Written evidence submitted by MTRU (SRI0054)

Is National Highways suffering from a lack of transport planning?

Introduction

I make this submission as a Chartered Transport Planning Professional (CTPP) with 40 years experience in public and private sectors.  Since 2015 I have been mainly involved in skills development for transport planning but undertake work for legacy clients, including recently on the merits and demerits of a National Highways (NH) scheme in the outer area of Greater Manchester which is also next to the Peak District National Park (the A57). To be clear I was providing technical advice to CPRE at the Examination in Public of the Development Consent Order (DCO).  They objected to the scheme, as did the National Park Authority.  That experience gave me a unique and recent insight into the current workings of NH and the reasons behind some of the public criticisms of their capacity to deliver, including the NAO.

Submission of Evidence

The need to be an intelligent client

While the criticisms of National Highways set out below are well known throughout the transport planning profession I think we could see them through the lens of a chronic lack of the right in-house transport planning skills.  This leads to an inability to procure, brief and supervise external consultants and a lack of clear audit trails.  This is very obvious in three areas:

1. Option development
1. This is often cursory and out of date by the time schemes are brought to the detailed appraisal stage
2. Real engagement is usually missing – the only options considered are capacity based – it is at a very low point on the classic description of public participation: Arnstein’s ladder
3. For historical reasons there is little understanding of traffic generation or the competition between modes and in some instances no recognition of the interaction between car use and road based public transport and cycling
2. Appraisal
1. This is consistently poor against strategic objectives – this relates to a) and is an area where HA and now NH have failed to follow Business Case guidance – the need for continuous checking of Strategic Fit (golden thread). 
2. Elements which are difficult or impossible to monetise are underestimated but with one exception.  The wider economic impacts are often used to boost the benefits of NH schemes while negative impacts are under-represented or missing.  Severance impacts in particular are often ignored.
3. Modelling and forecasting
1. As in a) above non-car modes are poorly represented in modelling and forecasting, often not at all (e.g. North East Strategic Model used by NH).
2. Road freight responses such as traffic generation through logistical change (trading off distance against depot cost) and competition with rail for unitised goods is missing completely.

Some of the reasons for this are the continuing legacy of the 1960s when road schemes were viewed in isolation and the key function of the then national highway authority (at one time also regionally organised) was highway engineering. 

Traffic generation (induction) still not recognised at the strategic level

In dense urban areas there is a broad consensus that road capacity is not generally an effective solution to transport problems, including congestion.  However, the fact that NH deals with the “strategic network” has led to an attitude that the truism that “you can’t build your way out of congestion” does not apply to what they do.  There may be an argument in some isolated rural locations on the highway network that this doesn’t apply but many NH schemes mainly affect traffic heading for or coming from conurbations.  There needs to be an urgent review to identify such schemes and move the funding to developing realistic options and a reappraisal. 

In this context it is worth mentioning the dichotomy between the local authorities who implemented Covid schemes where traffic “evaporation” – i.e the opposite of generation – was accepted in the predicted outcomes.  This was often of a high order – up to 30% in the literature and treated as such by local authorities for the DfT funded schemes.  There is no recognition of this in any NH modelling or forecasting which we have identified so far.  For schemes which have a significant amount of traffic to and from urban areas this is clearly relevant and must be taken into account.  This is a matter of rational inconsistency which is symptomatic of silo based working.  Which is right?  Or are they both half truths?

I referred earlier to my recent experience with NH on the A57 which is actually in the Greater Manchester area.  NH instructed their modelling consultants not to talk to me direct and were available only through them.  This was not only inefficient but led to a lack of true engagement at the technical level.  Given my career I knew and had worked with some of the consultants involved and the preferred outcome of a proper statement of agreed technical issues (Statement of Common Ground) proved impossible.  We were unable to hold a reasonable technical conversation and key points emerged very late in the DCO which of course nowadays is time constrained.  Some of them remain unresolved.  NH also withheld basic technical information until the DCO examination opened, despite my request for it and other data 8 months earlier.  This included the Local Model Validation report which is normally available at a very early stage. I was able to extract finally some of the data which showed, as everyone expected, that the majority of the traffic was Greater Manchester related, and that the model had had to be seriously constrained in terms of assignment and generated traffic in the urban area in order to make it stable.  This had the effect of minimising the impact on the urban area.  To be frank most of this was not understood by the Inspectors who did not have a transport planning background or access to independent advice of this nature.  I reluctantly concluded that the previous more adversarial Highway Public Inquiry system, where NH evidence would have properly scrutinised, would have been preferable. 

On the issue of the DCO, I think it worth saying to the Select Committee that HA/NH do not follow the latest public guidelines, in particular the framework set out by the Gunning report (itself based on legal cases) on public consultation.  This would improve decisions and not necessarily delay matters. 

The best way to speed consent is:

a.              to undertake proper engagement including supply of technical documents

b.              to ensure schemes are subject to assessment against current strategic objectives, particularly carbon (the essence of several current court cases).

I think there is an argument for removing responsibility for this from NH and moving to DfT and regional bodies.  The latter would allow better co-ordination between local and sub-national regional transport authorities and NH.  For this to work, funding must be mode-neutral in the first instance.  This is directly related to the level of service of the strategic road network – it will flow better through local demand management.

Joined up policy and joined up budgets

If the inadequate preparation of options creates a false choice for the public a parallel unreality of choice exists for local authorities.  The current position is that a local authority may be faced with a road scheme proposal by NH which affects its area and if it opposes it the money will be lost.  The apparent arms length arrangement between Government and NH is therefore somewhat misleading.  Hence there is reluctance from local authorities to oppose what are essentially Government schemes in case this affects their ability to attract funding for other transport programmes they might well prefer.  Some negotiation of small add-ons to schemes they think are not appropriate means that local authorities may face an even trickier decision. 

What should happen is that they should have the opportunity to say if the expenditure could be spent on more cost effective transport schemes in that location, especially where traffic is mainly related to their area or region.  This should already be part of the optioneering and appraisal process but often is not.  Again this failure to unify budgets is an example of silo based working leading to less effective and in some cases counter productive outcomes.

NH needs to be reformed into a delivery not a policy and planning agency 

The final issue relates to this need to change function.  NH has little “big picture” functionality but acts as though it does, for example on achieving policies on net zero.  There doesn’t appear to be a way in which some crucial decisions can be reached.  One of these is exactly what the roads of the future will need to look like.  At the moment NH is using some methods which would be familiar to highway engineers in the 1960s.  To be fair, NH has been proactive in some areas of work, for example on reducing carbon from construction and maintenance and in trying to promote traffic management schemes in some instances.  But on the key question of how roads in different locations need to function through the rest of this millennium there are no clear answers.  The result is a programme which is badly in need of review and reform.

Recommendations

1                    There needs to be a skills improvement programme to create a capacity for NH to:

1. Generate a realistically broad range of solutions to transport problems on the strategic network.
2. Undertake public and stakeholder engagement to the minimum standards laid down by the Gunning Principles and aim to do better (there are examples already available).
3. Allow for continuous strategic assessment against local and central Government policies in particular achieving net zero and the Sixth Carbon Budget (both of which requires demand management).
4. Better procure and manage external consultants where required for optioneering, modelling and forecasting.

2                    NH needs to be clearly defined as an implementation organisation not a policy making body.

3                    A review of RIS2 and proposed RIS3 capacity schemes must be undertaken to identify which have a significant amount of traffic which has its O and or D in towns and cities and the funding made available for alternatives in those areas where they are more appropriate.

4                    While large capital schemes for new capacity are about half of the NH budget this would still benefit from a switch to smaller scale improvements (e.g. safety and security, severance, streetscape, landscape) and of course management policies.  This would result from an improved optioneering process.

5                    There must be an end to NH stonewalling on some of these key issues – the situation is worse than it was in the early 1990s and this is the reason for the plethora of court cases.  They may not succeed but are a good indicator of the level of public disquiet. 

February 2023