it is to succeed in attracting passenger volumes, as well as being an attractive proposition to the cruise operators. iv) With regards to “Delivering nationally significant infrastructure projects”, we note Liverpool is not directly referenced in the context of future HS2 hubs. v) “By 2050, there is potential for the North to have … all air freight flying from the North’s airports, compared with just 4% in 2016” – we assume this means all the North’s air freight, rather than all the UK’s air freight. More importantly, there is broad concern regarding international connectivity; whilst the International Connectivity Commission report has been well received and included some useful analysis, it is important to understand what the next steps are. It may also be considered worthwhile to mention the North’s ports in this section – whilst these play a smaller role in international passenger connectivity, it is nevertheless an important role. Connecting businesses i) “supporting the international connectivity of the North” – it is considered that greater emphasis needs to be placed on connectivity to our regional airports, as a means of generating more business from international markets, and how their plans or strategies for growth can be integrated into the STP. Liverpool John Lennon Airport, for example, has a long term investment strategy and plans for growth, especially with respect to the US and main Western European cities/hubs. Moving goods i) It is considered that greater recognition could be given to the potential for the Northern ports, and indeed inland waterways such as Manchester Ship Canal, to play a more significant role nationally, both delivering goods closer to the end user, providing a significant saving on road and rail mileage and specifically reducing growth pressures on congested London & Southeast infrastructure, thus having a positive national impact. Indeed, analysis centring on the Liverpool City Region (as shown below) demonstrates the potential benefits in journey time for logistics operators using the Port of Liverpool:

Source: Liverpool LEP https://www.liverpoollep.org/wp-content/uploads/2016/01/SUPERPORT-FOLD-OUT-LOW-RES2.pdf ii) The STP states that “Road freight will continue to be the dominant mode by which goods are transported it is inherently less expensive to handle goods by road, by comparison with rail freight”. We would add that when whole costs are taken into account (including environmental costs) rail freight can indeed be competitive; this is particularly the case over long hauls, but can also be the case over shorter distances where volumes carried are both high and frequent. As such, its contribution to the effective movement of freight should not be overlooked.

3. Identifying the major strategic interventions Northern Powerhouse Rail Northern Powerhouse Rail (NPR) is a key investment that will help transform the North’s economy, through enabling greater agglomeration and, where new investments in infrastructure are made, releasing capacity on conventional routes. We therefore welcome this work programme, particularly the efforts to secure provisions for a ‘touchpoint’ on the HS2 network, specifically the vision for both HS2 and NPR services to reach Liverpool via a new line. We strongly suggest that synergies may be gained by delivering NPR to the same timescale as HS2, especially on those sections where the proposal is for NPR operations to share HS2 infrastructure. There also appears to be an implicit message for NPR that it must integrate with HS2 to achieve benefits, yet this does not appear to be highlighted with sufficient emphasis. The STP states that “A step change in the level of rail connectivity between some of the North’s largest cities is required” but it is perhaps important to remember that the

NPIER was clear in its assumption that underpinning transformed economic growth meant transformed connectivity between all of the North’s key cities2, not just some of them. It also states that “If the evidence demonstrates that significant upgrades to the Hope Valley corridor do not look promising in terms of moving towards the transformational outputs, TfN will consider the case for and further assessment of a new line between Manchester and Sheffield.” We would stress that a new line between Manchester and Sheffield may well not be viable unless it also serves Leeds, as in the original One North concept. This is important in terms of maximising pan-Northern agglomeration, and whilst consideration on each NPR corridor should be given to the potential benefits from serving other significant economic centres such as Bradford, this should not be to the detriment of the core cities and the North as a whole. Although the evidence within this section is useful, there is little or no detail provided regarding train frequency or capacity compared with the current offer. We suggest that TfN highlight the importance of regular interval service frequency to maximise connectivity benefits, i.e. rather than any ‘bunching’ or uneven distribution of service patterns in each hour. The section is also too focused on infrastructure at the expense of service provision, and the real transformational benefits such as faster journeys; improved frequency; better integration with other services; transformed station environments (and the associated potential for wider regeneration/development); or being able to travel from one side of the north and back within a business day. We would welcome the opportunity to discuss and aid development of the service specifications, particularly to ensure the best outcomes for the North, and to ensure full integration with local transport in the City Region, particularly with the Merseyrail network. Long Term Rail Strategy The overall aims of TfN’s Long Term Rail Strategy (LTRS) are welcomed. They largely recognise the current weaknesses of the rail network and the opportunities investment can offer to help support a transformed North. We request that within its strategy, TfN takes account of its Partner’s plans, aspirations and needs; for example, the recently updated Liverpool City Region Long Term Rail Strategy (noting that Merseytravel is also the authority for the Merseyrail Electrics Franchise). “The North’s rail network lacks sufficient capacity for growth and is severely constrained by on-train congestion, low journey speeds and poor punctuality” – Whilst we would not disagree with this, it should also be noted that in many places, the network is also constrained by track congestion, for example, the West Coast Main Line north of Crewe. The LTRS recognises the joint management of the Northern and Transpennine franchises as a way which will influence change; Merseytravel’s local management of the Merseyrail electrics franchise, and the successes this has resulted in, is a prime example of what can be achieved in changing performance and passenger perception.

2 NPIER Workstream 4, Scenarios for Future Growth in the North

It is welcomed that the LTRS defines both passengers and freight as “customers”, demonstrating the importance of both to the network. However, in terms of aspirations for average speeds – “at least 40 mph for local services, 60 mph for inter- urban services, and 80 mph for long distance services” – whilst generally supporting these aspirations, we would caution on practicality; for some urban routes with stations at close intervals (such as the Liverpool to West Kirby line or Leeds to Skipton line), this may not always be deliverable. It is somewhat disappointing that the LTRS does not explicitly recognise the benefits of electrification, for example, as set out in the recommendations of the North of England Electrification Task Force3. Notwithstanding issues giving rise to cost over- runs on the Great Western project, the benefits of electric trains from an environmental, operational and ridership perspective are proven. In addition to this, electrification to freight terminals explicitly enables freight trains to deliver far more efficient operation than otherwise, thereby improving overall network capacity. We acknowledge there are emerging technologies which in future generations may offer potential, but to date none of these are proven to offer the same benefits, deliverability and energy efficiency. As such, it would be unreasonable for investment in the North to be stalled until such evidence is available, since the economic imbalance will nevertheless continue to grow. We would also expect to see further detail of where HS2 and NPR hubs will combine (such as in Liverpool). Indeed much of this section of the STP would benefit from greater detail on the conditional outputs of the full LTRS. A minor point is a query relating to the stations included in the map depicting the North’s passenger railway network; Hamilton Square in Birkenhead has the 18th highest entrances/exits in the North West (ORR) but some smaller stations are identified as major on the map. Overall, this section feels somewhat thin on detail; there are many references to specific schemes, but fewer on specific outputs. The Major Road Network for the North Whilst fully supportive of the need to define and agree an integrated network of national and pan-Northern strategic roads to improve productivity and support growth, we consider that the ambiguity with respect to TfN’s Major Road Network (MRN) in relationship to DfT’s similarly named and proposed MRN, may be a cause of some confusion. As such, there is a strong possibility that there will be some discrepancies when the two networks are finalised. The STP recognises that “it is the rest of the road network, or the last mile, that can make all the difference as to whether goods or people arrive in time, or as efficiently as possible”. There should be a recognition of the impact of investment in the MRN on local networks, since investment in local networks will be needed to support the MRN - having efficient journeys that then hit congested local routes will undoubtedly have detrimental impact on the North overall.

3 Northern Sparks – Report of the North of England Electrification Task Force (March 2015)

Integrated and Smart Travel Technology is improving the way people pay for goods and services, and we welcome that this is recognised through the Integrated and Smart Travel workstream. In order to maximise travel opportunities across the North, both to reduce use of the car and reduce overall generalised journey times, greater integration between modes will be necessary, as is practised in the Randstad, for example. This is not to detract from emerging technology-led initiatives such as ‘Mobility as a Service’, but there is a concern that these may lead to increased, rather than reduced, vehicle traffic. We would, therefore, ask for future research by TfN to consider examining ‘best practice’ in comparator city regions, to understand what transport strategies can help to drive economic growth. The Strategic Development Corridors Whilst understanding, and supporting, the general approach adopted for the Strategic Development Corridors (SDCs), it is considered that there is a need for greater clarity in the STP for those who are not too familiar with how they were created and delineated and why for example, there are not other defined corridors between various sets of destinations.

4. Delivering TfN’s Investment Programme Stronger partnerships Partnership working is strongly welcomed and encouraged. The relationships with the Welsh Government, Transport for Scotland and Midlands Connect may prove to be particularly important. Innovation The focus and awareness of technical innovation, and what it may mean for the future, is welcome. This is an area where horizon scanning is invaluable, for identifying those innovations being adopted by other regions, both nationally and internationally. Whilst it is acknowledged that planning for technological change beyond what we can see five years at a time does carry a higher level of risk, in the short term, we should be able to make better estimates of innovation on demand for transport. Northern transport skills It is not clear exactly how or what TfN could do or intends to do to help address the skills gap. Clarification is sought on this important area of work and the LCR is prepared to work collaboratively to address this problem. Funding and financing TfN acknowledge that “the significant part of the resources required to deliver TfN’s investment programme will need to come from Central Government.” We note, however, the Government’s continued stance on TfN’s role being strategic, and

therefore it will be important to see what influence TfN will actually have on road and rail investment, since it will lack the same revenue raising and borrowing powers as Transport for London and is dependent on finding other sources of income to deliver the STP. It follows that the Strategic Case for any proposed scheme should restate: a) the importance of rebalancing the UK economy; and b) the benefits that accrue to the rest of the country (in particular London and the South East) through reducing the regional disparities, and having more than one national growth hub. Appraisal and analysis The strong approach taken by TfN to appraisal and analysis is welcome; specifically that rigour in this area will reduce the risk of business cases for investment being challenged. As above, we argue a key part of this – in the strategic case, should the tools not be available to support the economic case – lies in a heavy emphasis on rebalancing the economy. There may be value in reviewing NPIER as part of the analysis work; this important piece of work has proved invaluable at highlighting what the North might achieve, but whilst it shows improved growth from what the North has previously seen, it is less clear as to what extent it can be described as transformational. We query how TfN’s analysis is conducted in relation to the programme of investments; clearly network level impacts are also important, not simply the impacts between cities. In developing a business case, each SDC will need to be treated separately, but this should not exclude the estimation of pan-North benefits. It is equally important to understand the impacts of any dilution of investment, for example the differences in economic impacts between the emerging NPR proposals and the original conditional outputs of the One North proposals.

5. The Integrated Sustainability Appraisal The Integrated Sustainability Appraisal (ISA) is a welcome publication, which should help to support the STP from a sustainability perspective. As we move to the final version of the STP and ISA, it will be important to ensure that TfN can convince its partners and stakeholders that the ISA has sufficiently addressed some of the ‘big picture’ questions, principally related to transport demand in general rather than any construction issues, in terms of pollution, health risks etc. For example, will greater clarity be provided on: i) Why is there no assessment of the contribution of rail electrification in terms of contributing to a reduction of environmental impacts within the STP? We would have expected the ISA to at least identify this. ii) What can elements in NPR do to encourage mode shift towards more environmentally friendly modes? iii) Has the level of induced road traffic demand (from either highway or related schemes) has been assessed?

iv) Have the concerns of Non-Governmental Organisations (NGOs) about air pollution been adequately addressed? v) No evident assessment of the relative/joint merits of road/rail schemes across the Pennines – this should have been raised from an environmental angle. Based on previous and indeed continuing concerns expressed by NGOs (e.g. Campaign for the Protection of Rural England or CPRE), the ISA should perhaps highlight the need for a clearer link to improving air quality within the objectives of the STP. The STP says “the Government has set a target to reduce carbon emissions by 80% by 2050, which investment in the North’s transport network can support” but there is no evidence on how this will be achieved, and with the recognition of the increase in journeys, it is difficult to see how this will be achieved unless through direct intervention. The STP has passing references to sustainable travel, primarily in a local context, and we believe that the ISA should be looking to strengthen the STP in this area, especially as it is heavily road based. An option would be, for example, to look at reducing access to some of the economic centres through increased park and ride/rail or distribution centres, or the promotion of coach travel for longer journeys.

6. Overall The LCR has worked with TFN since its inception, including on the various workstreams and the preparation of earlier drafts of the STP. With that in mind, the LCR is happy to support the vision and objectives of the current draft STP and what TfN, on behalf of and with the support of its partners and stakeholders, is hoping to achieve for the whole of the North of England. It is a bold and ambitious Plan that will require significant investment if these goals are to be achieved. With that in mind, we encourage Government and, in particular, the Department for Transport to demonstrate its belief in both the Plan and the Northern Powerhouse concept by providing the necessary levels of funding to enable investment in transport infrastructure that will be truly transformative. We believe the STP, especially when refined following consideration of comments received via the consultation exercise, will go some way to giving businesses the confidence to invest in the North. The LCR will continue to work with and support TfN in its delivery.