Written evidence submitted by Collaborative Mobility UK [FPS 160]



CoMoUK (Collaborative Mobility UK) is the national charity dedicated to the public benefit of shared transport. We are a collective body for shared transport operators, particularly those in the car club and bike share sectors, whom we accredit. We work closely with local, regional, transport and national authorities the length and breadth of the country and conduct unique research into and with the users and operators of shared transport. We have recently opened a non-accredited category of membership covering e-scooters and started fortnightly forum meetings for local authorities interested in forming e-scooter trials. We want transport to be cleaner, safer, healthier, greener, cheaper, more convenient and more inclusive.


Answers to specific inquiry questions

Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach?

We appreciate that ‘Planning for the future’ is a white paper, but nonetheless it is our contention that while it offers many interesting opportunities for change, it fails to optimise its potential role in helping decarbonise transport while at the same time delivering places to live, work and play that are more sustainable, more pleasant, have cleaner air and do not suffer from congestion or parking stress.

The white paper is correct to single out the complexity and variability of the planning system, but in producing a hypothetically simpler and more rules-based system it must take great care to meet its legal obligations to net zero greenhouse gas emissions by 2050.


We are deeply concerned at the lack of:


-          Any proposed policy that will help deliver decarbonisation not just through building construction itself but also through the transport options that will or will not be built into or encouraged in future building developments.

-          Any integration whatsoever with the Government’s wider agenda on decarbonisation including its legally binding target of net zero carbon emissions by 2050, and in particular the recent policy direction taken by the Department for Transport in its future of mobility urban strategy; transport decarbonisation challenge-setting document of March 2020 and its recently closed call for ideas on transport decarbonisation.


Integrating with these initiatives from a fellow Government department would substantially enhance the decarbonisation performance of both departments’ efforts.


There are also exciting opportunities to take this twinned transport and built environment sectors’ approach to decarbonisation forward, in particular via:




On any Infrastructure Levy, we ask that recognition is given that not all sustainable transport needs are infrastructure-centred. Shared transport is a good example of this: while having appropriate space for the shared modes to use is of course essential, so too is having well-promoted and incentivised provision of shared schemes alongside restraining private car use, in particular solo occupancy private car use. There is an undoubted need to reform section 106 / section 75 or whatever might replace them, but the beyond-infrastructure needs of shared transport must not be forgotten in that process.


The white paper is correct to point to the timeliness of plans. This must be improved via a clear overall direction that unifies transport and spatial planning around sustainability at a top, guiding level with updates on details made on a more regular basis. This is important in sectors that move fast, such as shared transport.


The resource and skills strategy needs to reflect cutting edge best practice – and be kept up to date – in building in low carbon movement patterns.


MHCLG should work with the DfT in using best in class data on shared transport provision and potential, something the DfT is already working on. 


Such is the potential of shared transport to deliver decarbonised, cleaner, better places that we contend that CoMoUK should be considered for statutory consultee status as appropriate, alongside requirements to consult transport authorities.


Housing targets therefore need to go alongside government-wide decarbonisation targets to form an effective twinned approach.



How can the planning system ensure that buildings are beautiful and fit for purpose?

There are many concepts which are aired in the white paper which should have transport decarbonisation (bridging into building construction decarbonisation) built into them:



What approach should be used to determine the housing need and requirement of a local authority?

As we stressed in our response to the DfT’s call for ideas on decarbonisation, MHCLG should adopt a position of avoiding emitting journeys where possible and particularly highly emitting journeys; shifting to more sustainable modes where journeys are necessary and improving the emissions of those remaining journeys. These goals should not be seen as transport ones only – transport is a derived demand and a very significant amount of it is derived from the built environment that people live, work, play and travel in and through.

These goals should therefore form part of how housing need is determined.


How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?

A key weapon in winning this particular war is to decrease the amount of motorised traffic and car parking in an area, which immediately brings dividends in terms of air quality, noise pollution, traffic congestion and parking need. All of these directly contribute to the setting and experience of buildings of environmental, historical and architectural importance.

Thus the planning system must reward measures which help achieve this reduction, which will simultaneously boost progress towards the UK’s 2050 legally binding net zero greenhouse gas emissions target.

The planning system should also block measures which do not help achieve this reduction or which lead to increases in motorised traffic or car parking need.

One way to achieve this is for the planning system to recognise mobility and community hubs. These are places where shared, public and active transport come together with public realm improvements. In doing so they offer people a range of attractive sustainable transport modes in one place which in turn can enable significant reductions in car ownership (on which you can read more detail below).

Such hubs are well established across northern Europe and becoming so in the United States. We have published an introductory guide to them[1] and now have an accreditation system by which to appraise them[2]. As you can see from our map[3], there are hubs in development at 17 locations across England and Scotland. 

Not only can hubs bring positive options together but they can also be part of taking away – or never building in the first place – private car dependency, particularly private car parking.

We contend that such hubs have a major contribution to make to the future of British spatial and transport planning, which should combine to mutual best effect.



Background briefing: the contribution of shared transport to decarbonisation

Shared transport has been delivering on decarbonisation in the UK for many years. By ‘shared transport’ we mean ways of sharing cars, bikes or other micromobilities (where legal) either sequentially through time such as in car or bike sharing schemes; or simultaneously (as in liftsharing in a car to a common destination).

Bike share is obviously tailpipe free and carries a range of benefits:

-          It boosts more active lifestyles (48% of bike share users report health benefits as being a reason they chose to use a scheme);

-          It fits symbiotically with both public transport (23% of respondents use bike share in conjunction with the bus, and 35% in conjunction with the train) and people cycling their own bikes (47% use a personal bike as well as a bike share scheme and 12% of users went on to buy a bike);

-          It re-engages lapsed cyclists (46% of scheme users said it was the catalyst to them cycling again[4]).

Car sharing carries a complementary set of benefits:

-          The vehicles emit far less than the general vehicle fleet (43% cleaner for car clubs in England and Wales[5]) thanks to having a radically different composition with, for example, no diesel car club vehicles in London compared to 40% of private cars being diesel nationally;

-          It cuts miles driven. We find that car club users in London drive 526 miles less per year after joining a car club. We argue below that reducing vehicle miles travelled needs to be a key aspect of Government policy;

-          It cuts car ownership – 45% of long-term car club members in London cut their vehicle ownership[6];

-          It accelerates modal shift. For example in Scotland 16% of car club users walked more; 10% cycled more and 26% cut their private car use[7];

-          It makes much more efficient use of cars and so requires far fewer of them to fulfil journey needs, freeing up valuable space and cutting congestion. Private cars do not move for c. 95% of the time and only around 15% of which are ever in use at any one time. In a forthcoming piece of work relating to car clubs in London, we were able to credibly use the multiple of 94 members per car.

-          Liftsharing’s delivery of decarbonisation, and its potential to go further, should also be seen by Government as part of the answer on decarbonisation. It is an excellent example of what can be done using existing assets, existing journeys and existing infrastructure more intelligently and intensively to drive out significant amounts of carbon and other greenhouse gas consumption. This has particular applicability to journeys where public and active transport struggle to provide sufficient options for people, as in many rural areas. Before Covid-19 there were 36 million empty seats during the morning commute[8].

-          Also involving pre-existing assets on the ground is ‘peer to peer’ car sharing, which is already a self-identified evidence gap for the DfT. It should go about filling it, linking this to its work on sustainable rural mobility.

-          All of this results in direct carbon savings. We have done some work in Scotland across all modes and in London on car club to look at potential scale. This shows dramatic levels of potential: in the case of London, 82,000 tonnes of carbon annually based on mileage reduction across car owning households and a reduction in the number of car owning households on a plausible scale by looking at a range of factors such as public transport provision levels, households with lightly-used cars and their proximity to existing shared transport to devise a proportion of switchable households. In Scotland we calculate the figure to be 87,000 tonnes from car club; 135,000 tonnes from lift sharing; and 64,000 tonnes from bike sharing[9].

-          Shared transport is popular and growing across the country, with an indicative total of c.550,000 car club users[10] (note this total does not include other forms of car sharing), and c.305,000 bike share users[11]. One platform alone (Liftshare) in the liftsharing market has over 1 million members and ‘peer to peer’ ways of sharing cars are gaining in popularity all the time.


On behalf of CoMoUK, with kind regards.


November 2020

[1] https://como.org.uk/wp-content/uploads/2019/10/Mobility-Hub-Guide-241019-final.pdf

[2] https://como.org.uk/shared-mobility/mobility-hubs/what/

[3] https://como.org.uk/shared-mobility/mobility-hubs/where/

[4] All drawn from 2019 CoMoUK bike share user survey: https://como.org.uk/wp-content/uploads/2019/11/CoMoUK-Bike-Share-Survey-2019-final-1.pdf

[5] CoMoUK 2019 England and Wales car club user survey: https://como.org.uk/wp-content/uploads/2019/06/EW-report-v4.0.pdf; CoMoUK 2019 Scotland car club user survey: https://como.org.uk/wp-content/uploads/2020/03/80264-Comouk-Car-Club-Survey_final-WEB-R-Edit.pdf

[6] As-yet unpublished research available on request.

[7] CoMoUK 2019 Scotland car club user survey: https://como.org.uk/wp-content/uploads/2020/03/80264-Comouk-Car-Club-Survey_final-WEB-R-Edit.pdf

[8] https://www.creds.ac.uk/publications/where-now-where-next/

[9] CoMoUK Scotland vision: https://como.org.uk/wp-content/uploads/2020/03/CoMo-Scotland-Vision-Summary-Final-Final.pdf; London figures from as-yet unpublished research available on request.

[10] This is a raw data figure for 2019-20, including Covid effects.

[11] This is a Covid-affected figure, being from April 2020.