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DfT consultation on transport appraisal and modelling strategy - submission from Campaign for Better Transport.

October 2018

Campaign for Better Transport is a leading charity and environmental campaign group that promotes sustainable transport policies. Our vision is a country where communities have affordable transport that improves quality of life and protects the environment.

We welcome the opportunity to respond to this consultation on transport appraisal and modelling strategy.

Summary

We welcome the review of transport appraisal and modelling strategy. While acknowledging that the WebTAG tool is widely regarded as a world leader, we nevertheless welcome the potential to improve it further. It is reasonable to judge the value of an appraisal tool not only on its internal logic and theoretical robustness but also on what kind of infrastructure it delivers on the ground. Current appraisal is failing to deliver the integrated local transport that is needed for sustainable growth and a secure low carbon future.

We are concerned that the current over emphasis on the economic case for schemes, underlined by assumptions on demand and value that reinforce traditional assumptions rather than evolving needs, risks undermining schemes for which the strategic case, and the ability to deliver key policy priorities, is strong.

By ensuring that the widest range of impacts and opportunities from transport investment are taken into account, redressing the historic imbalance in valuing road transport over other modes, properly costing the environmental impacts of climate change, and supporting positive trends in the way people live, work and travel, a reformed WebTAG will enable better transport investment and better travel choices in future.

Our approach

We welcome the review of transport appraisal and modelling strategy. While acknowledging that the WebTAG tool is widely regarded as a world leader, we nevertheless welcome the potential to improve it further. It is reasonable to judge the value of an appraisal tool not only on its internal logic and theoretical robustness but also on what kind of infrastructure it delivers on the ground.

A level playing field for sustainable transport

We are concerned that the current over emphasis on the economic case for schemes, underlined by assumptions on demand and value that reinforce traditional assumptions rather than evolving needs, risks undermining schemes for which the strategic case, and the ability to deliver key policy priorities, is strong.

This is particularly seen in assessing new rail links which are generally undervalued, while new roads are overvalued. We are concerned that this inhibits the ability of decision makers to live up to the aspirations set in the Government’s policies to cut transport emissions, locate homes near transport hubs, promote rail freight, and boost walking and cycling. If health objectives were valued in appraisal, we would see much greater weighting for active travel and far less on car-based transport.

Traditional transport appraisal has consistently underestimated the economic benefits of bus services, walking and cycling provision and overstated the value of small scale savings in road travel time, leading to an imbalance in favour of unsustainable road building. Yet the DfT’s own figures show that spending on cycling offers far better benefit-to-cost ratios than road building schemes and the review of the Local Sustainable Transport Fund found that packages of small local schemes focused on sustainable transport delivered excellent BCR of 5:1. This echoes the findings of research published by Campaign for Better

Transport on the effectiveness of the LSTF projects in connecting people to work and boosting the local economy.

The experience of the Local Sustainable Transport Fund (DfT: Impact of the Local Sustainable Transport Fund, summary report 2017) is that by funding good quality local transport, promoting modal shift and actively engaging in travel demand management programmes, it is possible to change travel behaviour so as to cut traffic, tackle congestion, and maximise efficient use of the network. Projects reduced car use and successfully promoted bus use, cycling and walking, and demonstrated excellent value for money. We would like to see much greater value given to such proven scheme types in future appraisal.

Highways England’s report on long-term planning sees greater use of buses and public transport only as part of a ‘diminished prosperity’ scenario. This is both offensive and misguided. Modern buses are an integral part of vibrant, prosperous cities that achieve sustainable growth while managing congestion.

Traditional appraisal also undervalues investment in rail freight over road freight, despite the great potential for rail freight to deliver benefits in terms of reducing congestion, pollution and wear and tear on the road network. Research for CBT previously shared with the DfT found that HGVs only pay around a third of their congestion and external costs. There is a need to calculate and consider all the external cost of HGV use, as demonstrated by the DfT mode shift benefit table, and to review the current passenger car value (pcu) given which is too low for HGVs in many circumstances.

Appraisal models should better reflect the strong benefit-cost ratios for freight enhancements, typically in the range of 4:1 to 8:1, as highlighted in the latest Network Rail Route Strategic Plan. Targeted rail freight upgrades work; for example, the gauge upgrades out of Southampton Port increased rail’s market share from 29 to 36 per cent within a year and had a benefit-cost ratio of five to one. This should be factored into investment planning.

Better understanding of environmental impacts and benefits

POPE studies show that schemes that increase road capacity have increased traffic, adding to environmental degradation of the countryside and increased pollution in the urban areas which already have the most congestion, and bring little or no economic benefit. An appraisal tool that can justify new roads undermining the protected status of National Parks for the sake of a few minutes of motorist time saving is clearly flawed.

Transport is the one sector of the UK economy where CO2 emissions continue to grow. In light of the critical threat of climate change, any appraisal of infrastructure must seek to contribute to reducing greenhouse gas emissions. The current appraisal methods are failing to deliver the integrated local transport that is needed for sustainable growth and a secure low carbon future.

We are concerned that the real costs of climate change are not sufficiently reflected in current appraisal, and believe strategies such as the NPPF and the RIS should be subject to Strategic Environmental Assessment. This approach should also inform the appraisal of individual schemes.

Our report Roads and the Environment (2018), produced with support from the Rees Jeffreys Road Fund, addressed concerns that traditional scheme appraisal values the minimising of adverse environmental impacts but does not sufficiently look at the positive value of green infrastructure. It looked at the potential for mechanisms such as whole life costing, natural capital accounting and resource rental to better capture the value of green infrastructure in scheme appraisal and so enhance the roads environment for the benefit of users and for the wider community.

Reflecting and shaping changes in travel demand and behaviour

We recognise the uncertainty around future trends, reflected in the wide range of traffic growth forecast scenarios recently published by DfT, but also that there is an opportunity to harness the positive trends and focus investment to support them. Planning for future transport infrastructure should not only reflect demand – “predict and provide” – but also seek to deliver the best scenarios for a sustainable future, by shaping demand – “decide and provide”.

A key trend is identified in the work of the Commission on Travel Demand, which shows that travel demand is changing hugely, with fewer shopping and commuting trips, and lower car use by younger people.

Technology is changing not only how people access travel but the use made of travel time. This should change the current dependence on travel time savings as a primary tool in appraisal and allow appraisal to focus on the quality of the journey and its wider costs and benefits for society instead.

Using data to map the impacts of such behaviour change on transport infrastructure demand would lead in turn to much more appropriate and less costly investment. Two case studies commissioned during the RIS2 evidence phase (and shared with the DfT in our RIS2 evidence submission) demonstrate the benefits of this approach:

  1. Research by consultants MTRU, commissioned by Campaign for Better Transport and sponsored by the Department, has explored the potential for using rail freight to reduce road congestion. It found that upgrading strategic rail corridors parallel to the SRN could significantly reduce HGV volumes on the A14, A34 and M6 corridors. Upgrading existing rail lines, which run parallel to the motorway routes and are currently nearing full capacity, would allow large numbers of loads to be transferred to rail. Transferring 2000 lorry loads a day to rail would be the equivalent of taking 8000 cars off the road and would bring serious additional benefits including improved road safety and reduced air pollution and carbon emissions. The DfT welcomed the study, noting that “rail freight offers real benefits for the environment and helps keep bulky loads off of the road network, helping to ease congestion for other motorists.”
     
  2. Researchers at the University of Northampton pooled anonymised postcode data and travel survey responses from public sector employees to identify which routes have the greatest volume of single occupancy car commuting. Their study focused on mapping journeys on the A45 trunk road through Northamptonshire. Having excluded HGVs, LGVs, bus and coaches, the team identified flows of 102,000 cars a day on this road, and have postcode data on origin and destinations of 39 per cent of these journeys of which around 80per cent were single occupancy trips. Car sharing could remove 14,500 of these vehicles, and there are opportunities to use the data to enhance bus provision on key routes. Around 4 per cent of the overall commuting demographic is making journeys under 2 miles: switching 80 per cent of these to bike would remove another 4300 vehicles. A modest investment in these other travel options could remove around 20per cent of the traffic currently on the trunk road, with benefits not only for congestion but also for the environment, with reduced carbon emissions.

We would like to see the benefits in traffic reduction from modal shift of both passenger and freight traffic away from road transport given greater weight in future transport appraisal.

Joining up transport and land use planning

We welcome the work done to better reflect the added value that transport investment brings to places, both in terms of land value capture and of understanding the wider regeneration benefits. Increasingly, transport investments are not standalone projects but are designed to open up sites for news homes and jobs.

Transport appraisal should reflect the priorities of national and local planning policies that seek to locate these homes and jobs close to transport hubs and should support policies that direct development to appropriate locations.

Such an approach would give less value to building new homes close to motorways, or high-speed dual carriageway roads and place greater value on development on sites within walking distance of major public transport links, and adjacent to or within urban centres. This would follow the best practice set out in our publication, the Master-planning Checklist for Sustainable Transport in New Developments.

We would also commend allowing greater flexibility to meet different local area needs, particularly in the many areas seeking to accommodate rapid population growth, and around highly congested corridors between sensitive sites or in dense urban areas. A more open approach to option development and appraisal would keep new road building as a last resort, while allowing constructive engagement with stakeholders to seek more sustainable alternatives. For example, it should not be acceptable to say that because no bus or rail improvements are planned at present, therefore a new road is the only solution.

We would like to see a positive value in appraisal for developments that follow the sustainable transport hierarchy: reduce demand, widen travel choice, maximise efficiency, and make new capacity a last resort.

A methodology that reflects real world needs

We are encouraged by the range of factors that are being taken into account in WebTAG revisions and the modelling for RIS2, including demographic change, the reduction in number of trips, and the impact of spatial planning decisions on travel demand, and by the development of multi-modal regional traffic models.

We commend to DfT the survey research into how practitioners find the transport business case process carried out with our support by Paul Beckford under Prof Peter Jones and Dr Tom Cohen at UCL. (The findings have been presented to the DfT TASM team). This found that while the intellectual robustness of WebTAG was respected, it was not always sufficiently flexible to accommodate the needs and priorities of transport planners, operators and the communities they serve.

Responses showed that increasingly, transport projects are trying to solve multiple policy problems simultaneously such as boosting economic growth, reducing environmental impact, reducing congestion, improving network capacity, reducing journey times and opening up land for development for housing. Consequently, there is a significant need for greater cohesion amongst different policy areas, particularly between transport, planning, land-use and housing.

The Beckford study also found that whilst respondents were broadly satisfied with the five-case approach in theory, there was consistent criticism that in practice, the WebTAG model seems to focus too heavily on economics (especially value for money) and the transport impacts of schemes. A particular frustration of many respondents was the dominance of the time-savings metric within WebTAG, which inevitably favours long-distance schemes over shorter ones. We urge that this should be rebalanced to ensure that all schemes are competing on a level playing field.

By ensuring that the widest range of impacts and opportunities from transport investment are taken into account, redressing the historic imbalance in valuing road transport over other modes, properly costing the environmental impacts of climate change, and supporting positive trends in the way people live, work and travel, a reformed WebTAG will enable better transport investment and better travel choices in future.

This approach frames our response to the specific consultation questions set out below.

Priorities
1) Do you agree that these themes reflect the most pressing priorities for development of our Appraisal and Modelling guidance? If not, what other themes do you think we should be exploring? We agree that these are the priority themes.
2) What considerations should inform the scope and priorities of our strategy, particularly over the first 18-24 months? We would like to see the People and Place theme properly assess the critical impact of CO2 emissions, the health impacts of different travel choices, and also look at valuing natural capital. The work on uncertainty should embrace new and different certainties from falling travel demand, potential for technology to deliver behaviour change and the impacts of the significant changes required to cut CO2. Technology is changing not only how people access travel but the use made of travel time. This should change the current dependence on travel time savings as a primary tool in appraisal. The work on transformational developments should look at reflecting the value delivered by centring development around transport links, and the benefits of agglomeration in existing urban centres.
People and Place: capturing the range of impacts relevant to transport policy today
3) What should be our priorities for improving the appraisal of people and place and why? Please select up to three areas.
  • Costing CO2 impacts and the ability of transport investments to meet CO2 reduction targets
  • Costing air pollution and health impacts and the ability of different transport investments to help meet Government targets in these areas
  • Better valuing the natural environment both in terms of protected landscapes and the potential for green infrastructure
Reflecting uncertainty over the future of travel
4) What should our priorities be for improving our understanding and treatment of uncertainty in modelling and appraisal and why? Please select up to three.
  • Apply forecast scenarios sensibly to deliver a ‘best guess’ approach based on actual travel behaviour
  • Use data to value investments that reflect changes in travel demand towards more sustainable modes
  • Value investments that deliver critical targets on CO2 reduction, where there is great certainty of the need for change
5) What do you see as the main challenges to adopting a more sophisticated approach to uncertainty in Business Cases and what suggestions do you have for overcoming these?
  • We should not be passive in the face of uncertainty but understand that infrastructure decisions not only reflect but shape demand
  • A clear policy framework combined with a ‘best guess’ scenario-based approach will enable sensible choices despite some inevitable uncertainty
  • We also have some hard certainties, especially around CO2 emissions, which should set this framework.
Modelling and appraising transformational investments and housing
6) What should our priorities be for improving the modelling and appraisal of transformational investments and housing and why? Please select up to three.
  • Capturing the added value delivered by centring development around existing transport links
  • Better understanding of the benefits of agglomeration in existing urban centres
  • Valuing quality of development as well as location in terms of the transport choices supported by new housing developments
7) What transformational impacts do you currently find it difficult to represent in a scheme appraisal? What are the barriers to their inclusion and how would you suggest these are overcome whilst maintaining a consistent and robust approach? Campaign for Better Transport is not a user of WebTAG although we observe its impacts.
 
Currently transport appraisal for new developments appears to be driven by quantity of homes and jobs unlocked rather than the quality of place created.
 
Incorporating the sustainable transport hierarchy into appraisal of transformational schemes could assist in capturing the value of quality as well as quantity of development.
Supporting the application of WebTAG and making it more user friendly
8) What are the main barriers and challenges to applying WebTAG? How do you think these could be overcome? We commend to DfT the survey research into how practitioners find the transport business case process carried out with our support by Paul Beckford under Prof Peter Jones and Dr Tom Cohen at UCL. The findings have
been presented to the DfT TASM team). This found that the WebTAG model seems to focus too heavily on economics (especially value for money) and the transport impacts of schemes. A particular frustration of many respondents was the dominance of the time-savings metric within WebTAG, which inevitably favours long-distance schemes over shorter ones. We urge that this should be rebalanced to ensure that all schemes are competing on a level playing field.
9) What more could be done to articulate the flexibilities in WebTAG and support scheme promoters to apply the guidance? WebTAG should reflect and accommodate devolution of both overall strategy and individual scheme development to local authorities who know best what suits their areas.
10) How can we improve the way in which WebTAG is presented? Why? We are particularly interested to hear about how we can improve accessibility and clarity of the guidance. We echo the views of LG TAG that making necessary changes to WebTAG should not result in making it more complex.
Developing modelling and appraisal tools that meet user needs
11) What should our priorities be for improving the development of modelling and appraisal tools and why? Please select up to three. Our primary concern is that whatever method is used has the best real world impacts, in particular in giving appropriate value to low carbon, local and sustainable transport investment.
12) How can we best encourage innovation whilst maintaining a consistent and robust approach? Allowing more flexibility on a devolved basis, perhaps with a pilot scheme or pathfinder approach, could allow different areas to demonstrate innovation within a high level strategic framework.
13) What new and emerging techniques and methods should we potentially explore and what specific problems might they solve? We commend the approach set out in our report Roads and the Environment (2018) produced with support from the Rees Jeffreys Road Fund: this looked at the potential for mechanisms such as whole life costing, natural capital accounting and resource rental to better capture the value of green infrastructure in scheme appraisal and so enhance the roads environment for the benefit of users and for the wider community.




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