APPENDIX 3
Memorandum submitted by Mr Stephen Plowden
This reply is confined to the Highways Agency.
It is very short because of the shortage of time and the pressure
of other work, but it can be amplified if the Committee wants.
Despite previous assurances, the Government
has decided on a massive revival of the road programme. Any relief
that this brings will be short-term only. The roads will soon
fill up again and we will be faced with the same problems as at
present on a larger scale.
The HA supports the programme by calculations
which purport to show very favourable benefit/cost ratios when
the schemes are compared with do-minimum alternatives. But the
supposed do-minimum alternatives are not do-minimum at all. They
would be better described as business-as-usual alternatives. They
presuppose the continuation of the policies which, combined with
the growth of personal incomes, produced the traffic growth experienced
in the past. In particular, they presuppose the continuation of
a major road programme. Without this extra capacity, the traffic
increases in the so-called do-minimum situation would not arise,
and neither, therefore, would the problems which the road programme
is supposed to solve.
Even if a road scheme or programme showed a
highly favourable benefit/cost ratio when compared with a genuine
do-minimum alternative, that would not be enough to justify it.
Two other conditions, closely related to each other, would also
have to be met. The investment would have to show a favourable
result compared with do-something-sensible alternatives, and it
would have to show a higher benefit/cost ratio than could be obtained
from other ways of spending a transport budget.
Transport activity takes place within a regulatory
and fiscal framework set by governments. If this framework is
unsatisfactory, then the resulting traffic flows cannot be assumed
to be desirable and it is irrational to use them, or projections
from them, as a basis of future plans. It has been apparent for
more than 40 years that the framework for road transport is unsatisfactory
and should be reformed.
There is a huge number of ways in which transport
in towns could be improved. Urban transport is not the responsibility
of the HA, but since the great majority of the journeys on the
trunk road network for which it is responsible have one or both
journey ends in towns, traffic restraint in towns would have a
significant effect on traffic levels on the HA's roads, which
it should take into account in its own planning.
Outside towns, there is an overwhelmingly strong
case for lower and better enforced speed limits. They would not
only reduce the casualties, fuel consumption, pollution and other
adverse impacts arising from any given volume of traffic, but
would reduce the amount of traffic as well—even a proper
enforcement of the existing speed limits would have that effect.
There is also a very strong case (set out in Keith Buchan's and
my 1995 report for the Civic Trust A New Framework for Freight
Transport) for a distance-based system of road pricing for
lorries. Provided that the system was kept simple, as it should
be, with the charges related only to the physical characteristics
of the vehicle and not to traffic conditions, there are no technical
obstacles to its immediate introduction. Among the effects would
be to reverse the tendency for lengths of haul to increase, to
encourage operators to delay consignments in order to achieve
higher load factors, even if that meant slightly reduced levels
of service, and to induce some switching from road to rail and
water. It is hard to say whether a system of distance-based road
pricing for cars would still be needed once lower speed limits
had been introduced and enforced, but it might be needed at least
on motorways. A pricing system confined to motorways would be
very easy to introduce, since it only requires a record of where
vehicles entered and left the motorway network. But road pricing
on motorways only makes sense given suitably low and properly
enforced speed limits on other roads to prevent diversion.
In the longer term, new forms of car ownership
(shared rather than individual) and new types of car (local rather
than all-distance) could have a huge effect in reducing the demand
for long-distance car travel. Both developments could be encouraged
by, perhaps even depend on, the adoption of suitable policies.
Another exciting possibility which advances in IT have created
is a new form of demand-responsive, long-distance public transport,
offering a door-to-door service. That too could have a profound
influence on traffic levels, and indeed on car ownership.
The idea of carbon rationing based on contract
and converge is finding increasing support. Its introduction would
have a profound effect on long-distance transport of all kinds.
Fuel prices are likely to rise in any case; the assumptions on
fuel prices built into the DfT's traffic forecasts are extremely
implausible.
The division of transport spending between the
HA and local authorities does not seem to be informed by economic
criteria. Management measures such as bus priorities and small-scale
road schemes designed to improve safety and the quality of life
commonly show very much higher benefit-cost ratios, even when
assessed in ways which understate their benefits, than major road
schemes, even when assessed in highly flattering ways. The economic
evaluation of schemes to help cyclists and pedestrians has been
disgracefully neglected, but there are strong reasons to think
that they too would show very high benefit/cost ratios. There
is much more scope for this kind of investment by local authorities
than by the HA, which suggests that there should be a large transfer
of funds from the HA to local authorities.
The HA has described its task as to invest and
manage. The order is wrong. Until the existing road network is
properly managed, no case for increasing it, other than to serve
new development, or to bring environmental relief which cannot
be brought in other ways, and which is large enough to outweigh
the damage done by the road itself and the traffic it will carry,
can be made out. This obvious point was made by a HoC committee
as long ago as 1973 with respect to urban roads. It might have
been premature in 1973 to have applied the same principle to the
inter-urban road programme, but it is high time to do so now.
The HA's attitude reflects its own vested interest, not the public
interest.
Of course, the DfT and Ministers, rather than
the HA, bear the main responsibility for mistaken policies. However,
the HA is responsible for estimating the costs of its own road
schemes, and has completely failed in that responsibility. In
1995, in reply to a question from Joan Walley MP, the HA produced
a list of all the schemes for which it was possible to compare
the cost estimated at the time the scheme was accepted into the
road programme with the outturn cost (see press release issued
by Joan Walley on 12 October 1995) . There were 78 such schemes,
every one of which had overrun, and the average overrun was 38%
of the estimated cost. At that time, the HA must have had available
a huge amount of information about the cost of building roads.
Had it made proper use of this information in its cost estimates,
these errors could not have occurred. There might still have been
substantial discrepancies between the estimates and outturns in
particular cases, but they would not all have been in the same
direction, nor would the average have been out by so much. This
experience does not seem to have chastened the HA in any way,
nor led it to reform its ways. I have seen a table prepared by
Roadblock from the answer given on 14 July 2005 to a PQ from Colin
Challen MP, which shows that massive overruns still continue.
I understand that this information is being sent to the Committee.
The only roads to be built now should be those
that would still be required if the fiscal and regulatory framework
had been reformed and other measures affecting demand for motorised
road transport were in place. Since it is very hard to estimate
the effect of these reforms, it will often be difficult to identify
the schemes which should still be built if they were introduced.
The rule in doubtful cases should be not to build, since if it
should later transpire that the road was necessary after all,
it can be built then, whereas the decision to build or widen a
road, once effected, is irreversible.
The HA and the road programme are out of control.
The DfT and Ministers could bring them under control but are not
going to. The Treasury could as well, but it too lacks the will.
(It may also lack the knowledge, but if so, its ignorance is willful.
I know from years of trying that the Treasury is more interested
in peaceful relations with the DfT than in ensuring the wise use
of public money. I gave a very restrained account of the early
years of these contacts in a letter to the Independent
published on 28 November 1989, which is reproduced below.) The
National Audit Office can, and I hope will, get to grips with
the cost overruns on road schemes, but it is not allowed to question
policy, as distinct from its implementation, which makes it difficult
or impossible for it to engage with the wider points mentioned
above. That leaves only Parliament. If Parliament fails to act,
that would leave the law-abiding objector with nowhere to go.
People would, and in those circumstances should, turn to civil
disobedience.
In addition to the letter to the Independent
mentioned above, I am attaching two recent letters to Local
Transport Today. They amplify the points made above and draw
attention to two other startling features of current roadbuilding
plans. The plans are based on increases in traffic which have
been officially described as unacceptable, and for some schemes
the justification assumes that methods of road pricing will be
in place which it is known will not be in place.
5 January 2006
The Editor
The Independent
24 November 1989
Sir,
Lord Croham (letter, 22 November) suggests that
complaints about the Treasury come from people who unreasonably
blame it for the frustration of their pet schemes. A better ground
for complaint is that the Treasury has shown itself to be an ineffectual
watchdog of public expenditure.
The Department of Transport's method of appraising
its road schemes, known as COBA, has several very serious defects,
all of which tend to exaggerate the case for road building. Three
years ago, I tried to interest the Treasury in a critique of COBA.
Initially, this idea was warmly received. I was told that the
Treasury had been worried about COBA for some time; of course
the Department of Transport would have to be told, but it would
be made clear to them that they could not stop the study, short
of escalating the matter to a very high level. But this initial
enthusiasm soon vanished under pressure from the Department of
Transport; some weeks later, the same official told me that if
the Department of Transport, as the department principally concerned,
was not interested, there was little the Treasury could do.
Finally, as the easiest way out of the situation,
the Treasury commissioned a study on just one of the aspects that
I had raised. Some weeks after I submitted the report, I received
a letter from the Treasury containing its "considered views".
Some important points were accepted, and I was told that they
would be pursued, although no changes have since been made in
the method. When I queried another comment with the Treasury they
could not defend it; it transpired that they had simply relayed
a point from the Department of Transport.
A little later I wrote to the Financial Secretary
about an expensive road scheme in Manchester which had been accepted
on the basis of a COBA appraisal, even though COBA was not designed
for use in large towns, but would not have passed a more adequate
test. Some correspondence with the Treasury's letter writing unit
followed, resulting in the claim that "on the whole we are
satisfied that COBA, though by no means perfect, provides a reasonably
good approximation of the costs and benefits associated with new
road schemes". This claim was made even though the Treasury
had refused to look at all but one of the objections to COBA,
the officials were working from out of date manuals, and the senior
official concerned, who was also the warmest in COBA's defence,
and the most determined to belittle my points, was unfamiliar
with the most basic technical term in traffic forecasting.
In May of this year a huge increase in the road
programme was announced with virtually no attempt at a public
justification. It will not have been scrutinised behind the scenes
either.
Stephen Plowden
The first paragraph of the following letter was
published by Local Transport Today on 17 March 2005
with the heading M25 plans will not lock in the benefits of added
capacity.
The Editor
Local Transport Today
14 March 2005
The proposals to widen the M25 ("Highways
Agency takes up the challenge to `lock in' the benefits of M25
capacity enhancements", LTT 3 Mar) are a good example
of the illogical and harmful nature of the revived road programme.
The Highways Agency estimates that the total cost of the five
schemes will be £1.6 billion and claims that they will bring
benefits of £6.25 billion ("Infrastructure update",
LTT 26 Aug). However, its calculation of the benefits assumed
that road pricing would be in place to control traffic generation
and lock in the benefits. In fact, road pricing is not even one
of the locking-in measures that the HA is now examining, and it
is committed to these schemes even if, as is virtually certain,
it cannot find any suitable measures. If the widening does take
place, the enlarged M25 will soon fill up with traffic and we
will be faced with the same problems as at present on a larger
scale.
Although there must be some sensible schemes
in the rest of the £8.6 billion road programme, the net effect
of the whole programme will be similar. Large amounts of traffic
will have been generated and a bad situation will have been made
worse.
It has been apparent for decades that we need
a wholesale reform of the rules for using the roads. Lower and
better-enforced speed limits and selective road pricing are only
the most obvious of the required reforms. We also need improvements
in the facilities for travel by modes other than car both for
short and long journeys, a reversal of the planning policies that
have encouraged the trend towards larger and fewer shops and other
facilities, and support for the trend for more people to work
from home, not necessarily all the time but for a day or two a
week, and for teleconferencing.
It is impossible to predict exactly what the
effect of these policies would be, but it would be major. The
only sensible course is to implement them and to see what case,
if any, for increasing road capacity can then be made. The only
roads to be built in the meantime should be local roads serving
new development, and a few other minor schemes that could be justified
even if traffic levels were reduced. When you're in a hole, stop
digging.
Stephen Plowden
An edited version of this letter, with the
last two sentences of the first paragraph and the whole of the
second paragraph omitted, was published in LTT of 14 April
2005
The Editor
Local Transport Today
4 April 2005
The DfT's long-term traffic forecasts, referred
to in Andrew Forster's article "Tumbling motoring costs could
provide the spur for accelerated traffic growth" (LTT
31 March), are the major input to the Highways Agency's appraisal
of its road programme. The Highways Agency claims that this programme,
costing £8.6 billion will bring benefits worth £27.7
billion ("Infrastructure update", LTT 26 August).
But it is clear from the way that the forecasts are prepared that
this claim is not justified.
Appraisals of roadbuilding proposals are usually
based on a comparison with a do-nothing or do-minimum option,
but that is not a sufficient test. A comparison with a do-something-sensible
option is also required. There is a crying need to reform the
rules for the use of the roads, and there is plenty of opportunity
to do so over the 30-year (now 60-year) period used to assess
major schemes. The road programme should be compared with the
situation that would obtain on the existing roads if a package
of reforms, of which the most important are probably lower and
better enforced speed limits, was implemented. But the DfT's forecasts
assume that the existing rules will continue unreformed.
The DfT's forecasts do not even provide the
basis for a test comparing the road programme with a do-minimum
alternative. The forecasts for 2025 assume that by then the Highways
Agency will have added 4,032 lane kilometres to the network it
managed in 2000, and that £5.3 billion will have been spent
on "improving" local roads. Without this extra capacity,
the forecast that traffic will increase by 55% on the HA's roads,
and by 40% on the road network as a whole, could not be realised.
In paragraph 3.21 of The Future of Transport,
published last July, the DfT said that an increase in traffic
of 40% would be unacceptable. Nevertheless, it is now, in effect,
planning to bring that increase about.
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