6 March, 2001

The UN NGO Caucus on Sustainable Transport would like to commend the Secretary General for his report on Transport to the CSD.

By and large, the characterization of the problems for the environment and for the poor created by existing unsustainable transport policies is accurate and the scope of the problem reasonably rendered.

However, after an accurate description of the environmental impacts of existing transport system trends, the text focuses entirely on transport system technologies, which creates the impression that both the problem and the solution is reducible to the dissemination of more sustainable technologies.  It also casts consumer behavior as a given, and
recommends only including consumers associations in decision-making.

Rather, the international NGO community sees the unsustainable nature of the global transport system more in terms of generally higher income consumers responding to price signals that are heavily distorted by government subsidies and the difficulties of internalizing the costs of environmental externalities and road use.

The fact that the developed countries remain the greatest contributors to greenhouse gas emissions despite having the most advanced technologies indicates that a focus on transport technologies alone is unlikely to address the fundamental causes of rapidly growing transport sector emissions.

Meanwhile, the words 'internalization of the external costs of transport', and 'traffic demand management', the two measures the most critical to long term sustainable transport systems are not even mentioned.  So long as road space is treated as a public good and charges for its use do not reflect the scarcity of supply nor the costs of its provision, transport systems will always be unsustainable and encourage the over-use of scarce resources.

We suggest adding a Section V on Traffic Demand Management  (TDM) strategies which discusses measures to facilitate the internalization of the social and environmental costs of transport services.   This could be based on Sections C and D of the background submission by UNCHS.  Discussion of consumer behavior should be subsumed under this section.

Furthermore, the vehicle technology problem is focused exclusively on motorized vehicles.  One problem is that technological innovation has focused, quite naturally, on the most lucrative markets, such as for private motor vehicles, while innovations in technologies used primarily by the poor, such as buses in developing countries, bicycles, cycle
rickshaws, and railway systems, have not been disseminated to developing countries either.

We suggest that this section focus more on the mechanisms for facilitating the successful commercial acceptance of pre-existing yet more environmentally sustainable technologies in a developing country context, including a section on the modernization of  human powered vehicle technologies upon which many of the world's poor are dependent.

Finally, insufficient attention has been paid to the global pandemic of road traffic fatalities among vulnerable road users in developing countries.  The public health problems resulting from the transport sector are matched or surpassed by existing road safety problems.   We suggest adding a section specifically on road safety.  This could draw
from text from the NGO submission to the Multi-Stakeholder dialogue.

The document is most disappointing regarding the specific recommendations of what the international community should do.  The prominent focus on the Global Initiative on Transport Emissions, (GITE) is disturbing, as this is a forum funded and driven by the motor vehicle industry (mainly Daimler Chrysler) and the World Bank, with negligible NGO involvement.  None of the most important NGOs working on sustainable transport issues participated or were even aware of the conference held in Cairo sponsored by the GITE.  We feel strongly that the action program which emerges from CSD #9 should not be limited to those areas with which the global automobile industry feels entirely comfortable.

Financing:

We are not convinced that lack of available funding is the problem. Rather, there is funding available in the form of both grants and loans but it is being misused.   We see no need for yet another funding mechanism.  Given the experience with the Global Environmental Facility's OD #11 for transport, where certain industry interests tried to focus the entire program on the promotion of hydrogen fuel cell vehicles in several key developing countries, we are extremely wary of
another financing mechanism where the decision-making structure is less than transparent and the eligibility criteria are unclear.

The GEF focus on Hydrogen Fuel Cells was opposed by the NGO Caucus because they are generally inappropriate in a developing country context, and have yet to be demonstrated as viable in a developed country context where fuel supply and vehicle maintenance problems are less accute.  Furthermore, it encourages scarce international development funds to be used largely to subsidize the development of a market and the necessary infrastructure for a technology which is
currently dominated by a small handful of automobile companies, when the same emission reductions could be achieved for much less cost through bus rapid transit system promotion, or other types of collective and mass transit, non-motorized transport promotion, and a host of other lower cost measures which would promote technologies much more applicable and readily available in developing countries.

Information-

There is an enormous amount of information already available on the web and through other sources, though arguably it is often the wrong sort of  information.   Lack of information per se is much less the cause of the problem than powerful vested economic interests controlling the public policy dialog and the availability of specific types of information.  We
do not see how information provided by the GITE or any other corporate-dominated source is likely to greatly improve transport sector decision-making.   Much more important is financial and technical support for civil society organizations able to voice the concerns of public transit users and non-motorized transport users in a policy dialog which generally ignores them.   Without well informed civil society groups, there is no real consumer for the information.

Special Measures aimed at Africa-

We agree that Africa has particular mobility needs, but other regions also face similar needs.  However, we do not see how building on the GITE will do anything to address these needs.  We would rather see the Declaration on Low Cost Mobility in African Cities issued in Delft in 2000 serve as the basis for any special program for Africa.

Elaboration of an International Action Program-

Again, we are uncomfortable building an international action program  around the GITE.   Action programs have been elaborated for the  transport sector in a host of international forums with much greater international legitimacy than the GITE.  The following other forums and initiatives would provide a better basis for further work:

a. the UN ECE World Forum on the Harmonization of Vehicle Regulations
b. the UN ECE Convention on the Long Range Transboundary Air Pollution and its eight Protocols.
c. The Charter on Transport, Environment, and Health of the Third Ministerial Conference on Environment and Health
d. The World Banks Urban Transport Strategy
e. The UNDP Draft Interim Report on Transport and Sustainable Human Settlements: A UNDP Policy Overview
f. The Amsterdam Declaration of Velo Mondiale
g. The Declaration on Low Cost Mobility in African Cities, Delft
h. The Habitat II Global Plan of Action and the UNCHS Program on Transport and Poverty
i. Various EU declarations on Safety
j. The negotiated positions adopted by various regional transport and air pollution conferences, such as the International Conference on Transport and Air Pollution in Jakarta, 2000, the Regional Air Quality Initiatives of the World Bank, etc.
k. The Recommendations of the Helsinki Commision 17.1 and Austria's submission to the CSD.

Ultimately, the NGO Caucus on Sustainable Transport would rather see the CSD #9 recommendations focus on developing, through the regional UN Commissions, the following:

I. Regional and eventually global tailpipe emission standards
II. Global phase out of leaded gasoline
III. Regional and eventually global fuel specifications
IV. Regional and eventually global road safety design standards
V. Regional and eventually global vehicle design safety standards for both passengers and vulnerable road users.
VI. Global declaration of the rights of non-motorized transport to free and safe access to roads.
VII. Regional and eventually global ambient air quality standards and their explicit linkage to transport system planning and investment decisions.
VIII. Global declaration of rights to basic mobility for women, the disabled, and the elderly.