Written evidence submitted by the Wiltshire Climate Alliance
Transport Topic Group (SRI0026)

About Us

The Wiltshire Climate Alliance[1] (WCA) was established after Wiltshire Council acknowledged a climate emergency in February 2019. It is an umbrella organisation for different groups and individuals across the County of Wiltshire to come together to campaign for action on Climate Change.

The Transport Topic Group is one of a number of topic groups which have been set up within the WCA: it meets monthly, online, and its priorities include campaigning against road building as the default approach to transport planning and looking instead to public transport improvements and more active travel.

The WCA Transport Topic Group (WCA TTG) wish to submit evidence to the Transport Committee because we recognise that Wiltshire’s transport problems are being compounded by the current emphasis in the county of Wiltshire on RIS2 and RIS3 particularly from the local experience of the Amesbury to Berwick Down scheme on the A303, a RIS2 scheme, and the M4 to Dorset Coast Connectivity study being undertaken by Highways England, a RIS2 study to provide input to RIS3.

We have addressed each of the points in the call for evidence in sections 1 through 8 below.

1. How effectively the RIS2 enhancements portfolio has been managed to date;

1.1 The report of the National Audit Office (NAO) in November 2022[2] highlighted many of the issues around the delivery and management of the Road Investment Strategy 2 (RIS2), which runs from 2020 to 2025.

1.2 Our evidence is focused on a RIS2 scheme in Wiltshire, namely the A303 Stonehenge Amesbury to Berwick Down scheme. It is noted in respect of this scheme [see NAO RIS2, Figure 7] that the ‘Current estimates of cost and start date are given as at September 2022’.  These estimates have however been revised multiple times in the past 5 years, as shown in the following table:

1.3 Not only has the scheme start date slipped a year every year since 2017, but the cost estimate now has a range in excess of £1 billion. How can Government money be allocated to a scheme where cost estimates are so uncertain? Why do estimated costs cover a wider range after 5 years work on the project than they did at the start?  Is it acceptable for schemes to slip approximately a year every year for 5 consecutive years?

1.4 The NAO’s report on the Stonehenge project also highlights a number of difficulties with this scheme.  These include concerns from bodies such as UNESCO, the low cost benefit which relies very heavily on controversial ‘heritage benefits’ as well as a number of other uncertainties.  A summary of these concerns can be found in the NAO report on the scheme [NAO A303, Summary from p.5].

2. Whether risks to the enhancements portfolio for the remainder of the RIS2 period are being well managed;

2.1 In respect of the A303 Amesbury to Berwick Down scheme we note that the risks to this project are summarised in the NAO’s Nov 2022 report [NAO A303]. Having overridden the Planning Inspectorate’s recommendation to refuse permission for the scheme the Secretary of State’s decision to proceed with the scheme anyway was subsequently overturned by a crowdfunded judicial review. The continuing uncertainly over the future of the project is reflected in the wide range given for start date and the variance between upper and lower cost estimates. It is the opinion of the WCA TTG that the scheme should have been abandoned and more sustainable transport alternatives considered. The Government’s premise however seems to be that obstacles to the scheme should be treated as ‘risks’ to be managed and not as a sign that a flawed project is being allowed to proceed. 

3. 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;

3.1 We have no detailed knowledge of the overall programme, so would merely reiterate, as we have outlined in 1 above, that the delays and costs overruns for the  A303 Stonehenge Amesbury to Berwick Down seem to be increasing substantially, and involve more, rather than less, uncertainty, as the project proceeds.  The revised schedule for the start date now covers two years and the revised budget has a range of over £1 billion.  It seems pointless to speculate whether these dates and costs are in fact achievable.

4. What progress is being made on planning for the next Road Investment Strategy;

4.1 The WCA Transport Group have had some involvement with the M4 to Dorset Coast Strategic Study. We have grave concerns about the strictly mono-modal nature of this study: at a time when the imperative seems to be to reduce traffic it seems counter-intuitive that a study should be focusing solely on how to increase road capacity – and traffic.

4.2 Previous studies in the area have been multi-modal – we look back to SWARMMS (London to the South West and South Wales Multi-Modal Study), which reported in 2002, and to BB2SC (Bristol/Bath to South Coast Study) which reported in 2004. Both of these were multi-modal studies.  It seems a retrograde step indeed that we now have a study whose primary focus is on road-based ‘solutions’.

4.3 There is a reference in Version 0.1 of the M4 to Dorset Coast Connectivity RIS2 (2020 – 2025): Strategic Study[6] to multi-modal studies being conducted by others “we are aware that the Western Gateway Sub-National Transport Body are undertaking their own set of multi-modal transport corridor studies throughout 2021 and 2022, including one that will consider movement between the Midlands and the South Coast. We have been, and will continue to work closely with Western Gateway to align the two studies as closely as possible, sharing our evidence and testing potential interventions to make sure that the study outputs are co-ordinated and complementary.” [NH M4DC V01, p.6]

4.4 Rather than replicate and then attempt to align the two studies it would seem better if the M4 to Dorset Coast Connectivity Strategic Study could have been multi-modal from the start, and considered non-road interventions as the top priority.

4.5 It is stated that key stakeholders for the National Highways study included the DfT, Local Authorities and Sub National Transport bodies [NH M4DC V01,p.4]. We would question why environmental and social stakeholders including English Nature/Natural England, the Environment Agency, Wildlife Trusts and NGOs including CPRE and Campaign for Better Transport have not been included from the outset.

4.6 The National Highways website seems reluctant to report progress on the Strategic Studies being undertaken for RIS3.  The Western Gateway Sub-National Transport Body (STB) fill some of the gaps with the National Highways update for their board meeting on December 2022[7] where it is indicated that National Highways (NH) and DfT are awaiting Ministerial clearance for NH to publish the following:

• Connecting the Country: “our long-term strategic plan to 2050” 

• SRN Initial Report: “..headline recommendation to Government for the shape of RIS3”

• Route Strategies: “Between them, the 17 Route Strategies (20 reports) take a route-based detailed look at the whole of the SRN network, one section at a time….The Route Strategies will be published in draft form alongside the SRN Initial Report, and their final publication will follow later in the RIS period”.

4.7 It is hard to judge what progress is being made on planning for RIS3 in view of the lack of definitive information over time frames. National Highways have stated in their brief to the STB that “Once National Highways has published these documents, DfT will launch a RIS3 consultation to inform their development of the RIS. There will also be an opportunity for stakeholders to provide feedback to NH on our draft long-term plan and the draft Route Strategies.”  Assuming a bone fide consultation exercise is to be carried out, rather than a rubber stamping of the NH documents which have been produced, this suggests that there is a considerable amount of uncertainty currently over what comprises RIS3 and that planning with full involvement of all stakeholders is still at an early stage.

4.8 It would seem that initial timeframes for RIS3 planning are already slipping. In their undated V01 report NH reported that “We are aiming to report the recommendations from our work in late summer 2022.” [NH M4DC V01, p5] At the time of writing (January 2023) recommendations have not yet been made public.

5. What lessons from RIS2 need to be incorporated into RIS3 to ensure it is achievable and delivers on policy objectives;

5.1 The WCA TTG are of the opinion that RIS2/RIS3 are vestiges of an outdated approach to solving the nation’s transport issues.  The prime aim seems to be to select and feed road schemes into the production line to ensure there is a continual supply of work for National Highways and their contractors.

5.2 There needs instead to be a holistic approach which prioritises consideration of the decarbonisation agenda, including the benefits which could accrue from shifting long-distance freight onto the railways, and satisfying the growing demand for improved public transport and the need for much improve infrastructure for Active Travel.

5.3 This point has been identified by the Climate Change Committee in their June 2022 report to Parliament[8] where they state that “The Government has acknowledged the need to limit traffic growth, shifting travel to public transport and active travel, but action is now required to ensure this.” [CCC J2022, p. 33]

5.4 In respect of RIS2/RIS3 this same report notes that “While the recent Spending Review saw the total budget for Roads Investment Scheme 2 (RIS2) cut by £3 billion to £24 billion, this still provides considerable funding for new roads which will induce increased demand.   • DfT has listed “Improved environmental outcomes” as one of the objectives of RIS3, but the scoping document does not explicitly acknowledge the role of road enhancements in inducing increased demand or the fact that a majority of cars driving during the RIS3 period will still be carbon-emitting.” [CCC J2022, p.139]

5.5 We return to these points in Section 7 below.

6. Whether the Government’s current and forthcoming roads investment programme is meeting the current and future needs of consumers and business;

6.1 Current and future needs of consumers and business are driven by the cost and availability of alternatives.  Roads investments needs to be considered as a lower priority than alternative options such as investment in railways which would prove a better fit for the Government’s decarbonisation agenda. 

7. Whether the Government’s roads investment programme aligns with other policy priorities, such as decarbonisation, levelling up, productivity and growth;

7.1 These are crucial areas which this Select Committee must consider, in the light particularly of the Climate Change Act 2008 which commits the UK government by law to reducing greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050[9].

7.2 In respect of transport, there is no consistent view on what the ‘net zero’ policy entails across Government departments. On one hand there is the view that ‘net zero’ must require a reduction in road travel, both due to both a decrease in demand and a switch to more sustainable modes.  On the other hand there are Government bodies which are saying that road traffic will continue to grow and that roads need to be expanded to accommodate this growth.

For a reduction in road traffic

7.3 In ‘Decarbonising Transport’ [10] the top strategic priority is given as “Accelerating modal

shift to public and active transport” [TDP, p. 36]. It is stated that “Public transport and active travel will be the natural first choice for our daily activities”, and that “We will use our cars differently and less often”.

7.4 This is the same message which is promoted in Gear Change[11], where we were told that “Cycling and walking will be the natural first choice for many journeys with half of all

journeys in towns and cities being cycled or walked by 2030.” [GC, p.12]

7.5 Likewise the “Sixth Carbon Budget - Surface Transport” report[12] by the Climate Change Committee indicated that the path to net zero would require “that 6% of baseline car demand can be avoided or switched to other modes by 2030, rising to 17% by 2050.” And that “Factors including improved logistics mean that demand reductions for HGVs increase gradually to 10% for rigid HGVs and 11% for articulated HGVs by 2030, remaining at these levels thereafter.” [CCC ST, p. 34]

For a continuing increase in road traffic

7.6 The December 2022 National Road Traffic Projections[13] indicates that “Traffic levels in England and Wales are projected to grow in all our scenarios” [NRTP, section 4.2].

Sending the right messages about transport modes

7.7 There is clearly a lack of joined up thinking between the traffic forecasters and those who wish Government policy to follow the imperative of the ‘Net Zero’ agenda.  ‘Net Zero’ will also imply a need to send the right messages about the relative cost and convenience of motoring compared to other options.

7.8 A step change is needed in the provision of public transport to encourage people to use their cars less.  This can be achieved – as had been demonstrated in London for example – but more action is needed nationwide.   “Bus Back Better”[14] was an encouraging start, but the relative costs of public transport versus car ownership needs to be addressed. Over past years public transport costs have risen faster than motoring costs[15]: this is not sending out the right message to encourage modal shift.  

7.9 It is pleasing to see that this Select Committee will be considering ‘Our Future Transport’[16]  since a review of how Government will construct a transport policy across all modes which takes seriously the need for Net Zero is long overdue: a roads investment programme which works contrary to Net Zero goals should not form part of any future transport planning.

8. How RIS3 should take account of technological developments, and evidence on ways of increasing capacity on the Strategic Road Network (such as smart motorways and potential alternatives to them)

8.1 There is a key question as to whether ‘increasing capacity on the Strategic Road Network’ should be an overall aim, given the evidence (quoted above) that overall traffic levels will need to reduce if we are to meet Net Zero targets.  There are however numerous technological developments which could be considered to reduce the need to travel (for both people and goods) and encourage a shift to more sustainable modes.

8.2 The Transport Select Committee launched an inquiry into road pricing in December 2020, and this reported in February 2022[17].  A Government response to this report has been outstanding since April 2022.

8.3 That report highlighted that £35 billion could be lost by the Treasury through the rise in sales of electric cars and zero emission vehicles (ZEVs) and that road pricing would have both financial and environmental benefits.  It would seem essential that some form of nationwide road pricing is introduced.  Otherwise it would seem that driving will become cheaper, leading to more driving and more congestion, which will increase pollution and affect bus users' journeys

8.4 There are a multitude of options for reducing travel demand, encouraging modal shift and switching to alternative fuels in reports such as the Climate Change Committee’s Surface Transport report. We would urge that these reports and recommendations are read and acted upon. It is disheartening that National Highways are spending millions of pounds on road expansion, and planning to continue this into the future. Alternative approaches, including road user charging, which could help to address the transport needs of the country in a sustainable manner need to be considered and prioritised as a matter of urgency.  

February 2023

REFERENCES