A34 NEWBURY BYPASS
A response to the July 1995 study
by the Highways Agency
Chris Woodford
15th August 1995
Third Battle of Newbury
PO Box 5520, Newbury, RG14 7YW
@nticopyright -- please use, distribute, and copy freely
Note to readers: This document is designed to be read with the Highways Agency Study, though it just about makes sense as a stand-alone document. The paragraph numbers relate to numbers in the HA Study.
SUMMARY:
"We take great care when we decide to build a new road and we avoid sensitive sites whenever we can. I intend to inspect proposals very carefully to ensure that all realistic options are exhausted before we tread on Sites of Special Scientific Interest in future."
Dr Brian Mawhinney, 27th February 1995 [40]
The Newbury bypass is "one of the most environmentally contentious proposals in recent history" [41]. It would affect four actual or proposed SSSIs, two civil war battlefields, the unique setting of a scheduled ancient monument, twelve important archaeological sites, eleven habitats or species listed in the EC Habitats Directive, a National Trust nature reserve, ancient woodlands...
When Dr Mawhinney put the Newbury bypass on hold in December 1994 to explore other options in a year long review, the 10,000 people who had made representations against the road expected him to do just that.
But the review involved no public consultation, presented no new alternatives, and was abruptly terminated five months early. Its conclusions -- the July 1995 study by the Highways Agency -- are deeply flawed:
* Its remit was "to look again at the published route and any other practical alternative options for reducing congestion at Newbury". It has ignored two online alternatives (modifications to the existing route), and fails to take into account a demand-management alternative currently being prepared by Friends of the Earth and the MTRU consultancy.
* It uses data produced in 1983, the flawed COBA9 analysis, and no more than a "guestimate" of induced traffic, apparently flouting government guidance on the subject.
* It fails to consider much new environmental, archaelogical, and traffic data that has come to light since 1988.
* It endorses the case for the Newbury Western bypass, despite:
- DoT figures that show traffic on the existing road rising to current levels again by 2010, with traffic on the new road at similar levels.
- O&D data showing that the problem is caused mainly be an excessive of local traffic.
- An admission that the key problem is peak-hour congestion.
* It fails to consider the broader recommendations of the Royal Commission on Environmental Pollution, the Standing Advisory Committee on Trunk Road Assessment (SACTRA), and recent Planning Policy Guidance (PPG) notes.
* In the words of Keith Buchan of MTRU: "The Highways Agency has simply reviewed the choice of route, not whether a road is needed or not. It dismissed other options in just six lines, and has not even fulfilled its own terms of reference, which included full investigation of alternatives to the bypass. The report is a world away from modern transport policy thinking."
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SECTION 1: INTRODUCTION:
1.1 It's important to remember the background against which Dr Brian Mawhinney made his decision to postpone the Newbury bypass in December 1994. In his first major interview as Secretary of State, he said: "The great car economy is not a phrase I have chosen to use in my first 10 weeks in this job -- nor do I envisage using it in future... Environmental concerns about transport are obviously taking a higher priority in peoples' minds... and we must address these better over the next decade... I want to look with particular care at schemes that have major environmental sensitivities." [1]
Two weeks later, the Royal Commission on Environmental Pollution (hereafter abbreviated RCEP) delivered its report [2]: "Our aim has been to recommend measures which will reduce the environmental effects of all aspects of transport during the next decade and well into the next century... We do not regard this cycle of continual road building facilitating continual growth of road traffic as environmentally sustainable." [3] The order of that sentence is important: road building causes traffic growth, not the other way round.
This finding anticipated the Standing Advisory Committee on Trunk Road Assessment (SACTRA) report "Trunk Roads and the Generation of Traffic": "It will simply not be possible to cater for future unrestrained demand by private vehicle. Demand management measures and public transport policies are likely to form part of an overall transport strategy aimed at containing the demand for travel within the capacity of the road system". [4]
The SACTRA report was finally published on 19th December 1994, the same day as the Newbury bypass was postponed. Many people were tempted to link the announcements, seeing the postponement of a highly controversial road scheme as the nature response to Mawhinney's statements, the Royal Commission, and SACTRA.
In quoting Mahwinney's parliamentary statement of 19/12/94, the Highways Agency study deliberately misleads. They quote: "Once the Agency has reported back to me I will make a further announcement..." What Mawhinney actually said was that he would make a further announcement in about a year's time, in time for the new road starts for 1996.
The review was cut short by five months, despite the fact that the Metropolitan Transport Research Unit (MTRU) consultancy, under contract to Friends of the Earth (FoE), was preparing a demand management alternative to the Newbury bypass. The Highways Agency (HA) was fully aware that this study was going on; Roads Minister John Watts wrote to FoE informing them he was looking forward to seeing the MTRU report.
1.2 Consider the terms of reference (Annex) of the HA study:
1) The team was form the HA -- a department whose very existence depends on the continuation of the roads programme. How can the HA conduct an objective analysis on non-road alternatives, alternatives that seek to reduce the demand for road transport, or alternatives that require fewer HA personnel for their implementation?
2) "Look again at... any other practical options". The report fails in a number of respects:
i. The rail alternative compares today's run-down and under-funded South Coast/Midlands rail links with a highway in which £200 million (Newbury and Chieveley schemes) will be invested.
ii. The study fails to properly evaluate demand management and traffic reduction options.
iii. It fails to give full consideration to online alternatives, which it dismisses in the same terms as "central routes". It fails to evaluate (or even mention) the Steer Davies Gleave online alternative commissioned by FoE in 1994.
iv. It fails to evaluate (or even mention) the Newbury Transport Forum tunnel alternative, endorsed by consulting engineers Scott Wilson Kirkpatrick.
In fact, no alternatives besides the Western bypass, have been put to the people of Newbury by the Department of Transport since the Public Inquiry in 1988.
3) The review uses old traffic data (essentially that produced in 1983 for the 1988 Inquiry), the flawed COBA9 analysis, and no more than a "guestimate" of the implications of the SACTRA report. It provides no detailed cost-benefit analysis of any alternative, with the exception of a long discredited Eastern Route, which would be as vigorously opposed as the Western bypass.
1.4 The HA's reinterpretation of its remit fails to take proper account of the study's terms of reference (annex). They see their objective as affirming the Public Inquiry case, merely reconsidering the existing routes (which no-one asked them to do), rather than offering up and evaluating new options, or indeed asking whether there is any justifiable need for the Newbury bypass at all. In our opinion, the HA should have taken Dr Mawhinney's "Great Transport Debate" as their starting point, not the flawed and dated Public Inquiry case, based on 1983 traffic data.
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SECTION 2: BACKGROUND:
2.2 a) The A34 is a route linking the North and the Midlands with the South Coast, but not the only one. There are alternative routes involving M3-M25-M40 and A36; and rail routes via Birmingham-Bristol-South coast and Birmingham-Oxford-Reading- South coast, or even Birmingham-London-South coast (for the Channel Tunnel). It is important to question how much freight needs to be travelling through Newbury by road.
The A34 proposal has never been just a bypass -- it was always conceived as a quasi-freight motorway, an outer M25. In a 1992 report, the CBI stated: "Although dualled, the A34 is already showing signs of strain and therefore we consider that it should be upgraded to motorway standard." [11]
b) The A34 is indeed a link in a proposed Trans-European Road Network (TERN) route, but:
i) Euro MP Graham Mather's attempt to vote Newbury into Priority 1 status was rejected by the European Parliament.
ii) TERN itself has been much criticized; it may be more a negative thing than a positive for a road scheme to be associated with it. Some of the criticisms against TERN as a whole can also be levelled at the Newbury bypass:
"It will encourage the growth of road traffic, not discourage it, and make it more, not less, difficult to attain environmental targets... If it is true that international traffic is particularly important for trade and economic growth, then providing or reserving capacity for it would be sensible, but in fact the plan as defined at present seems to be based on the assumption that this can be done only by providing enough capacity for all he forecast local, regional, and national traffic using the same roads. And there is little evidence that the construction of new roads will, in itself, promote the harmonious development of economic activities." [12]
"In scrutinizing applications for grants in support of TENs, we recommend that the European Commission give support only to those developments which are consistent with sustainable development and respect for the environment." [13]
c) There has been no strategic environmental assessment of TERNs, no strategic evaluation of the economic impacts, and no public consultation.
2.4 All of the "length through Newbury" is "high standard... dual carriageway" -- only the part of the road South of the town (along the Newtown Straight) is single carriageway. The existing A34 does not pass "through Newbury" in the same sense as the effective high street, Northbrook Street: it is already an Eastern bypass of the town -- a failed one at that -- around which in-fill development has occurred.
The length of single carriageway and the numerous junctions act as restrictions on the capacity of the road With appropriate traffic reduction measures, this would actually be a good thing.
2.5 The estimated annual traffic flows need to be examined alongside projected figures for the same lengths of road for the year 2010 with the Western bypass in place, and with figures for other roads in Newbury [14]:
1993 2010 % change
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A34 Donnington Link 44026 64679 +47
A34 Inner Relief Road 53370 51027 -4
A34 Newtown Straight 24187 6836 -72
A343 Andover Road 9734 11066 +14
A339 Basingstoke Road 17531 25397 +45
Enborne Road 2984 4544 +53
Lambourne Road 3273 5057 +55
Long Lane 18966 20508 +8
B4000 Stockcross Road 5939 13170 +122
Even these figures are likely to be substantial underestimates of the traffic in 2010, and therefore substantial overestimates of any benefits of a bypass, as they take no account of:
a) Induced traffic (the SACTRA effect)
b) The errors in the forecasts. According to the SACTRA report, traffic forecasts for bypasses are "relatively poor" [15] with "over half of the forecasts... in error by more than 20%" [16]
c) The estimated 8000 extra cars resulting from 5,300 new homes intended for the area of central Newbury inside the proposed bypass boundary.
The Newbury bypass has been vigorously supported by the British Roads Federation (BRF), the road lobby group representing car manufacturers, breakdown organizations, and others who profit from traffic growth. The BRF has stated: "Many people in many parts of the country would love to see some additional traffic on their roads..." [17]. The Newbury bypass is designed to allow a massive increase in traffic between the M3 and the M40.
2.6 The growth in freight transport is described as the inevitable consequence of a passive, "laissez faire" transport policy -- one that allows traffic to grow unchecked, then builds roads to allow it to grow even more. The RCEP recommend that we "increase the proportions of personal and freight transport by environmentally less damaging modes and... makes the best use of existing infrastructure". [8] As Transport 2000 state: "Most freight in the UK is sent by road. Over the last 40 years, road freight has increased from 35% of all freight moved to 61%, while rail freight has declined from 42% to 7%. We send more freight by road and less by rail than most European countries and the USA." [19]
The increase in numbers of freight vehicles tells us little about economic growth or transport efficiency. For example, the fashionable (but unsustainable) practice of Just-in-Time (J.I.T.) logistics (planning deliveries to match exactly production and sales needs, and thereby keeping minimum stocks -- a policy likened to using roads as cheap warehouses) requires twice the energy consumption of normal logistics and can produce transport costs some 200% higher [20]. Furthermore, "capacity utilization has been drifting downwards and is now only 58%: empty running has declined slightly, from 33% of mileage in 1980 to 29% in 1993, but this has been offset by an increase in unused capacity on other trips." [21]
The RCEP also draws attention to the greater use of vehicle bans outside the UK: "Switzerland has now decided by a referendum that all lorries using the Alps as a transit route (some 350,000 a year) will have to be carried by rail piggy-back. The switch... must be completed within 10 years. France bans HGVs over 7.5 tonnes and all vehicles carrying dangerous goods at weekends, or public holidays... Germany and Italy also ban HGVs over 7.5 tonnes on Sundays. In many urban areas on the continent, HGVs over 17 tonnes are banned at all times and there is no doubt that logistical arrangements have adapted successfully." [22]
In Newbury, some of the traffic problem is caused by the conflict between local and through traffic. The RCEP "recommended that, where a route designed for long distance traffic is overloaded as a result of heavy local traffic, an assessment be made of the advantages of closing selected entry points, completely or at certain times of day, as an alternative to widening it or constructing relief roads" [23].
2.7a The HA states: "A considerable volume of this traffic is through traffic on the A34" -- but this simplistic statement needs further analysis; it is important to differentiate between cross-town, neighbouring, regional, and national through traffic.
The report states 65% of the traffic at Tot Hill passes through the Donnington Link, but this most certainly does not mean 65% of A34 traffic is "through traffic", as it implies. A simple calculation shows that 65% of the Tot Hill traffic (25,000 vehicles) = 16,250 vehicles. This is less than a third of the traffic on the Inner Relief Road, and less than half that on the Donnington Link.
But even this calculation does not reveal the true balance between "local" and "through" traffic. Figures calculated by MTRU from the Origins and Destination (O&D) data presented at the 1988 Inquiry "show that 80% of the traffic is local or from neighbouring areas, and that just 5% is long-distance through traffic from North to South".
b) Frequent junctions: There is a fundamental contradiction between section 2.7 (where "frequent junctions result in low traffic speeds throughout the day and a high level of congestion at peak times") and section 3.29.8 (where traffic induced by the bypass "would be constrained by the limited capacities of links feeding the existing route"). It seems frequent junctions are a problem only when the HA wants them to be.
c) "High level congestion at peak times, [or] on racedays..." The HA report should have investigated and quantified exactly what those peak time effects and traffic movements are; there seems little point spending £100-£150 million to relieve chronic and specific problems that occur only one or two hours a day, or one or two days a month, particularly if, in providing extra road capacity, we provide room for the problem to expand still further.
Two examples make the point more clearly:
i) The effect of school traffic gives cause for concern. In 1970, 80% of children went to school unaccompanied; by 1990, the figure had fallen to 9%. Parents cite fear of traffic as the main reason for the change [19]. A recent study showed that up to 30% of peak hour congestion in parts of London is caused by school traffic [25].
If the same applies in Newbury, school buses, car poling, and lollipop people represent part of the solution to one component of the town's traffic problems. This kind of cheap, effective, healthy, and safe solution seems to find no place in the HA's road-obsessed thinking, despite their study's objective of considering "any other practical alternative options for reducing congestion at Newbury".
ii) Newbury Racecourse has its own high-standard, purpose-built railway station serving stations to Reading and London Paddington, and Westbury and the West Country. The Racecourse still generates enormous quantities of car traffic -- yet it sees no contradiction between generating traffic jams and campaigning constantly for a Newbury bypass. Attendance figures from recent meetings hint at the scale of the problem:
Date of meeting Attendance
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25 Nov 1994 15066
10 Feb 1995 3259
14 Jul 1995 4944
15 Jul 1995 10000
16 Jul 1995 12681
d) "The traffic... makes the road environment unpleasant." There can be no better confirmation that a Western bypass would make things worse. As the Mott Macdonald figures show (section 2.5), traffic on almost every road in the town would increase significantly due to the extra general traffic a bypass would attract to the area.
e) "... afford little opportunity for management of the traffic." But consider:
i) The O&D data clearly shows that at least 70% of the traffic in central Newbury is "local";
ii) All estimates (e.g. section 6.12) suggest traffic on the existing A34 will be back to current levels by 2010, at the latest.
iii) Most probably, given massive suppressed demand on the A34 and in-fill development, a return to base levels will occur sooner. There will be much scope for induced traffic, particularly local traffic that can respond to an increase in capacity more quickly than traffic from further afield. Consider SACTRA: "When drivers are asked to speculate on how they might adapt to changing levels of congestion, they mention a wide range of responses including changes in the amount of travel. From this, we conclude that traffic suppression and trip suppression may both be consequences of increased congestion on the road network, and that induced or relief traffic may result from road improvements that reduce congestion." [26]
Taken together, these three pieces of evidence suggest Newbury traffic would return to current levels more quickly than 2010. One expert has suggested congestion might recur within two years. This makes a nonsense of the "window of opportunity" argument: that no traffic management measures can be taken until capacity is released by a bypass. There is no argument against taking those steps now -- traffic will be at current levels with or without a bypass; in this sense, the bypass is indeed an irrelevance.
2.9 It is misleading to suggest that there were two Public Inquiries. There was only one Inquiry, in 1988, and a small follow-up in 1992, at which the Inspector refused at the outset to reconsider the choice of route.
Even in 1988, the Public Inquiry was using 1983 traffic data -- the analysis is now 12 years out of date. Worse, the Public Inquiry case and the HA review that reaffirms it, is based on the road-obsessed transport thinking of the 1960s, 1970s, and 1980s. It neglects entirely the RCEP, SACTRA, PPG13, and the widespread shift in public opinion away from unrestricted freedom and towards greater environmental responsibility.
"Public Inquiries provide an opportunity for all sides and shades of the debate..."
i) The National Rivers Authority (NRA) was not present at the Inquiry and was unable to comment on the detailed design of river crossings; it maintains an objection to the scheme [7].
ii) The effect of toxic run-off was not considered [8]. Indeed, the DoT did not even accept that it could be a problem for individual schemes until April 1994. [58]
iii) English Nature and its predecessor, the Nature Conservancy Council, did not present a full assessment of the Western route. Not all parts of the proposed route were assessed and the quality of some of the assessments is questionable [9]. Interestingly, a more detailed case was presented against the minor, objector's Eastern route than against the DoT's preferred Western route.
iv) Much information has come to light since the 1988 Inquiry. For example, English Nature has 24 reports in its possession about the detailed ecology of the Kennet valley. 14-16 of these were written after the Public Inquiry [75].
v) The 1988 Inquiry considered no "non-road" alternatives, and certainly none based on demand management and traffic reduction; the people of Newbury have had no opportunity to consider or comment on these.
But the Public Inquiry process is flawed more generally than this:
* Alarm UK: "In recent years, Public Inquiry inspectors have turned down only 5 road schemes out of 146 -- just 3.5%" [9]
* RCEP: "Public Inquiries have been largely restricted to considering the route of a proposed road and have not probed alternative strategies which would remove the need for it" [10].
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SECTION 3: CHANGES SINCE THE INQUIRY
3.1 GENERAL:
3.1.2 Apart from changes in environmental appraisal, local circumstances, traffic and economic data, this section should also consider:
a) Changes in national and local public opinion
b) Mawhinney's "great debate" on transport issues
c) The Royal Commission report recommendations that apply to Newbury
d) PPG13
e) International commitments on sustainable development and biodiversity.
3.2 CHANGES IN ENVIRONMENTAL APPRAISAL:
3.2.1 As our submission to the European Commission demonstrates [27], the DoT has never done anything like a comprehensive environmental impact assessment (EIA) of the Newbury bypass, as required by directive 85/337/EEC -- and has always maintained that it did not need to do one. On the DoT's own admission, therefore, the Inspector could not possibly have "considered [environmental] issues fully in reaching his conclusions", and perhaps more importantly, neither could ordinary members of the public. As considered in 2.9 above, much new information has come to light since 1988, which is damaging to the Western bypass case. The DoT and supporters of the road seem bizarrely keen that the road should proceed as fast as possible on the basis of out-of-date traffic figures and a most inadequate environmental assessment... presumably so that the project can be committed irrevocably before the flaws in their argument come to light.
3.2.2 The HA admits that the scheme was designed to standards that applied in 1988 (the MEA) that no longer remain acceptable or valid. The NRA was never given opportunity to comment on the design of river crossings and maintains an objection to the proposed design of bridges and embankments [28].
3.3 AIR QUALITY:
3.3.1 a) It is a myth that improvements in technology will reduce car-caused pollution, as Transport 2000 points out: "As catalytic convertors are progressively fitted to cars over the next 15 years, overall levels of some pollutants will fall. But after that, traffic growth means pollution will get worse again. Cats are not effective for short journeys, when the engine is cold. This is a particular problem in urban areas where pollution levels are already high." [29]
In Newbury, traffic will be back to current levels by 2010, at the latest. Moreover, 70% of the journeys on the central section of the A34 are "local". The HA's poor analysis fails to show what distance people are travelling on average, but a significant proportion of these "local" journeys will be of short distance, as 47% of all journeys are under two miles, and 73% are under five miles [29]. With a high level of traffic remaining on the A34 and travelling a relatively short distance, there will continue to be pollution problems unless a massive reduction in traffic is our prime objective.
b) The Western bypass will produce an overall increase in traffic in the Newbury area, as discussed in section 2.5: all the same traffic will still be there, and more too. What effect will this extra traffic have on air quality? Supporters of the bypass argue that pollution will be moved away from the town centre, but the RCEP report suggests the answer may not be quite so straightforward. Climatic effects could confine pollution produced by the bypass in the river valley of the town:
i) "The atmospheric boundary layers, extending typically to a height of about 1km above the Earth's surface, is usually turbulent enough to disperse pollutants rapidly. In anticyclonic weather, which can persist for several days or weeks, a stable layer frequently forms at the top of the boundary layer, reducing vertical movements of air and acting as a lid to confine pollutants near the ground. Anticyclonic weather is associated with light winds, and horizontal movement of pollutants is thus also reduced. In cold weather, when emissions of pollutants are higher, anticyclonic conditions can result in severe urban pollution episodes." [30]
ii) "Strong sunlight promotes the formation of ozone. High ozone concentrations may give rise to 'photochemical smog'. In the UK, ozone concentrations are highest between April and September. In areas where there is heavy traffic, nitric oxide emitted by vehicles removes ozone from the air almost as rapidly as it is formed. In consequence, although the precursors of ozone (nitrogen dioxide and VOCs) come to a large extent from urban areas, the highest ozone concentrations are usually found in rural or suburban areas, in an air mass which has drifted away from an urban area. During anticyclonic weather, it may be several days before an inflow of cleaner air dilutes a polluted air mass." [31]
c) In-fill development seems almost certain to occur at Newbury, considering how the existing A34 bypass has attracted in-fill development, and considering Newbury District Council's stated objective [32] to produce "a comprehensive development between the existing urban edge of Newbury and the bypass". At least 1500 homes will be in this area, on land adjoining, and to the east of the bypass. People living in these homes may suffer air quality and pollution problems associated with the new road.
d) The people most at risk from vehicle pollution seem to be the drivers themselves. According to a team from Birmingham University's Institute of Public & Environmental Health, drivers "are exposed to five times more carbon monoxide, eight times more benzene, and five times more lead pollution than if they were outside their car" [33]. Beyond Newbury (at Tot Hill and on the Donnington Link), traffic will be at least 47% greater on the A34 with the bypass in place, where the two Newbury bypasses will be funnelling into the existing road network. Thus, anyone using the A34 beyond the central area of Newbury will be at greater risk from pollution-related health problems if the bypass is built.
e) It is important not to be unduly alarmist. The risk of pollution-related health problems in Newbury is overstated. RCEP: "Although the increasing prevalence of asthma has coincided with large increases in vehicle emissions, no causal relationship with levels of air pollution has been demonstrated." [34] Most people in the town experience only background levels of pollution most of the town; those background levels would rise in direct relation to the total amount of traffic in the area, so general exposure to vehicle pollution would increase if the bypass were built.
f) It has been suggested that the bypass would reduce pollution by improving traffic movements, but that is an argument for measures that would best reduce congestion, rather than an argument for a new road. As the HA study shows (section 3.29.4 and 6.1.2), congestion would rapidly recur on the existing A34 even with a bypass in place.
g) The air quality argument favours only one solution for Newbury: demand management -- to constrain the traffic within the existing road capacity and thereby prevent any increase in traffic or pollution; and traffic reduction -- to systematically reduce the problem. The National Asthma Campaign states: "The Government should draw up an integrated national transport policy including means designed to protect people's public health. So long as the relationship between air pollution and the primary causation of asthma remains unknown, the benefit of the doubt should be given to people not cars." [35] This sentiment is echoed by air pollution expert and St Thomas's Hospital doctor, Robin Russell-Jones: "Instead of blundering on with its massive road-building programmes, would it not be more sensible to create an integrated transport policy on both environmental and health grounds?" [36]
3.3.2 Given these various considerations, the air pollution argument seems simple. Any bypass will increase road capacity, traffic, and pollution; only demand management and traffic reduction can logically offer any hope of reducing air pollution in Newbury.
3.4 CULTURAL HERITAGE:
3.4.1 There have been no full archaeological digs at Newbury, and there are plans to excavate only one of twelve important sites on the route. The sites include a nationally important mesolithic (mid Stone age) settlement, three Romano-British sites, including a well-preserved villa, two Bronze Age settlements, and five medieval sites -- all of which will be damaged or destroyed. As the HA admits: "in accordance with the then current advice, relatively little work was done to assess the impact of the route upon archaeology" (emphasis added). This is a further, serious deficit in the environmental assessment; European environmental law (the EIA directive 85/337/EEC) requires that: "The environmental impact assessment will identify, describe, and assess in an appropriate manner... the direct and indirect effects of a project on... material assets and the cultural heritage." [37]
3.4.2 At least one of the archaeological sites (the mesolithic settlement in the Lambourn valley) is known to be of national importance, and will be damaged by the road despite the Government's own guidance [76] which requires: "a presumption in favour of physical preservation" of the remains. It seems bizarre that the HA should take into account this nationally important site as a "local change" since the Public Inquiry -- a classification that would also apply to the painting of more white lines in Sainsbury's car park. According to Jocelyn Stevens, Chairman of English Heritage: "The Highways Agency... commissioned a second opinion from an independent consultant, Dr John Samuels, who sought to minimize the importance of the remains located and thus the amount of archaeological work needed to deal with them." [120]
3.5.2 DISRUPTION DUE TO CONSTRUCTION:
The "severe disadvantages of the central route in respect of construction disturbance" do not also apply to an online alternative (the distinction between central and online alternatives is often blurred in the HA study), a rail alternative using the existing network, or a demand management alternative. Only variations of the existing route offer no significant construction disturbance.
The ecological disturbance due to construction has not been properly considered for the Western route. For example, the effects of construction run-off and spoil on ecologically sensitive water courses has not been assessed, and this can be critical: "Concentrations of suspended solids can be increased by spoil from infrastructure works, thus affecting the flow, volume, and composition of the water: an increase in turbidity... may cause abrasion damage and gill blockage in fish and may lead to the total disappearance of filter feeding invertebrates." [38] Asked to "confirm that you have assessed the indirect effects of the Western route... for example, noise, polluted run-off, polluted spray, and construction disturbance" [121], English Nature replied that it "does not have the resources to commission the detailed scientific studies which would be necessary to quantify these effects" [75].
The Kennet river has been particularly noted for the quality of its invertebrates [73], [74], and "the River Kennet is a unique habitat with excellent fisheries and a very high diversity of both aquatic and marginal plants, and aquatic invertebrates. Therefore, there is a need to maintain the existing high ecological value of the catchment." [39]
3.5.2 Other options not considered in the HA study have lower construction impacts than the Western bypass, and this should be fed into the assessment.
3.6 ECOLOGY AND NATURE CONSERVATION:
We have demonstrated already that much information was not presented to the Public Inquiry; that there has been no comprehensive environmental impact assessment (EIA); and that much important information has come to light since 1988.
3.6.1 Both Eastern and Western routes have major environmental drawbacks, and central routes involving significant civil engineering have other problems. But online alternatives and non-road building solutions emerge favourably.
3.6 and 3.7 together suggest that little further re-evaluation of the ecological case is required. But consider the changes in national opinion and policy since 1988:
i) "We take great care when we decide to build a new road and we avoid sensitive sites whenever we can. I intend to inspect proposals very carefully to ensure that all realistic options are exhausted before we tread on Sites of Special Scientific Interest in future." Dr Brian Mawhinney, February 1995 [40], emphasis added. The Newbury bypass has been described as "one of the most environmentally contentious proposals in recent history" and "massively destructive of a largely intimate landscape unable to absorb the impact of a major highway" [41]. It "treads" on three or four SSSIs. Mawhinney gave the go-ahead for the road in July 1995, fully aware that several options had not even been considered, never mind exhausted.
ii) English Nature (1992) will "continue to oppose vigorously road proposals that adversely and irrevocably affect Sites of Special Scientific Interest." [42] But English Nature has offered no condemnation of the Newbury bypass; the strongest statement it has made so far has been "English Nature does not guarantee that there will be no effect on wildlife" [43]; this is hardly vigorous opposition.
iii) The RCEP (1994) recommends a policy objective: "To halt any loss of land to transport infrastructure in areas of conservation, cultural, scenic or amenity value unless the use of the land for that purpose has been shown to be the best practicable environmental option." They go on to recommend:
"a. Strict protection for the special areas of conservation to be designated under the EC Habitats & Species Directive.
b. Any further loss or damage to natural and semi-natural habitats or archaeological features must be reduced to the absolute minimum." [44] There are 11 habitats or species listed in directive 92/43/EEC (Habitats and Species Directive) on the Newbury bypass route [45] and twelve important archaeological features [120].
iv) The RSPB (1994) "believes that the adverse impact of the transport sector on birds and their environment -- on biodiversity in general -- is unacceptably large. Both present and potential impacts must be minimized." [46]
v) PPG13 (1994) states: "forecast levels of traffic growth, especially in urban areas cannot be met in full and... new road building or the upgrading of existing highways will in some cases be environmentally unacceptable." It places "more weight on policies to manage demand". [47]
vi) The English Heritage Battlefields Register states: "If, as Winston Churchill wrote, battles are 'the punctuation marks of history', then battlefields are the fragmentary pages on which those punctuation marks were written in blood." At the launch of the Register, Jocelyn Stevens stated: "It is vital that those sites that remain should be recognized and protected." [49]
Each of these statements was made after the 1988 Public Inquiry, but before Dr Brian Mawhinney's review of the Newbury scheme; the review should have considered them all very carefully and should have taken their considerable weight into account in its evaluation.
3.8 LAND USE:
Changes in local planning proposals must be taken into the evaluation. The Newbury District Council objective to "provide a comprehensive development between the existing urban edge of Newbury and the bypass" [32] confirms that there is a significant change to be considered.
i) PPG13 stresses a reduction in the need to travel and the location of new developments within existing urban centres. New developments should take account of public transport provision.
ii) RCEP: "Some bypasses have attracted very considerable development. Purley Way, part of the A23 trunk road, which bypasses Croydon town centre, has become one of the biggest centres in the country for out-of-town shopping. There are now six retail parks in the industrial areas bordering the road, with a total of over 1 million square feet of retail space and parking provision for over 5000 cars... We conclude from the available evidence that provision of new transport infrastructure, especially new trunk roads and motorways, can affect land uses and hence further demand for travel as well as the environment and should be taken into account in land use planning." [50]
iii) SACTRA: "We recommend that existing procedures for taking account of likely new land-use developments in the vicinity of new or improved roads be reviewed and revised as necessary, so as to ensure that full account is taken in the scheme design and appraisal of the traffic produced by and attracted to such developments." [51]
iv) CPRE: "Developments associated with the strategic roads programme could become major and very prominent additions to the built environment." [52]
3.8.2 We would contend that there are many land use factors to be taken into the evaluation.
3.9 TRAFFIC NOISE & VIBRATION:
3.9.1 As in the case of pollution and air quality (see sections 3.3.1 and 3.3.2), the only logically favoured scheme is the one that reduces traffic the most. Bypasses fail completely in this respect; only demand management and traffic reduction can address the basic problem: there are too many vehicles on our roads.
Three major pieces of evidence against the Western bypass should be taken into the evaluation:
i) The proximity of the Donnington Link end of the scheme to the Mary Hare School for deaf children. This part of the existing A34 will see an AADT increase from 44000 to 65000; extra noise from the intersection and the Chieveley interchange will also be significant at Mary Hare [14].
ii) The effects of noise on bird life, particularly at Snelsmore Common. RSPB states: "Possible indirect effects of the road on nightjars at Snelsmore Common are of great concern to us but we are not able to predict their significance. Recent research in the Netherlands (Reijnen et al, 1995) demonstrated a reduction in the breeding densities of a number of woodland bird species adjacent to main roads. Road noise was identified as probably the most important cause... The topography of Snelsmore Common and the fact that the road will be raised on an embankment as it passes through the Cromwell's Glen/Packer's Copse area suggests to me that road noise will be significantly increased over much of the SSSI." [53]
iii) RCEP: "A motorway in a quiet rural area can be heard up to 10km away." It seems plausible that noise from the road will be heard right across the town, just as the M3 can now be heard in most parts of Winchester at certain times of day; the "amphitheatre effect" of towns based around river valleys is significant in this respect.
3.10 PEDESTRIANS, CYCLISTS, EQUESTRIANS, AND COMMUNITY EFFECTS:
The Western bypass would produce a 47% increase in traffic on the Donnington and Tot Hill links, and roughly a 50% increase in traffic on most roads in Newbury by 2010, with traffic back to current levels on the A34 [14]. Given this, it's difficult to see how pedestrian, cyclist, equestrian, and community effects favour anything other than demand management and traffic reduction.
It seems disingenuous, to say the very least, to suggest that the loss of amenity value of the Western area landscape should be less significant than any other effect considered in this section:
i) Snelsmore Common, the Kennet & Avon canal, Donnington Castle, Bagnor, The Chase nature reserve, Great Pen Wood, the old railway line, and the two battle areas are all major sources of amenity to the local community; all would be damaged or destroyed by the road.
ii) The Kennet & Avon canal is one of the premier canal fisheries in the country. It is used extensively, with an estimated 170,000 angling visits each year. [39]
The loss of amenity value has in no way fed into the balance: "It is an unsatisfactory feature of the present system of cost-benefit analysis (COBA) that use of low cost land of high conservation value gives a scheme a more favourable cost-benefit ratio. COBA does not in any case attempt to cover the value of land for the community, which is not reflected in its market price." [55]
What price an ancient woodland; eleven endangered bat species; an ice-age mollusc; hedges, lanes, and a battlefield untouched since the civil war; a Stone-age site; a bog undisturbed for 5000 years?
3.11 VEHICLE TRAVELLERS:
3.11.2 Anecdotal evidence from a BBC TV South documentary has no place in a supposedly objective analysis on which the decision to spend £150-£200 million (the combined cost of the two Newbury schemes) must rest. Different anecdotal evidence tells us the cameramen making the programme had to drive round and round the town for some time to locate a traffic jam suitable for filming.
a) "It is clear that consideration of [the impact on drivers] will point towards an improved route and to a bypass rather than to an online improvement." This is merely a statement of opinion. An online improvement alone could improve the driver's environment. But an online improvement based on demand management and traffic reduction would reduce noise, vibration, and pollution, and make life better for everyone in the town, not just road users. As discussed in section 3.3, a bypass with increased traffic levels on the A34 would increase pollution-related health problems suffered by drivers.
b) We have seen that with a Western bypass, Newbury would see traffic back to current levels by 2010. Traffic levels on the bypass are forecast to reach 44030 vehicles (20.2% HGVs) by 2010, compared with 51027 vehicles (7.6% HGVs) on the most heavily used A34 section in 1993 [14].
However, SACTRA describe bypass forecasts as "relatively poor" [15] with "over half of the forecasts in error by more than 20%" [16], which would make the bypass figure 52800. This is simply to cover errors in the forecasting method. To this must be added a component of induced traffic. Now the suppressed demand and scope for induced traffic is almost impossible to estimate, but according to SACTRA member Dr Phil Goodwin, a new road creates 10% of extra traffic in the short term and 20% over a longer period [56]. That would make an estimated AADT figure for the bypass, in 2010, of 58000-63000, with a higher proportion of HGVs than travel on the road today.
On this analysis, the Western bypass in no sense favours vehicle travellers. Only demand-management/traffic reduction alternatives can show any realistic prospect of reducing overall traffic and improving the environment for drivers who have no choice but to use the road.
3.12 WATER QUALITY & DRAINAGE:
"This impact has frequently been put aside for post inquiry discussions with the National Rivers Authority." As detailed in our submission to the European Commission [7], these discussions never took place. The NRA never had the opportunity to comment on the design of river crossings and maintains an objection to the Western route. According to Barry Winter, Planning Manager, Thames Region NRA: "After the Highways Agency published their plans we tried to negotiate, but even after quite a number of meetings they have not been prepared to change their design. We have reached deadlock." [120]
a) "A similar level of protection measures would be applied whichever route was selected." But a demand management alternative requires no new construction, no new river crossings, and reduces traffic levels -- and therefore the effects of run-off and spillage -- on the existing route.
b) "The level of protection and the reduced incident potential afforded by a modern road construction would improve upon current drainage arrangement." That may be true, but it does not mean the Western bypass would have less impact on water quality than the existing road. In DoT calculations of environmental assessment, the impact from accidental spillages and run-off is directly proportional to the vehicle flow rate and the percentage of HGVs [57]; given the considerably higher rates of vehicle flow and percentage of HGVs, and given that there are seven bridges, the Western bypass would have a significantly worse impact on water quality than the current road, particularly if construction effects are taken into account.
3.12.3 These elementary measures for run-off are not sufficient in themselves, without a comprehensive management plan. In 1994, the DoT was successfully sued by Mohamed Al Fayed for failing to protect water-courses entering his land from the damaging effects of toxic run-off. The settlement involved extensive and expensive measures for dealing with run-off, including regular monitoring and maintenance, and rapid action after heavy rainfall. [58]
3.12.4 Once more, the balance strongly favours traffic solutions that involve no construction and no increase in traffic near ecologically-sensitive watercourses; only online solutions and demand management satisfy these criteria.
3.14 CHANGES IN POLICIES & PLANS:
3.14.2 a) Given the probable knock-on effect of a 47% increase in A34 traffic, Oxford and Winchester City Councils should have been consulted.
b) There is nothing to suggest Hampshire County Council favours one traffic solution over another: "Whether it [the bypass] be on the previously proposed route or another one, the County Council members do not have particularly strong views." [59]
3.14.3 It would seem two more councils should be consulted, and the others consulted again as to other options for solving the traffic problem that do not involve road building.
3.15 Other environmental impacts not considered: the newly-calculated flood risk (possibly 19 inches) [60]; the impact of inadequate bridge spans on river life [7], [73], [74]; and the impacts of the road on surface- and ground water [7].
3.16 CHANGES IN LOCAL CIRCUMSTANCES:
Why consider only local circumstances? Given Newbury's position -- at the very pivot-point of what Dr Brian Mawhinney called "The Great Transport Debate" -- the review should also consider changes in national circumstances and international commitments since the 1988 Public Inquiry. The national changes (like RCEP, SACTRA, PPG13, and so on) are considered elsewhere in this document; the international commitments are worth considering here.
At Rio in 1992, the UK government signed the Framework Convention on Climate Change "with the aim of returning [emissions of greenhouse gases] individually or jointly to their 1990 levels by the end of the decade." According to RCEP: "while total carbon dioxide emissions from UK sources had fallen by 10% in the previous 20 years, those from the transport sector had increased; that the projected increase in transport emissions between 1970 and 2020 was equivalent to the whole of the projected net increase in total UK emissions over that period; and that two-thirds of this increase was accounted for by private cars." [61] RCEP recommends an objective: "to reduce emissions of CO2 from surface transport in 2020 to no more than 80% of the 1990 level."
The A34 bypass will produce roughly a 50% increase in traffic in the Newbury area -- traffic at the Donnington Link will increase from 44026 to 64679 vehicles per day [14]. Given that the average family car emits four times its own weight in CO2 every year [122], it takes no mathematician to see that the Newbury project is directly contrary to our Rio commitments.
The bypass also reneges on our Rio commitments on biodiversity: "The maintenance of diversity depends on the continued availability of habitats and of genetic diversity within species." [62] The Newbury bypass threatens three designated SSSIs and one proposed SSSI, and 11 habitats/species listed in the EC Habitats Directive, which is described as "the Community's contribution to the maintenance of biodiversity as laid down by the [Rio Biodiversity] convention." [63]
3.18 DEVELOPMENT IN AND AROUND NEWBURY SINCE 1988:
It should come as no surprise that recent developments to the west of Newbury constrain the line of a Western Bypass, but this is a self-defeating argument that in no way confirms the case for the road, or the choice of one route over another.
The locally unpopular decision to resite Sainsbury's near the A34 has -- by common agreement -- exacerbated the traffic problem. the decision to proceed with that development must have been made in the full knowledge that it affected, and would be affected by, the route of any proposed bypass.
The Sainsbury's planning decision seems to cast doubt on the ability of local planning authorities to consider the interaction between land use and transport planning, and certainly casts doubt on whether local authorities could successfully oppose inappropriate development near a Western bypass, as they claim.
3.19 RECENT/CURRENT DEVELOPMENT APPLICATIONS:
This section suggests planning authorities have powers to resist in-fill development that is not "plan-led" -- but that has never really been at issue. The planning authorities seem to have tacitly approved the 100 or so development proposals currently registered [32]. Some of the proposals -- for example, the Suttons Estates gravel pit at Speen Moor, and the Tot Hill service station -- relate directly to the building of the road. The point is that if these developments are remotely likely to go ahead, the traffic implications must be clearly assessed.
RCEP cites in-fill development following completion of the M40: "The construction of the motorway divided previously open country and created a new boundary for the development of neighbouring settlements. It also altered patterns of access to the settlements and made the motorway junctions into attractive locations for activities which depend on easy vehicle access. As a result, development which was not in accordance with the approved development plan took place on previously undeveloped land. Its nature and intensity (superstore, multi-screen cinema, home furnishings store, and headquarters office block all with associated parking) are radically different from previous development in the area (housing, a hotel, and open space). Traffic generated by the development has added to highway problems and brought forward the need for further improvements to the road network." [64] "Such development generates traffic and undermines the strategic purpose of the road; the traffic generated will cause greater congestion than had been expected, and thereby reduce the achieved time savings to less than had been assumed when calculating whether road construction was justified." [65] See also section 3.8.
3.19.2 "This is an issue for the planning authorities..."
But consider: "The growth in traffic demand created by a new motorway appears to be driven more by land-use effects than by transport effects. The introduction of links allowing high speeds encourages individuals to avail of a wider range of job and social activities. This can be achieved with little or no extra expenditure of travel time." [66]
3.19.3 "There is no evidence to suggest that the planning authorities have weakened in their resolve to oppose in-fill."
But consider: "Local authorities often experience difficulty in preventing undesirable developments by neighbouring or higher-level authorities. Mechanisms are required to resolve potential conflicts over road-building, for example, and out-of-town or other car-based developments. Local policies to restrict such developments will carry little weight unless they are upheld at the county and national level." [67]
"We can find no reason to take this issue further." This is directly contradicted by SACTRA: "We recommend that existing procedures for taking account of likely land-use developments in the vicinity of new or improved roads be reviewed and revised as necessary, so as to ensure that full account is taken in the scheme design and appraisal process of the traffic produced by and attracted to such developments." [67] (emphasis added)
3.20 CHANGES IN THE LOCAL PLANNING BACKGROUND:
This has been considered in 3.14 already.
3.20.2 We note in passing that "a recent study concluded that road building is not the key to economic growth in the regions" [68]. Also, "new roads can suck economic activity out of a region as easily as they can stimulate it. For example, a new road can open up an economically weak region to be exploited by an economically strong region. New roads tend to take economic activity out of urban areas and relocate it in green field sites. Often labour is shed in the process." [69]
3.12.3 DELAY TO M4/A34 IMPROVEMENT AT CHIEVELEY:
"...has no direct bearing upon the choice of route..." The delay, and the connection between the schemes, seems easier to understand. The DoT says: "It is the Department's intention to link the Newbury bypass proposals with those for the A34/M4 Junction Improvement Scheme (the Chieveley Interchange)." [70] Physically, the two schemes link directly one into another.
3.22 PROTECTED SPECIES:
Protected species were discovered on the route during preliminary works in 1994. We contend that "the requirements of relevant legislation" were not met in handling bats and badgers, and that relocation measures breach EC directives [7]."There is no information on the likelihood of these or other protected species being found on other routes, so it is not possible to reach a conclusion on any effect on the new balance between the routes." This might reasonably be paraphrased as: "Protected species may be found on other routes too so their presence is not important on any route." By any standard, this is outrageous.
We now know that 11 species or habitats listed in directive 92/43/EEC are to be found on the bypass route [45], indicating that it is an area of international ecological importance. Some of these may be candidates for protection as "special areas of conservation", though English Nature has not yet confirmed this. The RCEP recommends "strict protection for the special areas of conservation to be designated under the EC Habitats & Species Directive" [44].
The discovery of more protected species than were accounted for at the Public Inquiry is a major disbenefit for the Western route, and strongly favours no construction at all in rural Newbury; it does favour an online or demand management alternative.
As there has been no EIA, it is impossible to know what other protected species might be found on the route.
3.23 POTENTIAL CHANGES IN THE STATUS OF SITES:
a) English Nature's "Position Statement" on the Newbury bypass states: "The Rivers Kennet and Lambourn are being proposed for notification in the full knowledge that the Newbury bypass is likely to be constructed across the SSSI." [71] It is not clear what this means. English nature has helpfully attempted to clarify this statement by stating that "it does not guarantee that there will be no effect on wildlife" [43].
RSPB has fewer qualms about expressing the effects on the riverine SSSIs: "The bypass will result in direct loss of floodplain habitat and will sever the ecological corridor provided by the river system. Such damage to a habitat of SSSI quality appears to be inconsistent with the Government's commitment that 'wherever possible, new routes must be kept away from protected areas such as AONBs and SSSIs' (PPG13)" [72] Reports for the NRA on the impact of the river crossings have concluded: "Effects of embankment construction on wildlife are likely to occur" [73] and "The flight patterns of the species using the [river] corridor will be heavily affected by the construction of the crossing. Habitat will be fragmented and the river corridor interrupted." [74]
b) English Nature's Thames & Chilterns Team Position Statement seems a direct contradiction of the organization's national position: "to oppose vigorously road proposals that adversely and irrevocably affect Sites of Special Scientific Interest." [42]
c) The Position Statement fails to mention:
i. The proposal to make part of the Kennet Flood Plain an SSSI in future; the flood plain would be affected by the increased flood risk due to the road [7].
ii. Apart from the dormouse, the ten other species protected by directive 92/43/EEC on the route.
iii. The protected birds on route listed in directive 79/409/EEC (Wild Birds), for example, nightjar and common tern.
iv. That the route has had no EIA.
v. That the NRA maintains a formal objection both to the route and to the design of the river crossings.
3.23.5 This evidence directly contradicts the HA's suggestion that "the river(s) would be little affected", and strongly favours alternatives that do not introduce new river crossings through SSSIs.
3.24 FURTHER ARCHAEOLOGICAL DATA AVAILABLE:
This is discussed in section 3.4
3.25 THE 1643 BATTLEFIELD:
This has already been considered in section 3.6. Some consideration of the second battle of Newbury site (1644) should also be fed into the evaluation.
a) "...seen as an assistance with site management and development control." PPG15 states: "The physical survivals of our past are to be valued and protected for their own sake... they are an irreplaceable record... the effect of any development on the limited number of registered sites will form a material consideration to be taken into account in determining planning applications." [76]
c) "The Western bypass, like the disused railway line which preceded it, is on the fringes of the battlefield."
i. This seems to imply that no damage would be done to the battlefield by the road that has not already been done by the railway. This is quite false. The road involves the construction of much wider embankments, cuttings, interchanges, access roads, and compounds that are not presently there. Railways are narrower and used intermittently.
It has already been considered that the A34 may be widened up to six lanes in time [11]. RSPB state: "A three lane motorway averages 46.5 metres in width and a three lane trunk road 30.5 metres. This compares with only 9.14 metres required by a double track railway." The land lost to interchanges would also be highly significant at Newbury.
ii. "The Western bypass... is on the fringes of the battlefield." English Heritage has written to the DoT advising that the proposed road would cross the delineated site of the first battle of Newbury." [78]
3.26 CHANGES IN TRAFFIC & ECONOMIC DATA:
The Newbury bypass traffic case is still based on 1983 data used at the 1988 inquiry; the figures are now 12 years out of date and take no account of the M25, the M40, and M3 improvements.
3.27 TRAFFIC FORECASTS:
The HA review seems to attach great importance to the fact that the figures are part of the National Road Traffic Forecasts (NRTF). However, considerable doubt has been cast both on the methodology and the outputs of the 1989 NRTF, and similar doubt must be cast on the Newbury figures too.
a) Transport 2000: "The government predicts that road traffic will double by 2025. It has been calculated that the extra cars, if stationary, would fill a 257 lane London to Edinburgh motorway." [19]
b) RCEP: "DoT officials were not able to express any view about the proportion of forecast demand which might be restrained or transferred to public transport, nor to explain convincingly what the effects would be if capacity is not provided to meet the forecast demand." [79] And: "Even with the additions to capacity which form part of the trunk road programme, it was calculated that congestion at the national road traffic census points will have worsened significantly by 2000. There would be a further major deterioration by 2010; by 2025 there would be chronic congestion at all but one of the 29 points." [80] and "If the past trend of road traffic growth continues, the present programme of road building and road widening would not prevent a serious worsening of congestion on the trunk road network as a whole after 2000." [81]
c) SACTRA: "We have serious concerns about a number of important aspects of current traffic forecasting practice." [82] It describes the National Forecast Adjustment Figures with phrases like "conceptually doubtful", "conceptual inconsistency", "intrinsically wrong", and "meaning is obscure" [83]. The forecasts are also criticized for using fixed, rather than variable, trip matrixes: "The effects are not taken through into the appraisal procedures in anything other than a cursory and ad-hoc way... we see this as fundamentally wrong." [84]
d) Friends of the Earth: "One of the most effective ways of avoiding traffic growth is simply not to provide for it." [85]
e) Adams (1981): "Policy is to build the road... capacity necessary to cope with the forecasts. An absolutely critical assumption made by the forecasters is that this capacity will be built. Sometimes this assumption enters directly and explicitly into the forecasting calculations. The greater the number of miles of motorway the forecaster assumes will be built, the greater the volume of traffic he will forecast, and the greater the number of miles of motorway will be built." [86]
3.27.2 Suggestions that any increase in capacity are automatically desirable are contradicted by SACTRA: "It will simply not be possible to cater for unrestrained demand for travel by private vehicle. Demand management measures and public transport policies are likely to form part of an overall transport strategy aimed at containing the demand for travel within the capacity of the road system." [5]
3.27.3 a) This states flows on the current A34 could reach 65000 to 78000 vehicles without the bypass... but section 6.7.2 states: "The junctions in the town centre are generally operating close to capacity", suggesting flows cannot increase much higher than they are today. (See also section 3.29.8)
b) The flows for the relieved A34 from Mott Macdonald give an Inner Relief Road figure of 51027, much higher than the figures stated here.
c) The figures are also at odds with 6.1.2: "Flows on the existing A34, near the centre of town, could be around base levels by 2010."
In summary, the report is inconsistent, and biased in favour of a bypass. It underestimates the traffic figures. It states traffic on the A34 would rise to enormous levels without a bypass, ignoring the constraining effects of junctions; if a bypass is built, the junctions suddenly become an important constraint, preventing induced traffic on the existing A34 and bypass from undermining the "relief" provided by the bypass.
d) "The flows without the bypass would also apply to the Central Route" -- but they would not apply to demand management/traffic reduction alternatives that seek to constrain capacity.
3.27.4 The Eastern bypass reductions on the A34 are a full 10% higher than those for the Western Route -- but no-one is actively campaigning to reinstate the Eastern Route.
There is no consideration in this section of the percentage relief that any other option could give. Accepted that at least 70% of the traffic on the central part of the A34 has a local origin or destination, there is tremendous scope for relief by local traffic reduction. This important alternative option is not evaluated or quantified at all.
3.38 CHANNEL TUNNEL:
In 1988, the M40 had not been extended, the M3 had not been widened through Twyford Down, and the Channel Tunnel had not opened. Each of these is likely to have significant effects on cross-country traffic. There should be full evaluation of each of these changes.
3.29 SACTRA:
3.29.1 This is a considerable understatement of the DoT's response to SACTRA, which stated: "The Department accepts that, in urban areas, induced traffic will often be an appreciable consequence of major road schemes." [88]
3.29.2 SACTRA themselves: "consider that induced traffic is of greatest importance in the following circumstances:
1) Where the network is operating or is expected to operate close to capacity.
2) Where the elasticity of demand with respect to travel costs is high [where travel behaviour has a high potential for change]
3) Where the implementation of a scheme causes large changes in travel costs." [89]
In the case of Newbury, there is no argument about (1), and (3) is presumably the justification behind the scheme. As for (2), it seems reasonable that changes in travel costs might produce higher changes in demand for use of the bypass.
The SACTRA issues should have been given much more detailed consideration that the rather empty section 3.29. As Roads Minister John Watts has stated: "All the schemes within the roads programme will be the subject of assessment under the new modelling techniques, which we have adapted in the light of the advice from SACTRA. The relevance of the SACTRA analysis will be considered in each case." [90]
But compare John Watts' statement with a Highways Agency spokesman's comment on the Newbury SACTRA analysis: "It's a bit of a guestimate at this stage. We cannot say how much traffic will or will not be attracted until the scheme is in place." [87]
b) Keith Buchan, a member of the NRTF panel and MTRU consultancy, shows the importance of a detailed consideration of the SACTRA findings: "It is difficult to think of a recent road scheme which does not have a major part of its COBA value derived from congestion relief. This justification will now be removed to a very large extent... all schemes of any significance will need to be reconsidered, and most of them are likely to lose a substantial amount of their COBA benefits." [91]
c) The National Audit Office (NAO) has already criticized schemes justified by inaccurate figures: "wide variations of this kind must raise questions about the economy, efficiency, and effectiveness with which resources were used in the construction of the schemes concerned." [92]
Induced traffic would cast further doubt on the wisdom of investing in marginally cost-effective schemes like Newbury.
d) The SACTRA report shows that there is "a tendency to underestimate traffic, especially on new motorway and bypass schemes." [93] From an analysis of many before/after studies of motorways, bypasses, and other road improvements, SACTRA concludes: "The notable feature of detailed studies of traffic counts before and after a road improvement that increases in traffic counted on improved roads have, in general, not been offset by equivalent reductions in traffic on the unimproved alternative routes." [95]
3.29.3 "...a major constraint at peak periods". Suggests that there is a peak hour problem only, consistent with the finding that most A34 traffic has a local origin or destination. Providing extra capacity would simply allow the local traffic to increase, without solving the problem. This is consistent with 3.29.4, which states: "For local traffic, the wider network is congested, and would remain so on completion of the bypass".
3.29.4 "...with the local highway authority, it would be possible to introduce traffic management measures". But:
a) There has been no indication that any funding will be available for this after the £100-£150 million Newbury scheme is completed -- a significant omission.
b) The existing A34 will not be detrunked. It will remain in the control of the Highways Agency, and their willingness to introduce the kind of traffic reduction measures mentioned seems questionable, given that the existing A34 (or the A339 as it will become) will continue to be a major trunk road and through-route for Basingstoke traffic.
c) "...any relieved capacity benefited non-car users." This sounds excellent in principle, but if this is really a major objective, demand management and traffic reduction should be considered before the bypass is built, and before it can bring more traffic to most roads in Newbury (see section 2.5).
3.29.5 a) This contradicts section 2.2: "The A34 is the main route linking the North and the Midlands with Hampshire and the ports and resorts of its South Coast". Which is it to be? If 3.29.5 is correct, the A34 is a less significant road; if 2.2 is correct, there would be much greater scope for induced traffic than this section cares to admit.
b) SACTRA: "The Department does not, as a matter of course, assess whole routes before dividing them into schemes. In our opinion, environmental, land-use, development, traffic, and economic appraisals all need to be made at the strategic level in order that the best overall route can be selected." [96]
3.29.6 This describes "the potential rail alternative" as "slower and infrequent". But as Keith Buchan of MTRU consultancy points out: "The HA is comparing the present under-funded rail service with a future high-spend road scheme." [87] Rail is considered further in section 6.5.
3.29.7 The "simple elasticity test" is what the HA spokesman was referring to when he said "a guestimate" of induced traffic. This is a critical point. As SACTRA themselves state: "The value of a scheme can be overestimated by the omission of even a small amount of induced traffic. We consider that this matter is of profound importance to the value for money assessment of the road programme." [97]
It is therefore critically important to attempt to estimate induced traffic with rather more than "a guestimate". Questonnaires directed at local drivers, asking about trip and demand suppression, and similar studies of major freight companies might give some idea of the potential for induced traffic.
3.29.9 a) The figures of both 10% and 20% are "guestimates", and it is far from clear that the COBA analysis stands up to scrutiny (this has yet to be tested). 20% is described as a severe test, but it is not clear that this is severe enough. For example, SACTRA considers "nearly two-thirds of the traffic on Westway (M40) might be counted as induced"; "The M11... showed a growth of 130% in the period of approximately six years after opening... a significant proportion of this extra traffic is induced" [123]
b) "The scheme would still represent good value for money". In the eyes of the public who foot the £100-£150 million bill, the Newbury bypass provides good value for money only if it solves the traffic problem. If that traffic problem is local congestion predominantly at peak hours, the provision of massively increased capacity for through traffic does not sound like an appropriate solution. We have already considered the National Audit Office commentary about forecasting errors: "wide variations of this kind must raise questions about the economy, efficiency, and effectiveness with which resources were used in the construction of the schemes concerned." [92]
Ultimately, given the significance of the SACTRA induced traffic effect, the value for money estimate -- and the decision to commit £100-£150 million on the bypass -- rests on a "guestimate".
3.29.10 a) "If no bypass is provided for Newbury, there will be no induced traffic, but the town will continue to suffer from existing congestion." This is a direct contradiction of 3.29.4: "For local traffic, the wider network is congested and would remain so on completion of the bypass". It seems the town loses out either way -- it will be congested with or without the bypass. The problem is congestion, not capacity, and that can be solved by traffic reduction; no-one has suggested that doing nothing is an acceptable solution.
b) "This study is not the place for deciding the national debate". Most people who do not have a vested interest in seeing that the scheme goes through would argue exactly the opposite, that Newbury is the very pivot point of transport policy. Newbury is where we must decide between the old order (or ever-increasing road capacity) and the new (demand management -- doing what we can inside the existing road network).
c) "We carry no conclusion forward" -- not just no conclusion on the national debate, but presumably none on SACTRA either.
3.30 The detailed COBA figures for Newbury have yet to be released by the HA for analysis. This section will be updated in due course.
But we note here that the COBA method (and COBA9 in particular) is inherently flawed:
a) The COBA9 manual itself states that COBA "does not purport to measure value for money over the whole range of costs and benefits, including those broadly classified as environmental." [98] This is a particular problem on a route of such high environmental value as the Western bypass.
b) RCEP: "It is an unsatisfactory feature of... COBA that use of low cost land of high conservation value gives a scheme a more favourable cost-benefit ratio." [99] and "Many of the techniques which the [TPP] package approach is designed to stimulate (such as traffic calming, bus priority, pedestrianisation) would score badly in the customary COBA assessment (which attaches a high value to measures to speed up traffic flows)" [100]
c) COBA places value on collective, rather than individual, benefits. The House of Commons Transport Select Committee has stated: "The assumption that small increments of time have real economic value when aggregated over a large number of vehicles is unsubstantiated."
d) COBA takes no account of induced traffic. SACTRA findings are bolted on top as "guestimates".
e) RSPB: "A further criticism of COBA and the economic appraisal of roads is the understatement of costs. According to a recent report by the National Audit Office (NAO 1993), the cost of the 1989 road programme has been greatly underestimated: 'The estimated total cost of the widening schemes... has increased by 46%... The extent of the widening programme has also increased through the addition of new schemes... The total cost... is now estimated at 78% larger... than in 1989.' Furthermore, the NAO's analysis of 10 of the 18 completed schemes noted that the final cost was on average some 103% higher than the original estimate." [102]
f) Alarm UK: "COBA9 is junk sub-science used by the DoT to bamboozle and intimidate those who question the DoT's road proposals. It is based on a series of hidden assumptions that cannot be justified."
It is this flawed COBA analysis that is used to justify the A34 Newbury bypass.
3.31 SCHEME EXPENDITURE:
a) Some "other practical alternative options for reducing congestion at Newbury" have not been considered in this report; only the Western route and the very flawed variation on the old Eastern route are COBA costed.
b) The Western bypass figures should be updated with a more realistic estimate of costs, given the proportion of schemes that exceed their budget.
c) That £5 has been spent is irrelevant, if the scheme as a whole does not represent a cost-effective solution to the traffic problem -- should we throw good money after bad? Some alternatives, such as demand management and traffic reduction are very much cheaper than a Western bypass; the saving would greatly exceed the £5 already spent.
d) What is the real cost of the Western route? Much higher than has been suggested, given the cost of over-run (typically a third of road projects exceed their budgets), extra archaeological excavations that now seem essential [120], porous asphalt, security and policing costs...
3.33 The analysis should also take into account:
a) RCEP recommendations
b) Rio 1992 commitments to biodiversity and sustainable development
c) PPG13, whose significance seems to have been missed
d) PPG15, which is not mentioned
e) Dr Mawhinney's call for a great national debate on transport.
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SECTION 4: EVALUATION:
Section 4 bypassses the study's remit altogether, which was "to look again at the published route and any other practical alternative options for reducing congestion at Newbury, including, but not limited to, those already considered."
But the evaluation redefined is remit as merely examining the three main options offered at the Public Inquiry, and reaffirming them.
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SECTION 5: HAVE THE TRAFFIC PROBLEMS IN NEWBURY CHANGED?
5.1 This suggests that the key problem is separating the traffic into its different components and finding a solution for each; massively increasing the capacity of the road will simply allow the dominant traffic components to increase even more.
5.2 It also illustrates that the existing A34 is a failed bypass.
5.3 This is a strong argument against a traffic "solution" that would take 2-3 years to construct; the problem seems to be more pressing. As the problem is one of peak hour congestion, the solution points to specific measures to address the peak hour problems: commuting across town to work, school trips, major race meetings, and so on.
5.4 a) If national growth has been "virtually static", the 15% growth on both A34 approaches looks like a local problem -- it needs a local solution. A capacity increase would presumably do no more than provide further growth in local traffic.
b) Has national growth really been static between 1990 and 1994? The overall growth seems to be static, but certain types of journey are still growing at the expense of others. For example, school and shopping trips are still increasing -- and these are exactly the kinds of trip that will make the Newbury peak-hour problems worse.
5.3-5.6 "The current situation... is intolerable." There has never been argument that Newbury has a serious traffic problem; the dispute is about whether the Newbury bypass represents any kind of solution, and if so, whether the benefits offset the massive environmental costs.
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SECTION 6: IS A NEWBURY BYPASS PART OF THE SOLUTION?
6.1.1 As the Newtown Straight is relatively lightly loaded, the study should focus on "urban Newbury", where the real problems are perceived to be, and where bypass relief is claimed to be a mere 36%
6.1.2 "Flows on the existing A34, near to the centre of the town, could be around base levels by 2010". Add in suppressed demand, the effects of in-fill development, and the probable 20% underestimates in the forecasts [16], and even this benefit looks doubtful -- strongly suggesting base levels will be reached sooner.
"Goods vehicles... would remain well below current levels." But this is by no means guaranteed, and is contradicted by section 2.6, which speaks of a 50% growth in goods vehicles between 1983 and 1994.
6.1.3 This, with 6.1.12, translates roughly to: "The objective of the A34 bypass is to massively increase the capacity of the road for through traffic, while doing nothing to relieve local traffic congestion."
6.1.4 "By removing a large component of the traffic on the A34..." Section 6.1.1 quantified this component as 36%. Given that the majority of the traffic on the central A34 section is local in origin or destination, the objective is to reduce local traffic, not to give it "higher priority" if this just means further scope for expansion.
This is consistent with the RCEP: "Where the main purpose of a bypass is environmental improvement, we recommend that:
i) The design standards should provide only for the traffic flows which will be diverted from the town or village bypassed, not for further large growth of traffic;
ii) The design, funding, and implementation of comprehensive traffic measures in the area bypassed should proceed on the same timescale, and be given the same priority, as the bypass itself." [103]
6.1a) "A bypass would... meet in full the needs of trunk road traffic passing through Newbury on the A34." Local people have been led to believe that the sacrifice of their spectacular countryside is an acceptable price to pay for a road that will solve the local traffic problem, but this is clearly not the case: the road is a massive Euro freight route that shows no prospect of solving the town's own congestion.
b) Not only would a bypass "not solve all of Newbury's traffic problems", it would actually create new problems of its own. As section 2.4 shows, the road would produce a 50% increase in traffic on most other roads in the town. This would cause not only traffic problems, but safety problems too. As Inspector Frank Squires, Newbury Police, stated in 1990: "Problems will start when the bypass opens. The use of the A34 will suddenly increase because they will be able to drive all the way from Southampton to Liverpool where, before, Newbury has been the problem." [104]
6.2 OTHER OPTIONS:
This, the crux of the HA's remit, warrants only four pages -- a mere 11% -- of the report.
"There is nothing different about Newbury which makes a reversal of traffic growth more possible there than elsewhere." But we have already considered at some length that road building is not an answer to congestion (section 3.26ff) and that we cannot build our way out of the problem. Both SACTRA and the RCEP (see section 3.27.2) point to demand management and traffic reduction: "We recommend that DoT... investigate whether some towns and villages could obtain most of the benefits of a bypass more cost effectively and with less environmental damage, through traffic management measures." [105]6.3 DO NOTHING:
As RCEP suggests, letting congestion find its own level is an approach to transport policy, but: "The self-regulating nature of congestion will not lead to an efficient outcome in economic terms unless the costs of such delays are met by those who cause them." [106]
The point about "do nothing" is not that it is a good solution, but that it may be preferable to a highly destructive road and the recurrence of congestion, sooner or later, on a higher capacity alternative route or on the original road -- that is, "do nothing" may be preferable to scaling up the problem both in environmental and economic terms.
6.4 OTHER ROUTES REMOTE FROM NEWURY:
There should be an analysis here of the extra road improvements that will be required if the A34 is increased in capacity at Newbury, moving the congestion bottleneck elsewhere. They are likely to include:
* A34/M4 Chieveley Improvement -- linked to the Newbury bypass.
* M3 widening -- already planned
* M4 widening -- already planned
* M27 improvements along South Coast -- already planned.
* A34/M3 Winnall Junction at Winchester
* M40 improvements/widening? (a study by Oxfordshire County Council suggests a stretch of the M40 may be over capacity by 2012, with most of the road over capacity in Oxfordshire by 2022 [107].
The A34/M4 improvements and M4 widening are particularly significant.
6.5 RAIL:
As has already been considered, this section compares the present under-funded rail network with a future, high investment trunk road. It seems unlikely that the HA is the right body to provide an objective assessment of the relative merits of road and rail alternatives, particularly where a choice of investment between the two is required.
6.5.2 "The Inter-City Cross Country services... conflict and connect." What does this mean? It also applies to North/South and East/West road routes through Newbury. There is a direct passenger and freight rail route from the South Coast to the Midlands and the North; there are at least three alternative routes between the South Coast and Birmingham, and the journey takes comparable time for passenger traffic:
* Birmingham-Oxford-Reading-Winchester-Southampton
* Birmignham-London-Southampton
* Birmingham-Gloucester-Bristol-Southampton
The Railway Development Society (RDS) informs us there is considerable space capacity on the first route, at least.
6.5.3 a) "The travel times... compare unfavourably with the car times." But section 5.13 speaks of at least 45 minute delays to car traffic in Newbury at bad times, which would make car journeys unpredictable, and car and rail journey times comparable. The point is simply that if Newbury traffic is bad enough to warrant a bypass, as this study claims, it is bad enough to deter people from travelling by car, in favour of travelling by train.
b) Journey time is less important for some freight, which can be moved at off-peak passenger times by rail (during the night or at weekends).
6.5.4a) The rail service is described as "sparse", with only eight through trains in each direction, but this takes no account of connecting trains, which would increase the number of North-South trains to perhaps twenty or more. In addition, rail is a much more efficient people carrier than roads; one train can carry more than 500 car equivalents of people -- so "sparse" is, if anything, a tribute to this.
b) The discussion of transfer from A34 car users is very misleading, because the majority of A34 traffic is local and travelling only a very short distance; a consideration of the transfer potential to buses and coaches, cycling and walking, would be much more appropriate. There should really be an analysis of travel patterns between pairs of destinations served by private car, bus, and rail, and the transfer potential of each.
c) The real question is how effectively the rail, coach, and bus network could absorb road traffic if the £100-£150 million destined for the Newbury bypass were channelled into it:
i. Over the period 1985-1993, "road-related investment represented over 90% or more of transport investment" [108]
ii. "Road building is less effective in creating employment than investment in the upgrading of railway lines or housing." [109]
iii. "The length of the rail network has been reduced by about half since the beginning of the century." [110]
iv. "Britain invests less in its railways per capita than almost any other European country. We currently spend less than a third of the European average." [111]
d) There are other advantages of rail over road: "In rural areas, a three-lane motorway averages 46.5m in width and a three lane trunk road 30.5m. This compares with only 9.14m required by a double-track rail -- less than 20% of the width of a motorway. A modern suburban train system can carry 70,000 passengers per hour per track, whereas road would require three times the space to carry the same number." [112]
e) A true comparison between road and rail must compare like with like -- road and rail/bus/coach alternatives operating along broadly similar routes. For example, "a study funded by Eurotunnel local authorities, and the European Commission has concluded that for only £70 million, an 800km route from the Channel Tunnel to Scotland could be upgraded by 1997 to carry road trailers on railway wagons 'piggy-back' and that by this means 400,000 trailers a year could be taken off the roads by 2000. That would be 9% (56 million vehicle kilometres) of current HGV traffic between the UK and the continent." [124]
It is possible that something similar could be considered with the route between Southampton, the Midlands, and the North. Six Foot Railway Consultants and the Railway Development Society have produced a fully-costed rail package from Southampton, through Newbury, to York and Stockton, at a total cost of £500 million for the entire length, compared to the £150-200 million needed to upgrade the road network just around Newbury (bypass and Chieveley schemes together).
f) Consider also: "We were impressed by the target adopted by the Dutch government for increasing rail transport of freight in the Netherlands, where it has a smaller share of the market than in Britain, and has likewise been declining. The target in that case was to increase goods lifted by rail to 50 million tonnes in 2010, 150% more than in 1987." [113]
6.5.7 "The traffic forecasts for the bypass are considered to be robust with respect to transfer to rail." This translates as: if we invest £100 million in the road network, even more traffic will travel by road and even less by rail.
This is a major problem with the A34 road proposal, particularly considering that it is a TERN route; it will actively encourage the transfer of freight from rail to road: "Unless an environment-oriented traffic management is introduced into the EC liberalization and harmonization package, a significant shift of frontier-crossing goods traffic from rail to road must be expected, for the decisive factor in modal choice is the perceived relative change in the attractiveness of the different known alternatives, and the proposed EC package is by and large likely to enhance the attractiveness of long-distance road haulage only." [114]
The A34 TERN will therefore be at odds with EC transport policy, for as the Transport Commissioner's cabinet states: "The balance of TEN investments represents a strong effort to shift travel from road to rail." [115]
6.6 PUBLIC TRANSPORT & TRAFFIC MANAGEMENT:
Local traffic is at least 70% of the problem in central Newbury. There is considerable scope for demand management and traffic reduction, as a study now being prepared by MTRU consultancy for FoE clearly illustrates. This is consistent with RCEP, which recommended that: "DoT investigate whether some towns and villages could obtain most of the benefits of a bypass more cost-effectively and with less environmental damage through traffic management measures." [105]
No additional capacity is needed for this; there would be sufficient spare capacity in Newbury if the 70% of short-distance local traffic were subject to a package of traffic reduction measures. Moreover, as the A34 will be back to its current problem levels by 2010 -- at the latest -- there is no argument against reducing traffic now.
6.7 DO MINIMUM:
a) The real objective is, of course, "do maximum" to solve the traffic problem. It is far from clear that the proposed bypass would make any difference in this respect.
b) It is too simplistic to write off all online alternatives as "variations of the central route". Online alternatives should have been presented here and evaluated in full. At least two online alternatives were suggested to the HA by opponents of the Western route: the Steer Davies Gleave report, prepared for FoE, which sought to improve traffic flow by altering junction priorities and restricting access to the A34; and an alternative involving underpasses. Both of these were only partially developed, but both should have been evaluated in detail here, given the study's objective to "consider any other practical alternative options for reducing congestion at Newbury".
c) Online improvements would apparently suffer from not "relieving the town of its traffic or its congestion". But the Western bypass would not relieve the congestion, as section 3.29.4 admits, and would actually bring more traffic to the town (as section 2.5 shows).
d) "Significant increases in capacity could only be achieved..." The report is obsessed with increased capacity, not a discredited central objective of UK transport policy, as we have already considered (section 3.26ff).
e) "...if minor schemes could be identified, their usefulness would be short lived because increasing traffic would quickly use up the small extra capacity provided and would provide no answer to the basic problem."
As the "basic problem" is too much local traffic, and the solution is local traffic reduction, that would open up spare capacity to non-car users or community (public) transport.
6.8.1 "There is no scope for a different approach, without major road construction, to the problems of congestion in Newbury." We disagree entirely. We contend:
a) There are alternatives involving no major road construction. the FoE/MTRU package is one such.
b) The Western bypass would not solve the problem of congestion in Newbury, as 3.29.4 admits: "For local traffic, the wider network is congested and would remain so on completion of the bypass" and 6.1.2 "Flows on the existing A34, near to the centre of town, could be around base levels by 2010." It must be remembered that these conclusions rest on a flawed analysis (COBA9 and 1989 NRTF) or flawed (1983 O&D) data.
c) The "window of opportunity" argument -- that the bypass offers s short period of relief during which traffic could be calmed in the town -- is also flawed:
i. The existing A34 will not be detrunked; it will become the A339 and will remain the responsibility of the HA. There are no current plans for demand management and traffic reduction, suggesting the HA will only start to consider them when the road is complete. There is no guaranteed funding for these measures.
ii. Given the suppressed demand on the A34 and the speed with which motorists may respond to the increased capacity, there is considerable scope for induced traffic and congestion recurring quickly.
iii. The overwhelming majority of traffic on the A34 is local in origin or destination and would not divert to a bypass.
These suggest any "window of opportunity" would be small both in size and duration. There is no argument against local traffic reduction now.
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SECTION 7: WEST, CENTRE, OR EAST?
7.1.1 All other options having been swiftly rejected, or not even considered, the study now proceeds to reaffirm the Public Inquiry conclusion, using the same flawed assumptions and the same flawed data -- and assuming nothing significant has changed since 1988.
7.1.2 The study's consideration of what is or is not of significance seems biased and arbitrary: biased, because the evidence carried forward is only that which favours the case for a Western bypass; and arbitrary, because many items of relevant data are not considered at all.
It is the defined aim of this study (see annex) "to look again at the published route and any other practical alternative options for reducing congestion at Newbury". This should, in fact, exclude the Western route, as section 3.29.4 and 6.1.2 point out that it will not solve the congestion problem. Keith Buchan of MTRU states: "The HA has simply reviewed the choice of route, not whether a road is needed or not. It dismissed other options in just six lines, and has not even fulfilled its own terms of reference, which included full investigation of alternatives to the bypass. The report is a world away from modern transport policy thinking." [116]
7.1.3-7.1.5 We have already given comments on those things that the HA has suggested are new or changed since the Public Inquiry. We consider the following significant items should be brought into, or given greater consideration in, the evaluation:
1. The Royal Commission on Environmental Pollution report, "Transport and the Environment". Many of the RCEP recommendations apply to Newbury, but are not even considered. That the Government has not yet issued its detailed response to the Royal Commission does not prevent its recommendations from being considered here.
2. The SACTRA report. See section 3.29.2.
3. The information unearthed since the Inquiry. See 2.9.
4. The real nature of the peak hour problem. See 2.7.
5. New ecological evidence. See 3.6, 3.22, 3.23.
6. The English Heritage Battlefields Register. See 3.25.
7. PPG13.
8. New archaeological data. See 3.24.
9. Changes in land use associated with the bypass. See 3.18, 3.19.
10. Changes in traffic and economic data. See 3.26-3.30.
11. Other trunk roads that may need to be improved if the bypass is built.
12. The "hidden costs" of the Western -- for example, the high cost of policing and the probability of cost overrun.
13. Corridor effects -- knock-on traffic problems in neighbouring towns that have not been evaluated.
14. Commitments made at Rio in 1992 on sustainable development and biodiversity.
15. Dr Brian Mawhinney's call for a national debate on transport policy.
As the RCEP states: "The fundamental significance of the Trunk Roads Act 1936 was that by giving the Ministry a direct executive responsibility for this one aspect of transport only, it inevitably resulted in an organizational commitment to inter-urban road building at the expense of an overall and balanced view of transport needs." [117] It criticizes a road planning process that is "largely restricted to considering the route of a proposed road and [has] not proved alternative strategies which would remove the need for it." [118]
We offer no more detailed comments on section 7, which we consider asks fundamentally the wrong question, exposing once more the flaws in a road-obsessed transport policy. In this, we agree with SACTRA, who said:
"It will simply not be possible to cater for future unrestrained demand by private vehicle. Demand management measures and public transport policies are likely to form part of an overall transport strategy aimed at containing the demand for travel by road within the capacity of the road system".
---oOo---
REFERENCES:
Main documents:
RCEP: Royal Commission on Environmental Pollution, 18th Report, Transport and the Environment, HMSO, London, October 1994.
SACTRA: Standing Committee on Trunk Road Assessment: Trunk Roads & the Generation of Traffic. D.A. Wood et al, HMSO, London, December 1994.
EEC: European Commission DGXI (Environment, Nuclear Sfatey, and Civil Protection) Complaint Numbers P94/4867 and P94/4875: Newbury Bypass: Response to EC letter dated 7/3/94, 25th May 1995: Jo Carter, Jill Eisele, Jan Stephens, Chris Woodford.
T2000: Transport 2000: Transport Trends & Transport Policies, Myths and Facts.
RSPB: Bina et al (June 1994), "Transport & Biodiversity: A Discussion Paper", RSPB, Sandy, June 1994.
FoE: Tim Pharaoh: "Less Traffic, Better Towns", Friends of the Earth, London, 1992.
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1. "Tories Plan U-Turn on Car Culture", Observer 16/10/94.
2. RCEP (as above).
3. RCEP pxiii.
4. SACTRA (as above).
5. SACTRA 12.38
6. Newbury Bypass Study Report, Highways Agency, July 1995.
7. EEC p5.
8. EEC p10.
9. EEC p4.
10. RCEP 13.89.
11. "CBI wants A34 to become expressway", Newbury Weekly News, 17/12/92.
12. RCEP 13.99.
13. RCEP 13.100.
14. Traffic forecasts for Newbury, 1993 & 2010, Mott Macdonald Document 0003/N1/B.
15. SACTRA 5.15
16. SACTRA 5.18
17. Local Transport Today, March 1995.
18. RCEP 10.1
19. T2000
20. RCEP 10.7-10.9
21. RCEP 10.40
22. RCEP 10.48
23. RCEP recommendation 59, 14.63
24. T2000
25. Evening Standard, London, 28th July 1995.
26. SACTRA 4.28
27. EEC p3 ff.
28. EEC p5
29. T2000
30. RCEP 3.13
31. RCEP 3.14
32. Newbury Districy Council: Notice of Meeting & Agenda, Local Plan Review Panel, 11/10/94, M.J.Harris.
33. "Threat of pollution greater for drivers", Times, 28/1/95.
34. RCEP 3.26
35. Transport Select Committee: Inquiry into Transport-Related Atmospheric Pollution in London: Evidence submitted by the National Asthma Campaign, 5/7/94.
36. Dr Robin Russell-Jones, Letter to the Editor, The Times, London, 14/1/94.
37. Council Directive of 27 June 1985 on the assessment of the effects of certain public and private projects on the environment (85/337/EEC) -- "The EIA directive".
38. Bickmore & Dutton cited in RSPB p17.
39. River Kennet Catchment Plan: NRA, 1994.
40. "Transport: the way ahead", Speeches by Dr Brian Mawhinney, M.P., DoT, 1995. Section 2.17, p21.
41. DoT Landscape Advisory Committee.
42. Position statement on "Roads and Nature Conservation", English Nature, Peterborough, September 1992.
43. Letter from David Henshilwood, Thames & Chilterns Team English Nature, to Simon Festing, Friends of the Earth, 25/5/95, ref: IA3.03.051/DAH.
44. RCEP 4.60-4.61
45. Letter from David Henshilwood, Thames & Chilterns Team English Nature, to Chris Woodford, 25/5/95, ref: IA3.01.051/AH.
46. RSPB p11.
47. Planning Policy Guidance note 13 (PPG13), DoE, March 1994.
48. Battlefiels: The Proposd Register of Historic Battlefields, English Heritage, September 1994.
49. Statement made by Jocelyn Stevens, launch of English Heritage Battlefields Register, 6/9/94.
50. RCEP 9.12, 9.13.
51. SACTRA 13.39
52. Headicar & Bixby (August 1992), "Concrete & Tyres: Local Development Effects of Major Roads: M40 Case Study", Oxford Polytechnic.
53. Letter from Frank Lucas, RSPB Central Region, to Chris Woodford, 20/4/95, ref; FL/PB/nbepecom/SU46
54. RCEP 4.49
55. RCEP 4.48
56. "Roads programme on hold after report questions benefits", The Times, 20/12/94, p2.
57. "Environmental Assessment", DoT, 1993.
58. High Court of Jutsice CH 1993 A 5198, 18 APril 1994: Bocardo Societe Anonyme & Mohamed Abdel Moneim Al Fayed v Secretary of State for Transport & Surrey County Council.
59. Letter from Alan Lloyd, Chairman, Planning & Transportation Committee, Hampshire County Council, to Chris Woodford, 5/6/95, ref: AL/1mb/t
60. "Europe may put brake on Newbury bypass project", Daily Telegraph, 5/11/94, p6.
61. RCEP 3.71
62. RCEP 4.57
63. "The Directive Fauna, Flora, Habitats", non-technical brochure explaning directive 92/43/EEC, DGXI, European Commission.
64. RCEP 9.9
65. RCEP 9.10
66. SACTRA 13.39, 10.51
67. FoE (as above)
68. RCEP 2.14
69. Johnathan Bray (1992): "The Rush for Roads", a Movement Transport Consultancy report for Alarm UK.
70. DoT Deposit Document Number 1, 1992 Public Inquiry.
71. English Nature & the A34 Newbury Bypass: A Position Statement, Thames & Chilterns Team English Nature, 11/5/95.
72. RSPB Position Statement, Newbury Bypass, August 1995.
73. Bioscan Environmental Consultancy Report for the NRA: Newbury Bypass: Rivers Kennet & Lambourn, 1994.
74. Lee Donaldson Associates Report for the NRA: Newbury Bypass: Rivers Kennet & Lambourn, 1992.
75. Letter from David Henshilwood, Thames & Chilterns Team, English nature, to Chris Woodford, 14/7/95, ref: IA3.01.051/DAH.
76. Planning Polic Guidance note 15 (PPG15), DoE, 1994.
77. RSPB p20.
78. Letter from English Heritage to DoT, 1994.
79. RCEP 6.25
80. RCEP 6.26
81. RCEP 6.29
82. SACTRA 12.28
83. SACTRA 12.33-12.35
84. SACTRA 12.50
85. FoE p57
86. John Adams: Transport Planning: Vision & Planning, RKP, London, 1981.
87. Oliver Tickell: Accelerating on the road to a fiasco, The Times, 29/7/95.
88. Response by the DoT to the report by SACTRA, December 1994 p6
89. SACTRA 11.23
90. Reply to Parliamentary Question by John Watts M.P, 1995.
91. Transport Retort, Transport 2000 Journal, 18/2, Mar/Apr 1995,
p13
92. SACTRA 5.16
93. SACTRA 5.21
94. SACTRA 5.29
95. SACTRA 5.82
96. SACTRA 12.10
97. SACTRA piii.
98. COBA9 Manual, Introduction
99. RCEP 4.48
100. RCEP 13.36
101. "Traffic modelling, cost-benefit analysis, and traffic generation", Alarm UK briefing sheet, 1995.
102. RSPB p88.
103. RCEP 14.65
104. "Drivers warned A34 traffic could increase by 40%", Newbury Weekly News, 22/11/1990.
105. RCEP 4.34
106. RCEP 6.13
107. RCEP 6.30
108. RCEP 2.10
109. RCEP 2.13
110. RCEP 4.45
111. T2000 (as above)
112. RSPB p20
113. RCEP 10.63
114. Cerwenka, P (1990): Traffic Management for European Long-distance Traffic Focussed on International Goods Transport, quoted in RSPB p52.
115. Letter from Chris Boyd, Office of Neil Kinnock, Transport Commissioner, European Commission, to Chris Woodford, 25/4/95.
116. "Review of Newbury Bypass is deeply flawed say independent experts", FoE Press Release 6/7/95.
117. RCEP 13.80
118. RCEP 13.89
119. "Need for Newbury Bypass exposed as myth by government data", FoE Press Release 21/8/95.
120. "Stone age site sacrificed for new road", Telegraph, 20/8/95.
121. Letter from Chris Woodford to David Henshilwood, Thames & Chilterns Team, English Nature, 17/6/95.
122. "Fast & Filthy: the case for lower speed limits", FoE, 1991.
123. SACTRA 5.39
124. RCEP 10.29