PROOF OF EVIDENCE. Gerald Kells Transport Policy and Campaigns Advisor

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1 Highways Inquiry Procedure Rules 1994 Doc Ref: OBJ/ For a local inquiry into: PROOF OF EVIDENCE Gerald Kells Transport Policy and Campaigns Advisor For Friends of the Earth Cymru / Cyfeillion y Ddaear Cymru (Friends of the Earth England, Wales and Northern Ireland) February 2017 The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor) Connecting Road) Scheme 201- The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Amendment) Scheme 201- The London to Fishguard Trunk Road (East of Magor to Castleton) Order 201- The M4 Motorway (West of Magor to East of Castleton) and the A48(M) Motorway (West of Castleton to St Mellons)(Variation of Various Schemes) Scheme 201- The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and The London to Fishguard Trunk Road (east of Magor to Castleton) (Side Roads) Order 201- The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton)) Compulsory Purchase Order 201- The M4 Motorway (Junction 23 (East Of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) (Supplementary) Scheme 201- The Welsh Ministers (The M4 Motorway (Junction 23 (East Of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) and The London to Fishguard Trunk Road (East of Magor to Castleton)) Supplementary Compulsory Purchase Order 201-

2 1. Introduction 1.1 My name is Gerald Kells. I am an Independent Policy and Campaigns Advisor, with a background in transport, planning and environmental issues. I have twenty five years experience in the sustainable transport and policy sector. 1.2 I was the West Midlands Regional Policy Officer for the Campaign to Protect Rural England for thirteen years until 2013, and latterly their Regional Campaigns Coordinator. 1.3 I have been involved in a number of road inquiries in the past, including the Birmingham Northern Relief Road (now M6 Toll) for Friends of the Earth and local residents. I was also closely involved in the debate on the proposed Western Orbital Motorway of the West Midlands conurbation and sat on the steering group of the Study into the subsequent bypass proposals on that route. 1.4 I was a member of the Regional Planning Executive of the West Midlands Regional Assembly as well as Vice-Chair of the West Midlands Regional Transport Partnership. I sat on the steering group of two Multi-Modal Studies, and have given evidence to a number of Parliamentary Committees. I was a member of the steering group developing the Black Country Study as well as technical transport, planning and economic development officer groups involved in the development of the West Midlands Regional Spatial Strategy. 1.4 I am a member of the West Midlands Regional Planning Officers Group, Future Networks West Midlands and the Engage West Midlands and I have lectured on transport and planning at Birmingham University. 1.6 The starting point for my evidence is the submission by Friends of the Earth Cymru to the Inquiry (although I was not personally responsible for that document.) I will consider the need for the M4 Bypass and its impact on traffic and transport more widely. My conclusions will have implications for both noise and air quality, as set out in FoE submission, but those are not areas I am able to deal with in detail. I understand others Page No 1

3 will present the case for the Blue route. While FoE Cymru believes that is something that should be considered I am not in a position to deal with it in detail. 1.7 The evidence which I have prepared and provide for this appeal in this proof of evidence is, to the best of my knowledge, true and I confirm that the opinions expressed are my true opinions. Page No 2

4 2. The Case 2.0 Summary The broad case of Friends of the Earth Cymru is that the need for the road is unproven This can be summarized in six stages. I will address each in turn. 1. The traffic growth assumptions are unproven 2. Alternative options should be further considered 3. The road is likely to generate additional traffic 4. The benefits of the road are overstated and not equal 5. The benefits are outweighed by the disbenefits, including air pollution, noise, CO2 emissions and damage to protected sites and the countryside more generally 6. Partly as a result the economic case is not fit for purpose The conclusion I will draw in my evidence is that the road should not be proceeded with and that alternative more sustainable strategies should be pursued. Page No 3

5 2.1 The traffic growth assumptions are unproven The case for the road relies heavily on the traffic forecasts fed into the model, details of which are provided principally in the M Traffic Forecast Report (Revised in December (RTFR)). While the model does allow for some variation in trips and a low growth option also allows for some suppression of predicted growth we are not convinced this is adequate FoE Cymru s submission includes several graphs which demonstrate that the historic DfT traffic growth assumptions have consistently been wrong, usually too high, and that assumptions that traffic growth and economic growth are inevitably linked need not apply. Figures for Wales specifically have been lower than predicted (See Fig 1) Some of this lowering of growth has coincided with a recession. However, it is not clear that the recession is the only factor and the assumption that traffic will regain the assumed growth rate post-recession is untested. This is further bought into question by the continued rise in rail patronage which has continued in Wales from from 23,882 trips to 28,846 trips, approximately 21%, according to the Office of Rail Responsibility (See Fig 2) At a more local level the assumption of on-going traffic growth depends partly on the network being capable of accommodating that growth. Congestion on surrounding roads, as well as on the motorway itself, will suppress demand There must be a question in particular about how substantially traffic through the Brynglas Tunnel will grow, especially during peak periods. The modeled flows in the dominimum case rise as high as 3,900 vehicles per hour west bound in the p.m. peak in 2037 (RTFR Fig 10.9), towards the limit of capacity, but we are told there is already a deterrent effect to use of the tunnel (For example Matt Jones s Evidence Para 8.35). In other Page No 4

6 words the tunnel is likely to be to some degree self-regulating, not just because it has a physical capacity and there are nearby junction merges, but because local traffic will simply avoid it at busy periods Elsewhere, although the predicted traffic growth, if accepted, would lead to the motorway running closer to capacity, it would still, for the most part, avoid the stop-start conditions one would expect beyond 125% of the Congestion Reference Flow (approximately 90,000 vehicles per day (vpd) for a two lane motorway and 120,000 vpd for a three lane motorway) and the introduction of further traffic management measures could be used to manage the most congested periods It is notable that the Welsh Government s assessment refers to 80% of capacity as the point at which operational problems can be expected (RTFR ). The DRMB advice is that the carriageway standard options presented herein provide a guide to the desirable standard of carriageway provision given the features of the road and expected traffic levels. (DRMB TA79.99 Para 4.4) If the CRF is the standard for designing a new road it is hard to see why action needs to be taken if an existing road is within that capacity, unless there is some other overriding consideration, and practical experience shows that urban motorways do function at levels much higher than the CRF. For example sections of the M6 in the Black Country reached 160,000 vpd even prior to the introduction of the Managed Motorway I am also slightly dubious about relying on the collision statistics with reference to the National Average for motorway collisions (Para of Mr Whittaker s Proof, 1.2.1). It would be surprising if the collision rate was not higher than the average which will be dominated by rural stretches of motorway with fewer junctions where one would expect lower collision rates because there will be less potential for traffic conflict. Page No 5

7 2.2 Alternative Options Should Be Considered Further The FoE Cymru submission to this Inquiry (Paras 21-27) sets out a number of options which would address congestion on the M4 in a more benign way. It argues that combining the known benefits of these would lead to a reduction of 22% in traffic on the M4 (3% from a public transport package, 3% from Metro and Rail Investment, 11% from marketing and 5% from M4 management proposals). While there may be some overlap of the effect of these measures and the marketing element would depend on the extent of the marketing undertaken, there may also be cumulative benefits so we consider these assumptions about the potential for change may be modest In the do-minimum case 48% of traffic is assumed to be using the M4 locally (RTFR ) so there is considerable scope for reducing local traffic to allow the motorway to flow better and pursuing public transport options which would have other benefits for sustainable transport in the area The options for traffic control onto the motorway, particularly the closure of the East facing slips at Jn 26, should be able to be implemented relatively quickly and then monitored. Such a partial closure at Jn 26 would allow the through traffic, for which the motorway is primarily intended, to flow more freely. Other measures, such as traffic light controlled slip roads, have been implemented on motorways which pass through urban areas. It may be that peak time controls at other junctions would augment the effect. However, the only way to be sure would be to have assessed an overall package as part of the process of determining whether the bypass was needed It is also worth noting that while these measures would not eliminate all congestion on the motorway, taken together, they could bring it largely below the CRF. Moreover, by Page No 6

8 reducing local traffic accessing or egressing the motorway, they would allow the motorway to flow better, reduce conflicts (and hence crashes) and increase the working capacity It is also noticeable, as the FoE Cymru Submission to this Inquiry (Para 56) points out, that the data provided by the Welsh Government on congestion suggests it may be lighter in January, February, July, August and December. This would suggest two specific causes, school trips and holiday journeys, both of which could be addressed through a targeted approach of promoting and funding alternatives. Page No 7

9 2.3 The Road is Likely to Generate Traffic The Welsh Government s model seems to assume traffic growth on the motorway network as a whole is largely from reassignment. The Friends of the Earth Cymru submission (Para 16) tabulates the overall additional traffic on the two motorways in the model should the road be built Another way to look at the issue of traffic growth is to consider the additional traffic on roads either side of the core area. According to Fig 9.10 of the RTFR by 2037 the Annual Average Daily Traffic (aadt) on the M4 to the West of the scheme has risen by approximately 9% (EB) and 8% (WB). On the M48 it has risen by approximately 53% (EB) and 23% (WB) though from a low base. Since the dramatic M48 increase is not reflected in comparable increases in the bridge crossing numbers one must assume some of that additional traffic will impact on other non-motorway routes I have to admit to being dubious that traffic on the Severn Bridges would not rise more significantly with the scheme in place (as against the do minimum) especially if the tolls are reduced or removed (as the current consultation suggests they may be). Even removing the toll booths would be likely to increase usage. The most significant increase in the do-something predictions is in the 2051 figure where EB overall traffic on both bridges rises by 4.1% (RTFR Fig 10.14) in the do something scenario, the 2037 figure being 2.2% (RTFR Fig 10.10). However, this output in the model may be influenced by the fixed approach to the removal of the bridge toll, which I address further on. Any actual increase would, of course, represent a disbenefit to people using those sections of road and may well reduce overall time-saving benefits More fundamentally the introduction of a major new road to any network is likely to have significant impacts on modal choice and on the generation of traffic, which is likely to Page No 8

10 increase over time, from trip reassignment, modal shift and from lifestyle changes. As the theoretical diagram (Fig 3) shows, travel choices may be fixed in the short term but can vary dramatically over time Given that the M4 is passing through a congested urban area and that there are significant movements within that area, into and out of it as well as through it, one would expect released capacity to lead to both traffic reassignment and overall traffic growth. While there is some account given to this in the modeling, the extent is limited Part 2 of the Welsh Government s Statement of Case ( ) provides a good synthesis of the assumptions which the promoters are working on that such changes are small and mainly involve changes in the timing of journeys Their view that: New roads increase capacity, however it is not capacity that affects the demand for travel, but the ease of travel provided. is not one I can agree with It is also worth nothing that, despite the reliance on Variable Demand Modeling, the Traffic Report suggests that the VDM model has been used selectively. Table 3.1 of the RTFR sets out the various vehicle types and how it is applied to those. This excludes LGVs, HGVs, commuting and all trips not associated with business. Trips which did not start or end in the core area were also removed (Para RTFR). Furthermore, of the RTFR suggests that the increase resulting from the reduction in the Severn Bridges tolls (assuming that happens) were added in as a fixed component after the VDM modeling was completed Even so the resulting tables ( in the RTFR) suggest marginal impacts on traffic growth between the do minimum and do something scenarios. This is difficult to square with experience, especially since an obvious limitation is being removed at the Brynglas Tunnel and the surrounding network is complicated and congested Some effects might be seen fairly quickly, for example, changes in choices of leisure or retail destination, which would lengthen trips, others, such as choices about where Page No 9

11 people live and work, would be expected to take longer to materialise. Certainly one would expect to see these responses within a 20 year time span as people move houses and jobs, enter or leave the jobs market It also seems to me unlikely that removing or reducing the tolls from the Severn Bridge in conjunction with the opening of a new Motorway link would not influence longer distance journeys and other future life choices, as well as, most obviously, effecting modal choice between road and rail. This would clearly have implications for pollution and climate change targets Some form of Stated Preference testing might elicit useful answers to these questions but the level of growth is probably hard to accurately predict since people do not yet know what choices they will make or even how transport provision will influence them It certainly seems clear that, unlike the remedial measures FoE is suggesting, the proposed scheme would discourage modal shift, by increasing the marginal benefits (and perceived benefits) of car use over public transport use And since the congestion on the M4 will remain mostly in the peaks this would be where one would expect to see traffic rising to fill the gap This conclusion is backed up by previous experience. For example, reductions in aadt traffic levels through Birmingham following the opening of the M6 Toll in 2003 had been eroded five years after opening and overall traffic on the M6 rose by 1.5% between 2006 and 2012 against the trend in the West Midlands (See Figs 4 and 5). Every scheme is, of course, different but the M6 Toll experience suggests it is not easy to actually reduce congestion using a road building solution. Page No 10

12 2.4 The Benefits of the Scheme are Overstated and Unequal The benefits in terms of congestion delays, even based on the Welsh Government s evidence are limited to the peak hours during the week. There is a 3 minute benefit simply from the shortening of the route, although in practical terms that time saving (although it will figure in the economic appraisal) is likely to be less important to drivers than the perceived avoidance of congestion in the peaks. The more dramatic advantages in the 2037 pm peak of just under 9 minutes (Table 10.1 RTFR) relies on the assumption that the dominimum traffic delays on the M4 will not lead to changes in behaviour and are, as we point out, enjoyed by a very small segment of drivers. Indeed, since these are averages, it may be that this level of benefit is only achieved on the busiest days Moreover, those benefits would need to be offset against disbenefits accruing to all drivers from the additional traffic on the motorway on either side of the core area. There may also be additional delays caused on local roads which access the existing M4 if more local traffic uses that road for local trips But, although relatively short predicted time savings may not be significant to individual users or transfer into actual economic benefits, they will make up a great part of the assumed benefits, simply because of the number of people involved And, while there may be a perceived benefit in terms of journey reliability for motorway users, the alternative approach which we set out in Section 2.2 should also achieve greater reliability on the M4, and in particular more constant flow FoE Cymru s response also sets out how the new motorway benefits a limited group of people and is, therefore, inequitable (Paras 60-62). As well as income distribution, one could consider whether this is equitable to younger people, given they are less likely to Page No 11

13 own a car, or to the elderly and vulnerable. However, it is important to stress that the options we would like considered would benefit everyone. Those who need to use the M4 would benefit directly and they would also have greater choice to use other modes, both locally and more widely In terms of wider regeneration benefits, it is worth adding that the road is not being justified to access existing development sites. It will be for the relevant local plans to determine future employment needs but there is no reason to assume these would require motorway standard access. If such sites do come forward, they would, of course, add traffic to the new motorway, as well as the surrounding network This would seem to be contrary to the aim in Planning Policy for Wales to: align jobs and services with housing, wherever possible, so as to reduce the need for travel, especially by car (Para 7.1.3). Page No 12

14 2.5 The benefits are outweighed by the disbenefits, including air pollution, noise, CO2 emissions and damage to protected sites and the countryside more generally And there are significant disbenefits. The FoE Cymru response set these out in some detail in Paras In terms of noise the scheme would introduce a new source of noise in environmentally sensitive areas as set out in the FoE Cymru Submission (Paras ). A reduction in noise on the M4 is heavily dependent on the traffic case, but our approach would also be likely to have noise benefits, and there is no reason why a noise reduction strategy on the existing M4 as part of the cyclical resurfacing and environment management work. It might be that refusal of the scheme would act as a catalyst for such a strategy to be developed The promoters make claims about air pollution but they seem to rely on whether one is convinced that the scheme will deliver the claimed traffic benefits. As the FoE submission sets out, we are not convinced the assumed benefits to air quality close to the M4 justify the proposal, while the disbenefits, for example to wildlife, would clearly be significant The loss of countryside and damage to nature sites, both directly and potentially from run-off and noise, are also significant downsides More broadly, the FoE Cymru response sets out a number of areas where, in our view. the proposal would fail the Wales Future Generations Act goals This includes, in our view, an increase in climate change emissions resulting from increased traffic, which would over time undermine the benefit of individual cars having reduced emissions per mile. Page No 13

15 2.5.7 Under the Environment (Wales) Act 2016 (Part 2 Para 29) Welsh Ministers must ensure that Welsh emissions are at least 80% lower than the 1990 baseline by 2050, and set out proposals and policies to meet 5 year carbon budget periods But even if one accepted the Welsh Government s figures, the carbon reduction would only amount to 0.2% in 2022 and 0.4% in 2037 (Proof of Evidence of Tim Chapman, Table 1) Of course, we are not arguing for a do-minimum situation and the approach we advocate to alternatives should lead to reductions in levels of CO2 in the long term, something which would have been assessed had that package been included in the alternatives In this respect Planning Policy for Wales says that: Tackling climate change is a fundamental part of delivering sustainable development (Para 4.5.1). It goes on to explain that to do this there is a need, among other things, to support behavioural change (Para 4.5.2). The claims by the Promoter on Climate Change seem to me marginal and highly dependent on modelling assumptions, whereas a public transport and demand management based approach is clearly in the spirit of those policies. Page No 14

16 2.6 Partly as a result the economic case is not fit for purpose The economic case for the road is based almost entirely on time savings. As we have said we are not convinced that the level of those benefits, or whether they will transfer into real economic benefits, is proven. Moreover, if traffic growth is exaggerated, time savings will also be exaggerated It is also worth noting that the economic benefits are taken over 60 years (2081), well beyond the 2037 scheme appraisal date. The Uncertainty Log for the RTFR includes a number of elements up to 2037, (albeit these do not address our concerns about induced traffic.) However, they do not consider what might happen after Were traffic to continue to increase, one would expect returning congestion to create additional costs It is not clear to me if the maintenance costs are included in the COBA assessment but they would be a significant element at over 500 million. And given that the assumption is that significant HGVs will convert to the new motorway and that those are by far the most significant vehicular cause of road damage, one would expect significant on-going maintenance work to be required In terms of costs more widely the FoE Cymru report sets out a number of areas where costs may have been under-estimated. It refers specifically to the lack of inclusion of Inflation and VAT. There is an optimism bias of 51m in the assumed costs, although this seems relatively low for such a complex and expensive scheme, especially when past experience has been that schemes can run heavily over budget. Page No 15

17 3. Conclusions 3.1 In conclusion, Friends of the Earth Cymru is not arguing that we should do nothing to improve the M4 through Newport. We simply do not believe the proposed new motorway is justified. 3.2 Instead we argue that a package of measures should be pursued to manage traffic on the M4, along with significant investment in public transport in the area, which would not only reduce congestion but would have many other public benefits and would act as a catalyst for a more sustainable local network in the future We are not convinced that the benefits of the scheme outweigh the disbenefits and we have concerns about the high costs associated with the scheme and the risks they will increase, undermining the Cost Benefit Analysis. 3.4 But this is not just a transport scheme, it has significant impacts on the environment, including the loss of countryside, natural sites and in the longer term increased CO2 emissions. 3.5 For the reasons we have set out we do not believe it should go ahead. Page No 16