Memorandum by CPRE (RP 06)
M6 TOLL ROAD
The Campaign to Protect Rural England (CPRE)
is strongly opposed to the concept of a new "Express"
tolled motorway in Staffordshire and Cheshire. This evidence is
submitted by CPRE's national office and CPRE's West Midlands and
North West Regional Groups, and is based on our extensive knowledge
and experience of both national and regional transport debates.
Gerald Kells (CPRE's West Midlands Regional
Policy Officer) and Lillian Burns (CPRE's Cheshire Vice Chairman,
who represents CPRE's North West Region on Transport) sat on the
West Midlands to North West Conurbation (MIDMAN) Multi Modal Study
Steering Group. Gerald Kells was chairman of the Alliance Against
the Birmingham Northern Relief Road and gave evidence at the 1994
Inquiry (then for West Midlands Friends of the Earth). Both Gerald
and Lillian serve on the MIDMAN Implementation Group.
How effective has the existing M6 toll road been
in tackling congestion on the M6, on the new toll road and on
the surrounding area? What impact has the M6 toll had on traffic
levels?
1. It is too early to make any definitive
judgement on the impact of the M6 toll motorway, although there
are worrying signs that it is inducing new traffic movement and
causing problems on other parts of the road network around Birmingham
and the Black Country. The Highways Agency itself admits that
traffic is still settling down after the opening of the M6 toll
and there is likely to be reassignment onto roads where traffic
has temporarily been relieved as well as "oscillation"
between the primary route options.
M6 Toll/M6
2. The level of traffic of the M6 Toll (37,500
per day) is currently lower than the Highways Agency/MEL forecasts
at the Public Inquiry (50,000 in 1996 rising to 71,000 in 2011
on the busiest section) but not outside the stated preference
margin of error. The transfer from the M6 (using the 2011 figures
which are probably the closest to the actual present day figures)
was predicted to be of the order of 24,000 vehicles a day (or
half the through traffic), however the reduction in traffic on
the M6 was only predicted to be 1,000 north of the M5 and 6,000
south of the M5. Given that there have also been significant transfers
from the A5/A38 and A50/A500/M1 route to the M6 Toll, it would
seem likely that the Toll Road is not attracting the figures expected
from the M6.
3. The current reduction in traffic on the
M6 of between 12,000 and 19,000 vehicles per day has not removed
congestion, although it has dipped at some times of day, and probably
does not represent the long term stable position for the network.
The M6 is likely to attract back (and to generate) traffic until
it reaches the equilibrium of approximately 160,000 vehicles which
it started off with, more in keeping with the longer term predictions
at the Public Inquiry which did not envisage significant reductions
in overall M6 traffic. Neither CPRE nor the Highways Agency expect
travel patterns to settle down for at least two years, especially
given the current road works on the M6. As MEL said as far back
as 1992 "It is unlikely that the projected figures with or
without the BNRR would differ substantially. The bulk of any released
capacity on the M6 would, of course, be taken up by traffic which
would otherwise remain on the non-motorway trunk road network
within the conurbation" (MEL Letter: 21 August 1992) and
as the Highway Agency said in 2001 to Staffordshire County Council:
"Unfortunately a review of predicted traffic flows post BNRR
carried out by Oscar Faber advises that flows are unlikely to
reduce on the M6 South of [the northern end of] BNRR" (Letter
from HA to Staffs County Council 18 January 2001).
Impact of development
4. CPRE believes such benefits as exist
within the system will be dissipated thinly through the road network
and undermined by further traffic generation, especially given
the way in which the road can create undue pressures for new traffic
generating development along the corridor. One example would be
the large Ikea site on the M6 at Junction 9. The company are seeking
to expand operations on the site, but have also been looking at
sites south of the congested area (for example at Longbridge)
because congestion is putting people off visiting their store.
This is just one example of latent demand for new travel on the
M6 through the conurbation which will undermine the impact of
the toll road.
5. The M6 Expressway Consultation document
refers to "one fifth of traffic flowing through the West
Midlands Conurbation" (para 4) using the toll road. This
sounds impressive but is misleading. The percentage of overall
traffic carried by the M6 Toll in the West Midlands region, if
it reached the Inquiry figures, would be 1% of total traffic.
Even on the M6, which is designed for through-traffic, less than
30% (20% at peak times) passes all the way through the conurbation.
And because the majority of traffic is locally generated the final
effect of the road is likely to be much less than popularly expected.
There is also plenty of potential for readjustment of traffic
flows to occur on the network as a whole which will minimise the
overall gains. The Expressway would certainly not be a "silver
bullet" to solve congestion in the region.
Congestion displaced
6. The toll road has, however, displaced
congestion, as predicted in the traffic modelling at the Inquiry.
Rises in traffic on the M6 south and north of the road and on
the M42 were anticipated as some traffic increasingly concentrates
on the motorway network. On the M42 the rise of 5 %, reported
in the Monitoring data, is likely to tip the balance between being
congested and not congested at many times of the day. The traffic
predictions from the Inquiry suggest the long term increase in
traffic on the M42 as a result of the toll road will be greater
in impact than the reductions achieved on the M6 in Birmingham.
Effects on other A roads
7. The M6 Toll Monitoring Report looks at
a number of other routes taking screen lines across the M6 Toll
to pick up parallel A roads. These demonstrate small benefits
on routes adjoining the M6 Toll but increases on A road routes
at the end of the toll road. The Inquiry figures suggested a more
mixed bag with congestion on many access roads increasing. This
difference may suggest that less locally generated traffic is
using the toll road than MEL and the Agency predicted. Whatever
the cause congestion on many A road routes will increase. We hope
the Committee will investigate the redistribution of traffic and
congestion as part of its inquiry.
Freight traffic
8. There has been very little freight use
of the motorway and this may well reflect the toll price. MEL's
elasticity work for the Inquiry suggested no more than 30% of
HGVs were likely to use the route and that it would peter off
pretty sharply to zero if tolls were high. On that basis, objectors
from the environmental sector argued at the Public Inquiry that
lorry tolls should be pegged to car tolls. The Secretary of State
rejected this option (although it was endorsed by the Inspector)
on the basis that MEL was unlikely to place excessive tolls on
lorries and because the issue was not (at that time) raised by
hauliers. In the event, the toll has been punitive to lorry drivers.
MEL have now reduced their lorry toll, however, they are under
no obligation to continue to keep it low in the longer term. It
is likely that as traffic rises over time and MEL positively wants
to discourage too much traffic (causing congestion and making
the road unattractive) that they will want to increase lorry tolls
disproportionately. While we can only speculate, it may be that
their current reduction in lorry tolls reflects the need to get
additional short term revenue in the early part of the scheme,
or a concern that adverse publicity on this issue would affect
any bid for the M6 Expressway, or the stringency of the terms
of any future concession agreement.
9. Concern over freight not using the toll
road does not, of course, only relate to current freight traffic.
Proposals for Logistics Developments are anticipated to emerge
in areas such as Cannock, Burntwood and further North in Staffordshire.
They may be granted permission on the basis that the generated
lorry traffic will use the toll road, when in reality it wouldn't
but rather would add to congestion on other roads in an unplanned
way.
Is a new "Expressway" preferable to
widening the existing road?
10. The DfT consultation paper prioritises
the needs of motorists over those of other transport-users. Following
its logic, what is the motorist's benefit? According to the M6
Expressway consultation document the Toll Road has "made
a significant impact on improving journey times through the West
Midlands" [para 3]. It quotes a number of figures to justify
this. The maximum time saving, with the exception of Friday afternoon,
appears to be 30 minutes, and the average, 12 minutes southbound
and seven minutes northbound. However, these figures are not complete
journey times and, if congestion has been increased on routes
such as the M42, the real saving may not be as great as it appears.
It may even be negative. It is quite possible that those people
who are saving 7-12 minutes (and some even less) will be losing
time on other routes. Experience suggests that non-users of the
toll road are likely to be quietly suffering increased congestion
elsewhere with no benefit from the toll road. Whether people paying
the toll would do so if they had better information on alternative
routes, for example by GIS systems in their cars, and they knew
that they were paying £3.00 to save only 10 minutes, will
only be tested when such technology is more widely available.
There has never been any analysis to show that the overall cost
in tolls to motorists represents good value for money. It is important
to note that neither of the CPRE representatives on the MIDMAN
steering group agreed with the view that four lane widening was
the best option and the Study itself only says it is better as
a matter of "subjective judgement" over non-widening
options. It rejects five lane widening. (Midman Report: para 6.5.4).
11. The study did envisage widening being
accompanied by tolling the whole of the motorway in due course.
CPRE believes the best way forward in the long term for road charging
would be to develop an overall road user charge system which avoids
the diversionary aspects of motorway tolling. However, we accept
that tolling the whole motorway as part of a widening scheme would
be a reasonable approach to demand management. Placing a toll
road next to the current road would not represent demand management,
but would be another way of catering for demand. MIDMAN did not
envisage a new route of this nature but it did examine the concept
of a whole new motorway, albeit one on a more direct route between
Manchester and Birmingham. This idea was rejected largely on environmental
grounds.
12. One major difficulty in justifying a
new motorway is the lack of traffic. The consultation paper claims
the M6 "is one of our busiest motorways" [para 2]. This
is in our view misleading, because it does not apply to the sections
in question which are not nearly as congested as the M6 in the
West Midlands conurbation. Nor is there the volume of overall
traffic in the corridor one would expect on an urban road network.
The MIDMAN analysis suggested traffic volumes on the Staffordshire
section of the M6 traffic volumes would not be expected to reach
national capacity of 120,000 vehicles a day in the next decade
and won't exceed 140,000 vehicles a day in the next 30 years.
The Cheshire section would only be slightly more heavily used.
Assuming such long term forecasts materialise (ignoring future
uncertainties relating to climate change and world oil supply)
there would still not be the same level of other A-road traffic
in the corridor to transfer to the new toll road. In particular,
the significant transfer of traffic from the A50/A500/M1 route
as a result of the M6 Toll has already taken place and could not
be repeated on the M6 Expressway. Looking to predicted journey
time variability is no more helpful in justifying the concept.
Currently, the journey variability is only 10 minutes off peak
and 15 minutes on peak, and that over a distance twice that of
the M6 through the West Midlands conurbation. Given the need to
recoup the cost of an Expressway over double the distance, it
seems hard to see how a toll could be set which would attract
enough drivers to make the exercise pay, especially given that
something like 70% of drivers are not using the motorway all the
way from Cannock to Knutsford.
13. Whichever option is pursued, the increased
traffic at either end of the M6 Toll Road in the West Midlands
suggests there could be similar problems on a new M6 Expressway.
This would be likely to manifest itself on the motorways at either
end. This would include the sections of the M6 through the West
Midlands and associated A-roads, and with both toll roads linked,
even more pressure on the M42. At the northern end this would
mean either worse traffic problems in the Knutsford area than
exist at present or backlogs of traffic on the Thelwall viaduct
over the Manchester Ship Canal, or both.
Is this the most cost effective and environmentally
effective solution?
14. The argument used by the Highways Agency
against undertaking a Cost Benefit Analysis for the first M6 Toll
road was that the company would not build it if it was not profitable
or if people did not perceive a benefit. So a COBA analysis was
deemed unnecessary. As has already been pointed out, however,
the perception of benefit on one section of road does not imply
an overall benefit and for many non-users the increased congestion
on access roads to a new toll road will not be offset by using
the road.
15. If the M6 Expressway were to be pursued,
a full analysis would need to be undertaken to ensure the perception
of benefit is justified and to justify the public cost (rather
than commercial benefit) of the scheme. This would need to be
undertaken using more modern techniques, of course, such as the
New Approach to Appraisal (NATA), so as to ensure the full environmental
and social externalities, not just the time drivers save and lose,
were evaluated. We believe a Strategic Environmental Assessment
would also need to be undertaken in accordance with UK and EU
law.
Emissions and sites
16. Without a full landtake assessment of
a scheme, rather than a broad concept, it is hard to judge the
environmental impact but it is likely that air, noise and light
pollution from traffic would increase and affect a larger number
of people than conventional widening. A full environmental assessment
can only be carried out when more detail of possible routes is
known. There are a number of sensitive wildlife sites, including
SSSIs, and some historic buildings close to the route. It cuts
through open countryside and would impact on land designated as
Green Belt. It would be a further intrusion into the countryside,
and incongruous with the rolling countryside of the Shropshire,
Cheshire and Staffordshire Plain as described in the Countryside
Agency Character Area report. CPRE can submit aerial photographs
which have been taken of some sections of the proposed route to
illustrate the visual impact, if that would be helpful to the
Committee.
Land take
17. We would anticipate a significantly
larger land take with a new Expressway than with widening, although
again this is hard to quantify. Not only would there be the new
carriageways, there would need to be dedicated slip roads and
junctions with toll booths. Experience on the M6 Toll, for example,
at Burntwood, shows that these are often larger islands and their
shape is dictated by the need to accommodate toll booths. There
might well also be a new traffic management centre associated
with the route. If a motorway service area was deemed necessary
(and this would be likely because the road is longer than 30 km)
it would either be separate to the existing M6 MSAs or involve
additional land take to accommodate separate access and parking.
Lighting would also be increased especially round the toll booths.
Planning
18. The impact of the M6 Expressway should
not only be seen, however, in terms of traffic levels, or immediate
land use impact. It would undoubtedly have a profound effect on
strategic planning objectives. Both Regional Planning Guidance
(RPG 11 for the West Midlands and RPG 13 for the North West) are
strongly based on urban regeneration and reversing the population
drift to the Shires.
19. In the case of the West Midlands the
net out-migration from the conurbation is running at an annual
rate of 10,000 a year, over 20 years a loss equivalent to half
the population of Wolverhampton. In addition, those leaving are
largely the better-off families, which is undermining the goal
of achieving sustainable and balanced communities in many urban
areas. For example, in the Black Country a major sub-regional
study is being undertaken to seek a long term approach to redressing
the balance. The drift to the Shires has historically been fuelled
by the motorway network. Indeed, some of the decanting from Birmingham
to Staffordshire was planned for when the M6 was first built.
The by-product has been loss of countryside and commuter congestion.
The construction of a new inter-urban toll expressway, in as much
as it allows this pattern to continue, will almost certainly act
against the policy priorities established in the recently approved
RPG. Furthermore, schemes like the M6 Expressway may well be replicated
elsewhere in the country with similar damaging long-term effects,
if this proposal gets the go ahead.
20. The opening words of the Spatial Strategy
in the recently published RPG 11, are "The continued decentralisation
of population and investment for the Major Urban Areas and the
need to create balanced and stable communities across the region
have been identified as key issues" [RPG 11 para 3.1]. The
strategy is under threat from a number of decentralising forces.
Increasing road space into the Shires, by attracting traffic,
would undermine RPG 11 and inextricably lead to increased congestion
as the move to the Shires increases and people live in locations
where their travel needs are greater.
21. In the North West, RPG 13 prioritises
development in the North West Metropolitan Area, ie the "regional
poles" of Liverpool and Manchester, and their surrounding
urban areas. A specific policy on North Cheshire recognises the
problems of the significant development pressures being experienced
in that area and calls for a review of all development plan allocations.
Policy SD4 states that: "only those allocations which are
sustainable and which will add significant value to the development
of the national economy or which are of greater than regional
significance should be retained, together with those which meet
purely local needs." The aim of this policy is to protect
the physical extent of the North West metropolitan area and to
allow expansion only as an exception. If an M6 Expressway facilitated
new junctions in these Green Belt areas, it is easy to imagine
that new business development would aim to locate here rather
than the more central and sustainable urban areas, no doubt using
the ambiguous criteria above as justification.
22. The M6 Expressway would also seem to
be contrary to the national policies recently announced in Planning
Policy Statement 11 Regional Policy. This reinforces the Government's
determination to reduce the need to travel and reduce the length
of journeys (PPS11, paragraph 2.16). It also reinforces the criticisms
made of Government policy by the Social Exclusion Unit, namely
that it was overly focused on long distance movements made by
higher income groups to the detriment of the less well-off.
Climate change
23. The MIDMAN study report admits frankly
that all widening options are inconsistent with reducing CO2 emissions,
one of the Government's climate change goals. Given that the DfT
has now been brought within the PSA target for climate change,
it is particularly surprising that this consultation paper is
considering a reversion to policy aiming for accommodation of
increasing traffic growth. The Environmental Audit Committee has
also criticised the White Paper on transport for having "nothing
to say on the practical steps the Department for Transport would
take to tackle carbon emissions from Transport". Announcing
the publication of its report into the Budget 2004 implications
for energy, "Budget 2004 and energy", HC490, the Committee
points out that "carbon emissions from transport since 1990
have moved spectacularly in the wrong direction" (para 24)
.The associated press release calls for "a more imaginative
and radical strategy—in particular for transport and domestic
energy efficiency".
24. CPRE is seriously concerned about the
failure of the transport sector to effectively address the problem
of rising greenhouse gas emissions from this sector. None of the
Multi-Modal Studies in the West Midlands, for example, has predicted
an overall reduction in CO2 emissions as a result of their policies.
The MIDMAN study doesn't even predict a reduction in growth of
emissions as a result of its strategy, central to which is widening
the motorway (see MIDMAN para 6.3.5). There is evidence to suggest
that rising transport emissions may nullify all the effects of
energy conservation and renewables production. We note that the
Transport Select Committee has already expressed its astonishment
at the approval of road proposals which "manifestly work
against the UK's climate change commitments" (HoC Transport
Select Committee, Jam Tomorrow?: The Multi-Modal Study Investment
Plans, 2003). Of all the Multi Modal Studies examined by the Committee,
the proposals for the M6 had the worst impact on greenhouse gas
emissions.
Demand Management
25. The Government has, after much persuasion,
come round to the need for national road user charging. CPRE welcomes
the national debate which the Secretary of State has indicated
he wants to have on the subject. We fear that the debate over
national road user charging, however, will be confused by the
appearance of this consultation paper. It is our strong view that
road user charging should be a vehicle for managing demand. As
such it should be applied to existing roads to tackle existing
problems, rather as a mechanism to dampen down the problems of
traffic generation caused by future expansion in road capacity.
We urge the Committee to investigate the importance of this broader
distinction during the course of its inquiry.
Have there been any unforeseen impacts of the
existing M6 Toll?
26. It could be said that the consultation
on a second M6 Expressway as a result of the first toll road was
largely unforeseen. The Department for Transport told the Public
Inquiry into the M6 Toll that its construction wouldn't lead to
further road building. In response to evidence the DfT said: "The
BNRR would not lead to further road building and widening schemes
as Mr Kells suggests." [Response to evidence by Gerald Kells,
Page 10 para (e)].
27. The position environmental groups took
at the 1994 M6 Toll Inquiry has largely been justified. The very
limited traffic impact of the M6 Toll is largely as predicted.
In as much as freight organisations have been surprised by the
toll rate, we were not. As late as 1998, Steve Norris of the Road
Haulage Association wrote to Gerald Kells saying "We have
no evidence of any desire on the part of MEL to discourage HGV
traffic. In our discussions with them they have always reiterated
the concern which you yourself refer to, that we should be seen
as a key market for the new road." It remains to be seen
if the freight rates will stay low on the M6 Toll, and, if they
don't, there are no Government powers to stop MEL doing as they
see fit for the length of their 53 year concession. Even if the
toll road was used by some to justify developments which generated
significant lorry movements, local people would have no guarantee
that traffic would use the toll road rather than other, less suitable
routes.
28. As regards land use implications, these
have yet to fully emerge. The M6 toll is already being used to
justify development in South Staffordshire and for the moment
that is on a limited number of suitable previously developed sites.
When those run out, CPRE would expect developers to argue for
other sites along the motorway to be brought forward, competing
with urban sites in the Black Country. Birmingham City Council
has promoted two industrial sites, at Bassetts Pole and Peddimore,
in Birmingham's Green Belt alongside the M6 Toll. Although these
were rejected by the UDP Inspector, we have yet to see whether
the Council will continue to pursue them. We do not in the longer
term expect urban regeneration to flower because of the M6 Toll.
Rather we fear it will lead to increased pressure for Green Belt
land to be developed. Similarly, with the M6 Expressway, we fear
that the gap between the new motorway and the old will be particularly
sought after for infill car, and lorry-dependent development.
September 2004
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