I've been working through this and my god, there's a serious lack of critical thinking!
This is the draft Safe Speed memorandum so far, as it's flowed with little regard for the finer details of the English - yet.
Memorandum - Road Pricing - Waste not, Want not
(It's a waste, and we don't want it.)
Introduction
Road pricing has a surprising number of advocates. Great claims are made for reducing congestion, but we cannot believe a word of it. Road pricing is flawed, pointless, expensive, inefficient, regressive and intrusive.
There is a severe lack of critical thinking behind the schemes under discussion, and major effects are not even discussed.
Flawed
The dream is that we can reduce congestion by ensuring that roads are more expensive to use when they are likely to be congested. But the proponents have clearly forgotten that 'time is money', and that congestion always costs time. Adding a monetary penalty to the use of congested roads simply makes a small addition to a pre-existing regulatory influence ? that congested roads use extra time.
When we plan journeys, in most cases the first question is: 'Have I got time'? The question: 'Can I afford the journey?' is far lower down the list.
The report says: 'More Londoners think they would drive more often if there was less congestion than people in other regions.' Why is that?
The report suggests that congestion has an associated cost. Of course it does. That cost comes from lost time. Since much of the lost time accrues to businesses, and since businesses have a strong interest in controlling their costs, it should be obvious that we already have a powerful regulatory system in place based on congestion. Businesses make choices based on efficient transport, which may often include choosing a location away from congested town centres.
In summary, implementing a road pricing scheme based on congestion will simply add slightly to existing pressures experienced by all groups of road users to avoid congestion. It will not and cannot be expected to make a fundamental difference.
Before we embark on a system of road pricing we must fully and properly evaluate the self regulation of congestion via the mechanism of increased journey time discouraging journeys. There is great evidence of such mechanisms operating in London, where traffic growth has been far below national traffic growth over 30 years.
Regressive
Road pricing will have a far greater effect on poor people than rich people. In fact rich people really will not care, while poor people may find themselves unable to afford to travel. Clearly this in unacceptable.
Expensive
Any practical system of road pricing will be massively expensive to install and operate. Clearly there would need to be very compelling, very certain and long-term sustained benefits before we should decide to embark on such a scheme.
Intrusive
Most imaginable schemes involve invasions of privacy. The charging authority would have data on vehicle movements, while normally in this country we expect to be able to move freely without being tracked, monitored and recorded.
Error and breakdowns
All technical systems experience breakdowns, so obviously there will have to be provisions for system breakdowns. One particular important area is to consider what happens when the equipment on an individual vehicle breaks down. How will it be possible to know what charges should apply to that use of the vehicle? It might be suggested that a vehicle without a working data gathering system should be automatically disabled, but this would bring serious problems. For example:
* Areas of poor position signal would accumulate disabled vehicles.
* The broadcast parts of the system would become a terrorist target, since all motor transport would be disabled if the system was disabled.
Subversion
Equipment installed in individual vehicles would be very vulnerable to unauthorised modifications, induced failures, or deliberate disconnection.
If instead we follow the London congestion charge model with ANPR, there will obviously be people who would use false or stolen registrations to avoid payment. This could become widespread and contribute to loss of control of the entire vehicle registration process.
Schemes of Electronic Vehicle Identification (EVI) would be vulnerable to tampering, jamming, cloning and simple destruction. And how would a road user know if his EVI tag was working or not? Even if he did know, he would very likely be happy to turn a blind eye for as long as possible.
With a satellite positioning based system data gathered in the vehicle regarding the vehicle?s movements must be ?uploaded? to central administration by some means. The most likely technology would be cellular telephone link, with a data burst sent once a day, once a week or once a month. What would happen if the cellular link failed? Especially what would happen if the cellular link was caused to fail?
Information
It is not acceptable that results of the London Congestion Charge are analysed mainly by its implementers.
3.12 The converse is that a reduction in congestion can be achieved through a relatively small reduction in traffic. The experience of the London Congestion Charge is that a 15 per cent fall in traffic has led to an average 30 per cent reduction in congestion - Congestion Charging Central London, Impacts Monitoring, Second Annual Report, published by TfL in 2004.
Short lived benefit
Since we have seen that simple logical analysis reveals that the main reaons for avoiding congestion has always been and will always be the time spent wasted in congested conditions, it follows that the proposed system of road pricing will have a short term effect, but a long term cost. Consider this illustrative graph describing the effects of a road pricing scheme on traffic nearing saturation limits in a population centre:
At time '20' a system of roads pricing is introduced, and a short term benefit appears. However by time '60' we have returned to the path that would have been followed if the road pricing scheme had not been introduced. But, and it is a very big but, now we have the massive overhead of the road pricing infrastructure absorbing national resources for no benefit whatsoever.
Knowing the charge
A particular major difficulty that has not been discussed in the report, is how would a road user know what charges he would encounter before he makes his journey decision. We might assume initially that most road users are regulars on the route, but regulars are the hardest to discourage with pricing.
Those that do not travel a route regularly may be the easiest to discourage, but how would they estimate in advance what the charge would be? They may get an unpleasant bill at the end of the month, but that forms no part of the discouragement to travel in congested places for the month that it applies. Some people would undoubtedly use a web site to pre-calculate their journey cost. But most people simply would not bother.
Displaying the charge at the roadside would be horrendously expensive and completely ineffective because the folk seeing the charge for a congested road would already be incurring it. It may discourage them from returning, but not from using the road in the first place.
Assuming a satellite based system it would be quite impossible to transmit pricing data for display inside the vehicle because of the huge number of charging zones. Local storage of data on board vehicles would work, especially if integrated with satellite navigation, but once a road user has got into their vehicle and started on the trip they are unlikely to change their plans for a few pounds of extra charges. And the data in the vehicle would need to be very regularly updated to reflect the latest charges.
The problem of being unable to know the charge at the time of planning the journey would make rapidly varied charges reflecting temporary local conditions completely pointless.
We conclude that knowing the charge in good time to avoid incurring the charge would be quite a significant problem. Let?s please remember that half the population is of below average intelligence! Millions upon millions of road users will simply pay the bill and moan without ever knowing where and when the larger charges accumulated.
London Congestion charge 'hassle factor'
Paying the London congestion charge isn?t easy for occasional visitors. It might be argued, and it must be considered that a significant part of the claimed success of the London congestion charge is not based on the £5 fee, but is instead based on the time and trouble required to pay the £5 fee.
...more to follow
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