The Local Government Technical Advisers Group (LGTAG) thank the Select Committee for the opportunity to give written evidence and are more than willing to discuss our submission further as required. We include a contents page and a Summary of our evidence in the last section, We hope these will be helpful.
Contents
Appendix A Joint submission to the Department for Transport on modelling and Appraisal of schemes (includes also individual submissions by LGTAG CIHT and TPS)
Appendix B LGTAG submission to Transport Select Committee in March 2021 on Smart Motorways (includes background on generated traffic from capacity increases)
1.1 The Local Government Technical Advisers Group (LGTAG) is an Association of Technical Officers providing public services for Local Authorities. Our officers deal with public services like waste, recycling, street cleansing, parks, recreation, Planning, Council property (including housing) design, construction and maintenance, roads and transport, flooding and coastal protection etc. Our raison d’etre is to share best practice and advise central and local government bodies and representatives on problems and solutions relevant to these subject areas. Our membership is mainly senior staff in London and Metropolitan Boroughs, Counties and Unitary and District Councils as well as Consultants and Service providers where such services are outsourced to the private sector.
1.2 We are particularly concerned with our own Transport Infrastructure projects and indeed those of other bodies which have immediate transport and planning implications on local authorities. We should add local government as a whole, is responsible for 98% of the road network providing essential links for buses, freight, pedestrians, cycles, cars etc. supporting local communities and economies.
1.3 Also, of relevance to this Select Committee inquiry - we submitted evidence to this Committee in early 2021 into ‘Major transport infrastructure projects: appraisal and delivery’ and ‘The Roll-out and Safety of Smart Motorways’ (please see Appendix B) and to the Housing, Communities and Local Government Committee of Parliament on the Government Comprehensive Spending Review 2020. As this Transport Committee inquiry follows a National Audit Office report, some of our evidence to that HCLG Committee inquiry is relevant. We include two extracts here but where appropriate we will quote or paraphrase other parts (we can provide a copy of our full evidence if required):
“We identified the following priority themes for investment which should perhaps be reflected in at least funding and consequentially appraisal and delivery of major infrastructure projects:
Closing comments
“There needs to be more delegation of planning and approval of development and infrastructure to the regions and authorities of the country who are best placed to understand the problems and needs.
2.0 Introduction to the issues in NAO report we wish to comment on
2.1 We note that the National Audit Office report expressed concerns and our summary comments are as below:
2.3 We have addressed all the points, to a greater or lesser extent, which this committee asked for evidence bearing in mind the summary of our views on the thrust of the NAO report in para 2.1 above and the background on road schemes as described in paragraph 1.3. We also attach appendices which provide further details of our analysis to support our submission of evidence.
3.0 Responses to the specific points raised by the select committee in the invitation
3.1. How effectively the RIS2 enhancements portfolio has been managed to date:
3.1.1 We do not believe that the country’s needs and priorities for transport for the public and businesses were properly identified and analysed at the beginning to deliver the real priorities for transport and use. The lack of this early analysis and then the prioritisation of enlarging already large roads in the RIS schemes has inevitably led to difficulties in managing the portfolio of the programme.
3.1.2 As mentioned above the Strategic Road network is only a small (but recognisably busy) part of the Highway network, let alone the transport network as a whole. Furthermore, there is substantial, including governmental, evidence (particularly SACTRA 1994 and SACTRA 1999) that the road schemes being programmed will not help the economy. We do not believe that the RIS programmes will play an important role in improving the country’s infrastructure and boosting local economies. It should be noted that most of the ‘economic’ benefits quoted have been calculated using an unreliable and out of date system. The so-called benefits are based largely on car commuter’s travel time savings which in turn are based on spurious assumptions and calculated ignoring consequential delays elsewhere. Appendix A – provides a series of documents presented to the DfT and agreed by various professional bodies, giving the details of our concerns, on how such so called ‘economic’ benefits are calculated and misleading.
3.1.3 We seriously doubt future investments in road infrastructure will deliver the Government’s overarching policies of levelling-up, and dramatically cut carbon emissions. On the former it is notable that many, and particularly the most expensive schemes, are in the south of England (e.g. radial routes leading towards London, M25 junction works, the Lower Thames Crossing and Stonehenge). The schemes anywhere near our major cities and particularly London will generate substantial extra car traffic with consequential increases in carbon emissions and, even with fully electric cars, ingestible particulates from tyres and road surfaces. It is notable that the traffic on the Strategic Road network is responsible for about 30% of the road-based carbon dioxide and particulate matter. Large schemes will also consume large quantities of concrete and steel with their associated carbon dioxide during fabrication. Further, several schemes (e.g. A3/M25) result in the loss of substantial numbers of mature trees.
Whether risks to the enhancements portfolio for the remainder of the RIS2 period are being well managed
3.2.1 Regardless of our view, in most cases RIS schemes are unlikely to provide the benefits the country needs with the ‘easier’ schemes more likely to be implemented earlier, making the worst points of congestion even worse, throughout the country. We are unconvinced that the details of implementation have been adequately considered before construction. (The M2/A249 junction is a particular example. Here M2 traffic travelling east has not been able to access the significant town of Sittingbourne with its large industrial area, the whole of Sheppey and the port of Sheerness without extensive diversion through equally congested towns. Similarly, from these areas, traffic has not been able to access the M2 eastbound. Further, with the same construction closure, traffic coming from the south and west using the A249 cannot proceed eastwards along the M2.)
3.2 What the impacts of delays and cost overruns are on the overall programme, and whether the revised programme can be delivered to schedule and on budget
3.2.1 Delays and cost overruns will result in the easy schemes being brought forward with consequential even worse congestion elsewhere.
3.3 What progress is being made on planning for the next Road Investment Strategy
3.3.1 We cannot answer this question although we hope that some of our individual local authorities are being consulted not least to avoid situations such as the M2/A249 junction as above.
3.4 What lessons from RIS2 need to be incorporated into RIS3 to ensure it is achievable and delivers on policy objectives
3.4.1 As described above and in the Appendix A we do not believe that most of the RIS programmes will deliver the real National or Local policy objectives. There is now a significant body of evidence, that highlights the issue of induced traffic leading to a roads programme, which is unsustainable.
3.5 Whether the Government’s current and forthcoming roads investment programme is meeting the current and future needs of consumers and business?
3.5.1 As discussed almost throughout our submission we do not believe the Government’s current and forthcoming Roads Investment Programme is meeting the current and future needs of consumers and business. The current and future needs and the methods on how these could be measured are fully covered in our Appendix A. The most telling statement in the Position Paper of this Appendix is by the Chartered Institution of Highways and Transport (CIHT):
“There is a widespread feeling among our members that current systems of decision making are not leading to desirable results. Governments have repeatedly declared their intentions to create a healthy society, fight climate change, reduce poverty, strengthen local communities, and tackle many other vital issues but the schemes that are eventually built do not reflect those goals.” The reported declared intentions above could be a good starting point for what the road investment programme should be targeting.
3.5.2 Similarly in LGTAG’s evidence to the HCLG Select Committee as described in Para 1.3 above are other appropriate objectives for the Strategic Road Network:
3.5.3 Often stated objectives for consumers and businesses are to reduce congestion and improve reliability of journeys.
3.5.4 For congestion (on the road network) whole journey times from origins to destinations are probably the best measure. In terms of the Strategic Road Network, this element of most journeys is usually not the critical factor but congestion in urban areas is. Strategic Road enlargements usually result in substantial extra car traffic adding to the urban congestion. A government report (SACTRA 1994) on induced traffic from Trunk/Strategic roads confirmed this such that a Transport Minister stated at the time that the Government would not have built so many roads if they had known this before. The same Minister (no longer in Government) has confirmed to one of the contributors to our evidence.
“And yet National Highways still have a huge capital program ---- Each new generation needs to learn the lesson anew.”
3.5.5 It is also of note that other past Ministers and Secretaries of State have been fully aware that building more roads is not the solution to many of the problems. The present Father of the House stated that he wasn’t going to build roads for people to commute in their one and a half tonne metal vests and Secretaries of State for Transport/Environment from both main parties certainly followed more Environmentally aware policies than adding to the Strategic Road Network (John Selwyn Gummer and John Prescott).
3.5.6 The following links show practically the results of past traffic generation effects of road schemes:
http://www.eco-logica.co.uk/pdf/wtpp05.2.pdf - see editorial and pages 28 onwards. Written in 1985 this work studies roads built in and around London. The increase in peak traffic in one year is remarkable and the all-day traffic tends also to double within 5 years.
https://bettertransport.org.uk/roads-nowhere/induced-traffic This one is a compendium of work completed over many years, including SACTRA 1994.
3.5.7 In larger cities road enlargement often increases overall congestion and traffic delays over whole journeys. This may be counterintuitive but can be explained.
3.5.8 Transport models and ‘approved’ processes used to predict future demand usually grossly underestimate induced traffic and overpredict future traffic volumes without the scheme. There are many examples of where traffic has built up quickly after a scheme has been completed and then doesn’t, and often cannot, increase further.
3.5.9 As mentioned above, reliability of journeys is critical for the public and business. Large roads out of balance with local roads at the beginning and end of journeys will tend to increase the risk of major hold ups and the network will not have reasonable alternatives to mitigate traffic incidents.
3.6 Whether the Government’s roads investment programme aligns with other policy priorities, such as decarbonisation, nature recovery, levelling up, productivity and growth?
3.6.1 We consider there is little evidence that the road investment programme aligns with most of either central or local government’s policy priorities as described above.
3.6.2 As far as productivity and growth are concerned these are objectives that we consider most people and almost all our leaders would support. However, for business, predictability of journey times is critical, not least in managing business fleets and choice of location of plant and distribution centres (including retail). Reliability, as described in the paragraph immediately above, is the critical aspect of predictability and this will not be helped by a Strategic Road programme. While productivity could perhaps be increased if overall journeys take less time to make, but Strategic Road capacity increases will in most cases, not help.
3.6.3 Achieving growth in the economy is dependent on many factors outside the Transport sphere. Again SACTRA 1999 identified that Strategic Road enlargement is unlikely to help significantly. Nevertheless, access to development sites (largely by local transport improvements) and allowing other areas than the south to prosper are critical. However, the preponderance of RIS schemes and expensive schemes in the south cannot really help growth where it is needed in any case.
3.6.4 It is now accepted that being in heavy traffic or living near a road with heavy traffic is risky compared with being in other places in a community. Further, evidence now shows that many different pollutants along busy highways area higher than areas in the community, increasing the risk of harm to people who live or work near busy roads. The number of people living "next to a busy road" may include 20 to 30 percent of the urban population in the UK. Our knowledge and understanding of the health effects of traffic pollution is continually improving. There is significant evidence that traffic pollution causes asthma attacks in children and may cause a wide range of other effects including the onset of childhood asthma, impaired lung function, premature death and death from cardiovascular diseases and cardiovascular morbidity. The area most affected, is that within the band of 0.2 to 0.3 miles (300 to 500 metres) of the highway.
3.6.5 The 25 Year Environment Plan sets out the ambition to establish a Nature Recovery Network, now underpinned by the nationwide delivery of Local Nature Recovery Strategies under the Environment Act 2021 and recently developed in the Environmental Improvement Plan. A key aim is to ‘restore 500,000 hectares of wildlife-rich habitat outside the protected site network’. This follows recommendations from the Lawton Review to increase habitat connectivity, thereby reversing trends of biodiversity loss documented in the State of Nature Report 2019. The Nature Recovery Network is envisaged to include green infrastructure which will deliver a wide range of ecosystem services that can benefit society; delivery of this ambition was recently set out in the National Green Infrastructure Framework. With Government investment there is the opportunity for the systemic enhancement of vegetation management systems on the ‘soft estate’. For example, changes to road verge mowing regimes to encourage wildflower diversity and the transformation of grass cuttings from a waste product to a resource. This could be a largely self-funding, nature-based solution for Biodiversity Net Gain, carbon capture, emissions reduction, and flood risk management as part of a bio-based circular economy through sustainable utilisation of biomass. The principal biodiversity opportunity associated with the 260,000 ha of the UK’s road verges seen by Plantlife International is the potential to reverse the 97% decline of species-rich grassland since the 1930s.
3.7 How RIS3 should take account of technological developments (more home/remote working), and evidence (such as smart motorways and potential alternatives to them)?
3.7.1 Our submission to this select committee in April 2021 was on the Inquiry on the Roll-out and Safety of Smart Motorways (attached as Appendix B). Our chief concerns on these at the time were:
3.7.2 Our written evidence also included appendices giving additional detailed evidence on the traffic generation aspects of the Strategic Roads.
3.7.3 As we do not consider expansion of already high-capacity roads will provide any real benefits we could not support any Strategic Road alternatives. Nevertheless, if we are going to keep such extra lane operation they should be restricted and enforced to 40mph limits when in operation and preferably be part time only with appropriate signing as was the case with the first such schemes.
3.7.4 Home working and electronic communications generally since Covid have reduced the need to travel by approximately 10% and thus reduced the time wasted in long distance communications. With people returning to public transport, there should be less long-distance travel and hence Strategic Road enlargement will have less relevance.
4. Summary and concluding comments of LGTAG’s submission to the Select Committee.
4.1 We hope our submission will be helpful to the Select Committee and will hopefully, (subject to the Select Committee’s deliberations) encourage the DfT and Government to reappraise the duties and objectives of National Highways. Bearing in mind the National Audit Office overall brief is to ensure value for money in public expenditure we hope our evidence will helpful.
4.2 To conclude, our submission summary is as follows:
LGTAG would be pleased to provide further evidence to the Select Committee on request or verbally at a meeting.
February 2023