Executive Summary

Paragraph five states that "a truly integrated approach should take account of the interactions between transport and other policy areas, including land use planning, local economic development and social inclusion", yet the following paragraph states that "the approach set out in this paper has been designed primarily for the purpose of appraising trunk road investment." This typifies the serious retrenchment from integrated transport policies that this consultation paper proposes. It is our opinion that we can either have decision-making on a full range of potential transport infrastructure provision in integrated fashion, or we can review which roads have a better chance of being built. Unfortunately, this paper presents only a framework for the latter.

Paragraph six notes that developing an appraisal system which can be applied across different modes of transport is "an ambitious proposition which will require further development." While development of a nationally applicable system may take more time, to appraise the trunk roads programme based on the appraisal criteria presented in this paper would represent a grave failure of an integrated approach to transport decision-making. This would represent a serious retrenchment in policy orientation from the Integrated Transport White Papers launched less than three months ago.

Chapter 1 Introduction

section 1.4

The penultimate sentence of paragraph 1.4, "In the longer term, it is the intention of develop the approach so that it can be applied in a cross modal fashion, consistent with an integrated transport strategy" implies that the approach proposed is inconsistent in the short and medium term with an integrated transport strategy.

The failure to adopt cross-modal appraisal techniques, and the failure to produce appraisal techniques consistent with the integrated transport strategy embodied in the UK and Scottish Transport White Papers, is wholly inadequate and wholly unacceptable.

sections 1.6-1.7

We agree that "rational decisions on the use of limited resources", using "good appraisal techniques" and "transparency in the procedures used to prioritise transport projects" are all required in a considered appraisal evaluation of transport projects.

However, we do not agree that the appraisal techniques are good, nor are they particularly transparent given the failings in the methodology used, and are unlikely to produce rational investment decisions.

Chapter 2 "Summary of consultation issues"

First bullet point: "Route Profiles"

This is inadequate and should be replaced. See our comments on Chapter 4, below.

Second bullet point: "sub criteria and indicators"

We agree that the set of criteria presented (economy, integration, safety, environmental impact and accessibility) is a good basis for appraisal methods.

However, the methodology used to assess these criteria is inadequate, as it completely fails to incorporate integration by conducting assessments of road proposals without any comparison to alternatives.

Third bullet point: "summary assessments"

We agree that qualitative assessments of environmental impacts are in many cases appropriate. We prefer the seven-point scale.

Fourth bullet point: "cross modal fashion"

We strongly support the production of a cross-modal corridor approach to transport infrastructure appraisal.

The failure of this document to develop such an approach renders it utterly inappropriate for assessing the Scottish trunk roads programme. Cross modal techniques must be developed for this review of the trunk roads programme.

Chapter 3 "The role of trunk roads in an integrated transport strategy"

paragraph 3.1

We welcome a statement of current modal split presented here, both for passenger and rail use. We think it aptly presents the domination of unsustainable transport modes in such movements.

We would welcome a recognition of the unsustainability of current transport modal split, and that the current modal split, to some considerable extent, is as a result of recent decades' transport infrastructure investment being biased towards unsustainable modes such as car and lorry use.

paragraph 3.2

This section seems to be very keen to boast of trunk road completions, without noting the difficulties of their being brought forward. The most obvious case is the construction of the rural M74 (bullet point 4), thereby increasing the competitive advantage to rail movements, and especially at a time where the sustainable alternative, the West Coast Main Line, was widely recognised as being in dire need of redevelopment.

We would request that this section is tempered by a recognition of the environmental and social impacts caused by construction of projects such as these.

paragraph 3.3

This paragraph states that "Improvements to the trunk road network have been accompanied by very major increases in both the number of vehicles on the roads and their usage." If this is a recognition of the impacts of a 'predict and provide' approach to trunk road construction, then we welcome it. However, clarification would be useful.

While we accept that economic growth and traffic volumes ahve risen at the same time, it would be over simplistic to suggest that traffic volume is only a function of economic growth. We would hope that the Scottish Office would be prepared to accept that the heavy expenditure in trunk road expenditure over recent decades, as trumpeted in paragraph 3.2, in comparison to public transport infrastructure, has also had a significant impact in expanding road traffic volumes.

paragraph 3.4

We find the tone of this section unnecessarily begrudging of the work of the House of Common's Standing Advisory Committee on Trunk Road Assessment (SACTRA). As the Government's key advisors on trunk road assessment, we would have hoped that the Scottish Office would have been less dismissive of their advice presented. SACTRA's work, as acknowledged in the last sentence of the paragraph, has shown that trunk road construction can generate more traffic, while their Interim Report on "Transport Investment, Transport Intensity and Economic Growth", published in February 1998, clearly concluded that linkage between transport provision and local regeneration was not established.

While this paragraph rightly acknowledges that a 'predict and provide' approach to trunk road construction has been criticised as "unaffordable, unsustainable and, ultimately, self-defeating" (as referred to in the Scottish Transport White Paper), the Scottish Office would do well to remember that critics of 'predict and provide' include Deputy Prime Minister John Prescott who, in his speech to the House of Commons when launching the UK Transport White Paper on 20th July this year, said: "Everyone now acknowledges that we cannot build our way out of congestion; the days of predict and provide are over." Unfortunately, we do not see much commitment to UK Government policy in this paragraph.

paragraph 3.5

While this paragraph makes reference to "traffic reduction measures", we are very disappointed not to see reference to the Road Traffic Reduction Act 1997 and the Road Traffic Reduction (National Targets) Act 1998.

The statement in this paragraph that "for many people the car is a vital part of their daily lives" overlooks the fact that 38% of Scotland's households have no regular access to a car (Scottish Transport Statistics 1998: Table 1.14; 1996 figures).

paragraphs 3.7 - 3.8

We agree that a "balanced approach", incorporating the five criteria outlined in paragraph 3.8, is required in order to assess where the trunk road network has a role to play in Scotland's transport needs.

We are not, however, confident that the methodology presented in this consultation paper will give balanced results, based as it is on a dated and discredited appraisal criteria (please see our comments, below, on paragraphs 5.14-5.31).

Chapter 4 "Route Profiles"

paragraph 4.2

The consultation paper does set out a revised means of identifying the need for improvements, 'Route Profiles'. These, however, relate solely to roads and apply a factor based on traffic forecasts assuming no policy change to identify route sections which might experience congestion or other problems by 2005. This is precisely the 'predict and provide' approach which the Government, in the summary of the recent Scottish Transport White Paper, noted was "unaffordable, unsustainable, and ultimately self defeating."

We do not agree that Route Profiles are in any way a "tool to aid strategic decision-making." Route Profiles do not provide a strategic assessment of transport needs: they only provide information on particular road routes. While they may provide information on which roads to direct investment towards in comparison with other road proposals, Road Route Profiles are inadequate in strategic decision-making because they fail to provide an assessment of alternatives.

The revised appraisal system proposed makes no attempt to assess trunk road schemes against alternative options, notably public transport investment. It makes no mention of recent significant legislation, including the Road Traffic Reduction Act and the Environment Act, both of which are likely to have a significant impact on the desirability or otherwise of road schemes as opposed to alternative means of dealing with transport problems. Though it is stated that integration should be built in to the appraisal process at a high level by making option development a multi-modal process, no guidance is given on how to achieve this. Equally, there is no recognition at this top level that integration is also about links to other policy areas, notably land use.

The proposed appraisal system may be appropriate for comparing alternative alignments once a strategic decision has been made that a road scheme is needed. However, it is totally unsuitable for the assessment of whether a road scheme is the right strategic option.

We insist that a cross-modal approach to appraisal of schemes is adopted now in order to carry out this review, as the form of appraisal presented here is inadequate.

Chapter 5 "Appraisal proposals"

paragraph 5.13 "Economic impacts"

By proposing to retain the Network Evaluation from Surveys and Assignments (NESA) model, this review proposes to use a model devised for assessing road schemes. It does not look at alternatives to roads, such as investment in public transport, and does not, therefore, fulfil the Government's objective of integrated transport.

NESA may have use in deciding between alignments of trunk road where, and only where, a strategic assessment of need has been established through cross-modal corridor appraisal techniques. As this paper cedes that cross-modal techniques are necessary, but then makes no attempt to develop them, we must conclude that NESA is a completely inappropriate methodology for use in this review.

paragraphs 5.14 - 5.31 Valuation of Time Savings & Vehicle Operating Costs

Traditional Time Savings and Vehicle Operating Cost Savings methodology assume that a new road will have no effect on journey patterns. This is an incorrect assumption which has been challenged by the work of SACTRA, and particularly by its 1994 report on the traffic generation effects of new road construction. It is not clear how the appraisal techniques presented can reflect the available evidence that time savings through improved roads are often simply consumed through the making of longer trips for similar purposes (and as such acting contrary to environmental goals).

It is also unclear how very small time savings should be valued: for example whether the value of 100 people saving 30 seconds as a result of a road improvement is equivalent to 10 people saving 5 minutes.

The example used in this paragraph 5.17 illustrates the inadequacy of the Time Cost savings methodology proposed (irrespective of our other specific concerns about the appropriateness of such a methodology). While NESA values car users' time while working at £12.90 per hour, the time of a bus (or other Public Service vehicle) passenger while working is only valued at £10.64 per hour. This assessment gives a simplistic bias towards use of car users' time; for example, and using this methodology, we would contend that as the bus user is using a more sustainable transport mode, that the valuation of time cost for the public transport user should be higher than that of the car user using a generally more unsustainable transport mode. Unfortunately, this can better be seen as another indicator of the inadequacy of the appraisal methodology presented in this paper.

The methodology used presents no assessment of time costs incurred by cyclists and pedestrians; where walking represents 28-30% of journeys in Scotland, this is another failing in the methodology.

paragraphs 5.32 and 5.33

We agree with the statement in section 5.32 that "the options developed for appraisal must reflect an integrated approach to transport provision. Option development should therefore be a multi modal process with the aim of identifying the best solution, or combination of solutions, to address a particular transport problem." Unfortunately this consultation paper completely fails to address this issue by focussing appraisal techniques only on road schemes.

This section completely fails to spell out the potential options of, for example, improved / new rail routes and / or bus priority combined with existing or smaller scale new roads as an alternative to the proposed road - as opposed to a proposed new road having some direct / indirect (and perhaps even accidental) benefit for public transport.

Paragraph 5.33 refers to the integration of transport with other policy areas as a "second level" of integration. These policy areas include, health, land use planning, economic development, sustainability and social inclusion. While it is considered that the interactions identified under this heading are reasonable, the proposed appraisal procedure to assess schemes in relation to them is inadequate. It is considered that these interactions can only be satisfactorily assessed in a procedure that includes all modes using a common appraisal framework. They cannot be satisfactorily considered in a roads-only appraisal.

paragraph 5.38

We agree with the second bullet point in paragraph 5.38, "it needs to be demonstrated that developing resources to the transport project would represent a more cost-effective means of developing the local economy than the use of other, existing policy instruments."

Despite the dismissive view that this document takes to the Interim Report of SACTRA (1998) (paragraphs 5.10-5.12), the SACTRA Interim Report clearly states as one of its main findings that new road links can undermine the strength of the local economy, and therefore "that there is no simple, unambiguous link between transport provision and local regeneration" (SACTRA Interim Report main finding 3).

SACTRA also states that "the state of the art in local and regional economic impact studies is under-developed", and that assessments of net economic impacts are often over-stated, and may indeed run counter to regeneration objectives (SACTRA Interim Report main finding 4), as acknowledged in paragraph 5.41.

However for most road schemes previously in the Scottish roads programme, and as, for example, in the case of the proposed M74 Northern Extension, there has been no attempt to demonstrate that it would be a more cost-effective means of developing the local economy than other existing policy instruments, never mind ill-specified attempts.

paragraphs 5.45 to 5.49 "Safety"

In this section, the traditional NESA methodology is again presented. While it may be possible that an individual road scheme can be shown to reduce the accident rate for a particular stretch of road, the methodology fails to address whether the same objectives could be achieved by other means. For example, where accidents are caused by speed, if resources currently devoted to trunk roads were instead diverted to speed reduction technology, the benefits in terms of reduced accidents may well present better value for money than through use of the methodology presented here, decisions to construct new trunk roads.

paragraphs 5.50 to 5.58 "Environmental impact"

We agree that there are considerable difficulties in placing monetary values on environmental impacts, and especially when an attempt is being made to disaggregate impacts to specific proposals. The qualitative appraisal approach, supplemented by costings where easily identifiable and possible to measure represents a fair basis on which to attempt to incorporate environmental impact of transport. It also appears to offer a good basis on which to move towards a less mechanistic transport appraisal method which could be applied across all modes and to other policy options.

We do however believe that the Scottish Office should be devoting more effort to assessment of the broader social and environmental costs of transport, especially with reference to a national aggregated basis; for example, see the work of Maddison et al. (1996: p. 141), who calculate that the marginal external costs of UK road transport costs between £45.9 - £52.9 billion, and where taxation as a percentage of external cost was calculated as only 31-36%,

paragraphs 5.59 to 5.67 "Accessibility"

We support the simple definition of accessibility used as "ensuring that the places we need to get to can be reached", as it important that accessibility is defined in this way, rather than spurious "personal mobility" definitions that are sometimes used.

The Accessibility assessment centres on impact on pedestrians and cyclists, community severance and impact on public transport. The first two of these are dealt with in a similar fashion as they are under the existing appraisal techniques. With regard to public transport the advice states that in the context of an integrated transport strategy a qualitative assessment of the impact of road schemes should be undertaken. For example road options should be assessed to determine whether a scheme would result in the diversion of a bus route or make it more difficult to walk to the railway station. It is considered that this is a very simplistic approach to assessing this issue given the rigorous assessment of public transport accessibility which is now possible using computer based systems.

Paragraph 5.67 refers to the very specific physical impact of the road on access to public transport (the example being given of whether a scheme would result in the diversion of a bus route or make it more difficult to walk to a railway station), but fails to refer to the overall competitive effect on public transport from construction of a new road. Unfortunately, this example typifies the rather limited extent to which the proposed appraisal method attempts to take account of the new transport policy context in which it is supposed to be operating.

This paragraph also fails to specify why a quantitative effect cannot be established, especially given the willingness of the NESA methodology to attempt to establish quantitative effects for motorised travel. We would appreciate clarification on this topic.

paragraphs 5.68 to 5.72 "The Overall Approach"

There is a general failure to state which of the indicators will take most importance using this framework. In order to achieve the transparency that the document claims, and given the variety of quantitative and qualitative criteria and indicators identified, it is necessary to state which will be treated as having most importance in decision-making.

We generally agree that qualitative assessments of environmental impacts is the most appropriate way in which to proceed. We prefer the seven-point scale referred to in 5.70 to the simplified scale in 5.72 as the latter is unnecessarily simplistic in approach.

We welcome the statement in paragraph 5.71 that "It should be emphasised that this process would not yield 'scores' for interactions, sub-criteria and indicators which might then be added together to determine an overall ranking. The intention is simply to assist the decision maker by providing a rough scaling of potentially complex qualitative material". We agree that these values should not, under any circumstances, be used as numerical values. If this were to happen it would present a gross over-simplification of their impacts.

paragraph 5.73 "Longer Term Development of the Network"

The second sentence of paragraph 5.73, "In the longer term, it is the intention to develop the approach so that it can be applied in a cross modal fashion, consistent with an integrated transport strategy", which implies that the approach currently being proposed is inconsistent in the short and medium term with an integrated transport strategy, repeats the unacceptable failings outlined in section 1.4, that is, it fails to propose the use of cross-modal appraisal techniques for this review, and that the appraisal technique being proposed are ceded to be inconsistent with the Government's integrated transport policy.

In response to the request "Views are invited on the amendments to the approach set out above which would be required to fit the approach for this purpose", we request that the Scottish Office develops cross-modal appraisal techniques for this review.

A major omission is the failure to relate the roads review to the Railtrack Network Management Statement - developing a 'route corridor profile' to incorporate issues of rail capacity / congestion, speeds, loading gauge in an integrated fashion which will help to secure the best overall transport solution to that corridor's problems. The wide difference of approach in this and the Railtrack documents reflects a continuing inability to put into practice the principles of integration and sustainable development.

Annex 1

In the Annex 1 example of a route profile (Inverness-Aberdeen) there is no indication as to how the judgment on public transport potential is reached. The assumption seems to be that only commuter traffic is relevant, not leisure or business trips - this seems very questionable.

Also there is no consideration whatsoever of rail as an alternative for freight - while most of the HGV traffic is short-haul (albeit some feeding into railheads in Aberdeen) there is undoubtedly potential for modal shift for longer-haul traffic originating along the Inverness-Aberdeen corridor; e.g. EWS have been increasing the quantity and quality of their services over the last two years.

Annex 5

Annex 5 presents an outline of the Central Scotland Transport Model (CSTM3). The methodology that it presents, incorporating as it does "interaction between major road and public transport schemes" and compliance with the advice of SACTRA, presents an improvement upon the methodology suggested in the rest of this document. The appraisal methodology presented in this paper should not be used in deciding on trunk road investment proposals in the Central Belt of Scotland when better-specified models such as this are in development. Until the Scottish Office is prepared to present cross-modal appraisal methodology, development of this methodology for use in a Central Belt of Scotland context is preferred.

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