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Volume 3 of the study (.pdf) praises the CCTV camera Automatic Number Plate recognition enforced London Congestion Charge, and simply accepts Transport for London's claims about the reduced level of congestion within the small central zone, without any analysis about the effect which this scheme has had on the rest of London.

The study does note that although the running costs of the London Congestion Charge scheme have been published, the startup costs have not, so it is impossible to see if it is delivering value for money.

There is no mention of the fact that before it was launched, the Mayor of London Ken Livingstone etc. were promising £60 million a year "profit" from the scheme which would be available for other public transport investment, when, in fact not a single penny of this "profit" has been forthcoming, and it looks unlikely that it ever will. The study praises the "strong political leadership" which forced the original scheme, and its westward expansion through, in spite of the vast majority of responses to the public consultations which were negative i.e. Ken Livingstone simply went ahead with the scheme anyway.

Similarly, the Transport for London Oyster Travel SmartCard is praised, for allowing the possibility of better transport planning, by collecting lots of detailed travel pattern data, although there is no evidence that this has actually resulted in any better planning than there was previously. It is also praised for allowing the possibility of more sophisticated off-peak pricing schemes, although, again, the price distortions of the current tariff scheme are not analysed.

Both of these large and complicated projects, are also being used for mass surveillance, in addition to their nominal tariff enforcement uses. Transport for London recently admitted in a Freedom of Information Act request, that the ANPR cameras are deliberately not switched off at night and at weekends and bank holidays, when the Congestion Charge does not apply.

However, surely the Eddington Study should have examined exactly why the Lorry Road User Charge (LRUC) scheme, which would have only applied to the relatively simple problem of heavy goods vehicles and motorways ? This was announced by Chancellor of the Exchequer Gordon Brown in the 2004 Budget, but it has now been scrapped, yet there does not seem to be any mention of it in the study report.

Vincent Geake, the former Chief Executive in charge of this failed LRUC scheme has been promoted to be Chief Information Officer at the Home Office.

The Department for Transport and the Eddington Study seems to use these geographically small scale schemes as evidence for a project which would dwarf them in complexity and scale, i.e. a National Road Pricing scheme.

The danger is that the current NuLabour Government, and possibly even their successors, will pretend that, say, the London Congestion Charge is actually a "successful pilot" for a national scheme, when it is, in fact, orders of magnitude too small.

The Road Pricing Feasibility Study published in July 2004, only vaguely claims that there might be £12 billion a year economic benefit in reduced congestion delays.

However, the Eddington Study is claiming economic benefits of £28 billion a year from road pricing i.e. more than twice as much as the 2004 study:

Benefits of road pricing

[...]

1.36 In the Road Pricing Feasibility Study (RPFS)⁴, the DfT explored the potential benefits of a national road pricing scheme implemented in 2010 using the DfT’s National Transport Model (NTM). This study has explored the impacts of that scheme in the longer term, namely 2025, again relying on the NTM.

1.37 The illustrative national scheme modelled for both the RPFS and therefore this study is a relatively sophisticated, distance-based scheme where prices are based on the marginal social costs of the journeys that take into account costs of congestion and environmental damage, including a carbon cost of £95 per tonne in 2025^5. Charges are capped at 80p/km⁶ with 75 different levels of charges, varying by time of day, by area and road type.

1.38 Clearly, this is only one of many options, and has been chosen only to make comparisons with the present day more straightforward. The evidence suggests that before considering the costs of setting up and running such a scheme, total benefits estimated at around £28 billion⁷ a year in 2025, including GDP benefits of £15 billion a year. The costs of such a scheme are not known at this stage, and pilots should be used to provide a better assessment.

The footnotes in the Eddington Report in Volume 3, page 167 , are revealing:

[8] Feasibility Study of Road Pricing in the UK, DfT, 2004
[9] Defra guidance in line with GES Working paper 140, GES, 2002.
[10] 1998 prices, in line with the Feasibility Study of Road Pricing in the UK, DfT, July 2004.
[11] Feasibility Study of Road Pricing, Annex J: Costs,DfT, July 2004.
[12] As defined in Volume 2.

Does this mean that the headline figures of £28 billion "benefits" by 2025, is simply calculated by taking the 2004 study figures, at 1998 or 2002 prices, and fiddling the figures with a guesstimate about the compound rate of inflation between now and 2025 ?

Read that cost "estimate" again - set up costs of between £10 billion to £62 billion and running costs of between £2 billion to £5 billion a year.

The "benefits" of allegedly £28 billion a year, are really just an guesstimate (fiddled for inflation) of what might potentially be achieved, if the arbitrary reduction targets of 5% reduction in congestion were somehow to be met.

These sort of wild estimates, for as yet non-existent technological magic fixes, never before successfully implemented on a national scale (neither in the UK nor in any other country), with unquantifiable specific benefits to the public, or even to other Government Departments, smacks of the "not fit for purpose" Home Office National Identity Register / ID card scheme.

The Department for Transport and the Treasury must not be allowed to embark on a hugely expensive Road Pricing Scheme enforcement infrastructure, using some mix of roadside radio beacons, portable in car units, GPS satellite positioning and mobile phone technology and Automatic Number Plate Recognition technologies etc.,which could ever be abused to track and limit the freedom of movement and privacy of innocent, law abiding motorists.

We do not see any mention in the Eddington Study, of the effect on Traffic Congestion of increased Car Parking charges or Business Rate increases on Corporate car parking spaces. or Residential street parking permits, or of Park and Ride schemes, none of which need a massive new surveillance infrastructure to be developed.

Distance Based Road Pricing, like ID Cards and the centralised National Identity Register, would be a massive change in our society, and in the relationship between an individual and the state.

We must insist, that there should be a properly funded , independent privacy and security impact assessment of each of the possible multiple options, not just the current Government favourite. These must be published before any "enabling legislation" is rubber stamped through Parliament.

The farce of the lack of any proper detailed costings in the so called Regulatory Impact Assessment for the Identity Cards and National Identity Register scheme must not be repeated.

It is conceivable that a National Road Pricing Scheme which did not infringe our privacy and human rights , and did not add to the problems of defending the Critical National Infrastructure against military, terrorist and organised criminal attack might be designed, but we do not trust the Labour government to even bother to consider these aspects properly.

Feasibility Study of Road Pricing in the UK, DfT, July 20th 2004

The Eddington Study seems to have simply taken the 2004 report into the feasibility of Road Pricing,, and come up with some new figures for alleged "benefits", without clarifying any of the uknown costs, or specifying any actual technical solutions, which were highlighted in the 2004 report.

Slightly more detailed information about these road pricing plans are hidden away in the Annexes to the 2004 report.

Technically these Annexes are available on the Department for Transport website, but they seem to be hidden from the website's own public search facilities, however the Google search engine does find a page with links to the .pdf version of the report, with annexes, which, mysteriously, no longer appear in the HTML version which the website search engine directs visitors to.

• Annex G:Compliance, Enforcement and Privacy (.pdf 44Kb)

  "Privacy" is "handled" by either an allegedly anonymous
  pre-paid , perhaps SmartCard based system which tops up the On Board Units, which decrement the pre-paid charge as the vehicle travels.This is obviously going to be vulnerable to fraud, e.g. through GPS satellite signal spoofing to fool the On Board Unit into believing that the vehicle is not moving in a high charge zone or peak travel time period.

  The preferred option appears to be reliance on a complicated arrangement of so called "Data Cleansing", whereby different public and / or private sector agencies deal with reistration of vehicles, with roadside toll reading of instances travelled and time periods, and another one to handle actual payments. We would need to see a huge amount proof, that the data was really being anonymised properly.

  This Annex G tacitly admits that the whole scheme is currently illegal under the Human Rights Act / European Convention on Human Rights Article 8 the right to privacy, and the Data Protection Act principles of data protection, by saying that the Primary "Enabling" Legislation would need to "take into account" i.e. circumvent, these existing safeguards and protections.

  Surely the proponents of Distance Based Road Pricing must prove massive benefits for everyone, not simply marginal ones for some groups of people, before these protections from bureaucratic red tape control and potential repression, feeble as they are, are further sacrificed ?

• Annex I - System Architecture (.pdf 93 Kb)

  Annex I vaguely describes the preferred, complicated, Data Cleansing model with several different third party government and probably private sector organisations, relying on On Board Units, using an as yet undefined mix of ANPR CCTV surveilance cameras, roadside beacons, mobile phones and the still not yet operational Galileo Global Positioning Satellite systems.

  At least there is a diagram to illustrate the systems arcitecture, which is something which has still not yet appeared for the Home Office's Identity Cards / National Identity Register scheme.

• Annex J - Costs (.pdf 31 Kb)

  "It is not possible to predict with any certainty what a national, distance-based, charging scheme using satellite technology would cost in the middle of the next decade. This sort of system has never been tried before and, without detailed design and testing, it is not possible to specify accurately what would be required. "

  Despite this, they have somehow come up with a guesstimate of £62 billion set up costs, with £2 billion to £5 billion a year running costs, but really they have no clue to the nearest £10 billion or so !