Written evidence from Wharf Weston (TE 30)
1. SUMMARY
1.1 This submission addresses one of the questions
that the Select Committee for Transport have asked:
"Are the current methods for assessing proposed
transport schemes satisfactory?"
1.2 The submission argues that the DfT's approach
has serious defects, resulting in recommendations that are wasteful
of public funds. The key concerns are:
- Inappropriate forecasting methodology for long
term projections of demand where demand saturation is an increasing
risk.
- Inadequate account of uncertainty is taken which
requires flexibility for long term projects.
- Lack of a visible framework for generating and
assessing project "alternatives" to ensure objectivity
and value for money drives the choice of publicly funded projects.
- The unit values attributed to journey time savings
by DfT ignore key developments.
- A material monetary cost (property blight) is
excluded from DfT's assessment approach.
- The impact of competition is persistently ignored.
1.3 Some of these criticisms are not new, but
the DfT has failed to learn lessons of previous projects, despite
studies investigating past failures. The assessment prepared
by High Speed 2 Ltd (HS2 Ltd) and DfT for HS2, is a revealing
current case study and is used to illustrate the concerns.
2. INTRODUCTION
2.1 Appraisal should not be a process justifying
investments that are politically driven, ignoring or discarding
facts and options that are impediments to reaching the "right"
answer. The misallocation of public funds to unneeded and over-expensive
projects must be avoided. The arrangements must ensure that only
schemes that represent good value for money and are superior to
alternatives are selected.
2.2 The DfTs approach is in principle reasonable:
- It combines limited cost benefit analysis (for
impacts apt for expression in terms of money) with other criteria
that, while capable of objective assessment, are less readily
monetarised e.g. environmental impacts. The decision maker is
left to consider the particular combinations of value for money
and other factors in making a choice.
- The methodology and many of the assumptions or
parameters to be used for assessing transportation schemes are
published by DfT in webtag (guidance on the DfT web site). This
promotes consistency and the use of validated assumptions.
2.3 However there are weaknesses in DfT's approach
which may lead to poor decision making.
2.4 DfT continue to apply a "predict and
provide" approach to rail demand, despite its abandonment
for roads, and recent effective abandonment for air (with a policy
for no new runways for London airports). While not developed
in this submission, with increasing environmental concerns and
the creation of a portfolio responsibility for "non travel",
a reconsideration of this policy for rail seems overdue.
3. UNCERTAINTY
AND DEMAND
PROJECTIONS
3.1 DfT have been criticised for over-estimating
demand for major rail projects previously. The Select Committee
on Public Accounts criticised persistent over-estimation for CTRL.[62]
3.2 HS2 Ltd's demand estimates are high compared
to other reputable forecasts.
Table 2
LONG DISTANCE RAIL GROWTH FORECASTS
Source | Date
| Period | Increase
| Annual rate |
(DfT[63]
DfT[64]
| 2007 (July)
2007 (July) | 2006-2027
2006-2030
| 65%
73% | 2.4% (1.8% from 2017))
2.3%
|
Network Rail[65]
| 2010 (August) | 2008-2034 |
70% | 2.1% |
Prof J Dargay[66] for ITC
| 2010 (January) | 2005-2030 |
35% | 1.2% |
HS2 Ltd (Atkins) | 2010 (February)
| 2008-2033 | 133%[67]
| 3.4% |
Average (based on rates) |
| 2008-2033 | 75% | 2.3%
|
ITC is the Independent Transport Commission.
3.3 There are strong reasons to believe that all these forecasts
will prove overestimates, as they are founded on elasticities
with GDP (so that forecast demand increases more quickly than
GDP), but this relationship has been breaking down for domestic
travel. Clear evidence of saturation limiting recent growth to
that of the population has been emerging (see National Travel
Survey[68], Dr D Metz[69],
Bluespace Thinking[70].
The graph shows that since 1995 increases in wealth (real Gross
Value Added per capita) have not been matched by any increases
in domestic travel.
3.4 DfT correctly observed in their 2007 analysis[71]
that the relationship between transport demand and GDP has been
changing. But this is not generally recognised in demand forecasts.
Figure 1
TRAVELLING TIME, JOURNEY NUMBERS AND DISTANCES PER PERSON
(CF REAL GVA/CAPITA)[72]
3.5 Just projecting forward recent trends in rail demand
ignores the broader picture. There is no long term relationship
between GDP and long distance rail travel. From the 1950s
to the early 1990s, despite massive increases in GDP, rail usage
enjoyed no increase. It is likely that the recent increases are
a response to rail improvements, and modal switching in the context
of saturating overall demand, not a consequence of economic growth.
3.6 Inadequate account is taken of market maturity and saturation.
This, if uncorrected, will lead to a major misallocation of funds
when applied to assessing long term projects, as expenditures
will be made to accommodate demands that will not materialise.
3.7 At minimum there is risk that the high levels of growth
(267%) predicted by HS2 Ltd will not occur. This has important
consequences for the choice of options. HS2 is inflexible - a
new railway is built to Birmingham or it is not: it is all or
nothing. In contrast the rail and road alternatives for improvement
existing infrastructure are incremental, have short lead times
and can be implemented against the emerging trend in demand.
The alternatives are robust to shortfalls in demand, HS2 is not.
Any consideration of risk (as commended by the Treasury Green
Book and DfT's 2007 White Paper) favours adoption of the alternatives.
A methodology is needed to make this happen.
3.8 To illustrate, if we consider each of the estimates in
Table 2 equally likely, the expected NBR of HS2 becomes 1.35[73].
In contrast the NBR of the alternative schemes might increase,
as only the easier and cheaper options would need to be implemented.
3.9 The 2007 White Paper recognised the problems of long term
forecasts and the need for flexible solutions:
"Forecasts
have been wrong before, and any strategy that tried to build a
rigid investment programme based on fixed long-term forecasts
would inevitably be wrong again.
To overcome this challenge, the guiding principles
in this strategy are:
- To invest where there are challenges now, in
ways that offer the flexibility to cope with an uncertain future;
and
- To put in hand the right preparatory work so
that, as the future becomes clearer, the necessary investments
can be made at the right time."[74]
3.10 Unfortunately DfT's assessment methodology
does not reflect this advice.
4. ALTERNATIVES
AND THEIR
ASSESSMENT
4.1 DfT's processes neither generate an appropriate
range of alternatives, nor are they properly employed in option
selection. The effect of this deficiency is that DfT recommend
projects that are inferior to entirely feasible alternatives.
This is a persistent problem. The Foster Report[75],
observes inadequate assessment of alternatives to the Intercity
Express Programme:
"I am not convinced that all the credible alternatives
to Intercity Express Programme (IEP) have been identified, worked
up and assessed on an equal footing with it
..
The team's preliminary analysis suggests that these
alternatives could achieve better value for money than IEP, realising
a greater proportion of the currently desired IEP benefits with
reduced expenditure over the coming 15 to 20 years, and especially
during the next decade."
4.2 Similarly for HS2 there are weaknesses in
the option development and the selection process:
- The "do minimum" case is inadequate-
it cannot meet the projected demand and so when compared with
HS2 causes key benefits (on crowding) to be overestimated.
- The HS2 Ltd alternative is only for a new railway
(not an improved existing one) and the DfT developed alternatives
are not required to be used in the selection process.
- DfT alternatives do not include a least cost
option that meets the projected demand.
- The assessment rejects alternatives that have
better Net Benefit Ratios than HS2 (on the basis they do not provide
surplus capacity - yet they do meet the demand required).
- There is no assessment involving incremental
benefits over incremental costs of HS2 compared to the best alternative.
The HS2 Ltd "do minimum" reference case
4.3 For HS2, the assessment is done against a
"do minimum" reference case for rail and road network
development, which essentially only incorporates committed future
developments or those very likely to happen within the next 10
years. This means it will fail to meet the projected demand growth.
4.4 Appraising HS2 against this case will overestimate
key benefits, eg crowding. This is because, with predicted passenger
trips into London greatly outnumbering those originated from London[76],
an all day load factor of 81%[77]
is unachievable. Like commuter trains, those running against
the flow will be sparsely occupied - but unlike commuter trains,
passenger numbers cannot be expected to continue to grow if this
necessitates increasing levels of standing.
DfT developed alternatives
4.5 DfT had some credible alternatives developed
by Atkins, but they were not seriously considered as alternatives
to HS2, or used as a basis against which to assess HS2.
4.6 Importantly, no attempt was made to develop
the least cost means of meeting this demand. Generally this is
achieved by running longer trains. This option was developed
as "Rail Package 1", but was dismissed as it could not
accommodate all the projected demand without infrastructure amendments
that were claimed to be impractical. But it was also deliberately
not incorporated in other packages of changes[78],
although it would have made them both less expensive and less
disruptive means of meeting demand. Indeed it was not even costed.
4.7 To omit the least cost approach only makes
sense if there is no interest in developing the best value for
money option. A 65% increase in demand could be accommodated
by longer trains[79]
with no further infrastructure works beyond that scheduled for
2012 and part of the "do minimum" reference case (except
perhaps some limited work at Euston). Currently WCML Pendolinos
have four of their nine cars as first class. With the decline
in first class travel, it may be possible to reduce this to increase
overall capacity without loss in revenue. Consequently, over
half the projected demand (a 133% increase without HS2) could
be satisfied with no disruption to services at all. Typically
this means of satisfying additional demand is commercially justified,
and would not require DfT subsidy.
4.8 Rail Package 2 (RP2)[80]
allows projected demand to be met, and while HS2 Ltd predict that
it would generate less benefit than HS2, it has much lower costs,
and so has a better Net Benefit Ratio (NBR). But DfT do not use
RP2 as the comparison basis for HS2, to judge whether the additional
benefits of HS2 justify the additional costs of HS2. This
is not because it had been rejected on the basis of other criteria
in the assessment framework, as it has better sustainability.
4.9 RP2 is rejected primarily because it does
not provide as much additional capacity as HS2[81]
- despite the fact that on HS2 Ltd's demand estimates there is
not actually any need for this additional capacity. The creation
of un-necessary capacity hints at the misallocation of resources
rather than compelling justification. Other ways in which HS2
is held superior (journey time, reliability) are already incorporated
in the assessment of NBR for which RP2 is better than HS2.
4.10 In a climate of public spending cuts, to
reject a more cost effective solution on the basis it does not
provide as much excess capacity is profligate. As RP2 satisfied
the forecast demand, it seems common sense to use this rather
than an unrealistic "do minimum" case.
4.11 Had RP2 been used as the base against which
to assess HS2, this would have shown that HS2 could not be justified
in terms of its NBR. The table below summarises the costs and
benefits for HS2 and the best value for money alternatives. If
we assume that all the benefits of RP2 and half those of Road
Package 2 are benefits that HS2 would otherwise deliver, we can
see that HS2 has a net benefit ratio of 1.88 (instead of 2.7).
Table 1
HS2 AND ALTERNATIVES: NET BENEFIT RATIOS
| Against "do minimum" case (source: HS2 Ltd)
| Incremental case |
| HS2 | Rail Package 2
| Road Package 2 | HS2
|
Present value of benefits | 32.3
| 7.35 | 5.14 | 22.38
|
Present value of net cost | 11.9
| 2.03 | 1.40 | 11.9
|
Net Benefit Ratio | 2.7 |
3.63 | 3.66 | 1.88
|
4.12 In reality some combination of parts of Rail Packages
1 and 2 would be necessary to accommodate the demand growth projected
by HS2 Ltd before HS2 is completed.
4.13 DfT's process also fails to do justice to alternatives,
assuming a common start date for HS2 and the alternatives of when
HS2 could be complete. This fails to credit the alternatives with
a benefit stream that could predate that of HS2. This means that
the NBRs for the alternatives will be significantly understated
compared to an assessment that allows phased early implementation
of alternatives against emerging demand.
4.14 Under DfT's methodology there is no requirement to adopt
the best value for money solution, nor, when selecting a different
option, is there a requirement to justify this in terms of the
other criteria in the assessment framework (but not incorporated
in the cost benefit analysis).
5. VALUE OF
TIME SAVINGS
5.1 Time savings are the principle benefit used to justify
government subsidy in transport investments. However, the webtag
values fail to take account of some travelling time being useful
and are based on out-of-date data.
Usefulness of some travelling time
5.2 Webtag values for time savings derive from a resource
cost for business travel (the cost to the employer of the time)
and a willingness to pay basis for commuting and leisure travel.
5.3 Time spent travelling is not split between useful and
non-useful time. For both business and other travel, any saving
of time spent on trains is credited at the full value of
the entire time saving. This is inappropriate for long distance
rail journeys. It ignores that some of the time within rail journeys
is useful and productive. Mobile phones, laptops and mobile broadband
can make the train as productive as the office, and similarly
useful for commuters and leisure travellers.
5.4 However, DfT's webtag guidance disregards the usefulness
of this time - despite it being generally recognised[82]
that shortening long distance journeys may have little or no value
for saving productive time, including in work sponsored by DfT:
"Rail Business travellers in the UK are now using travel
time highly efficiently. Marginal reductions in travel time (10,
15, 20 minutes) are not guaranteed to lead to much extra productive
time at work, whether in the 'usual workplace' or elsewhere."
[83]
5.5 For business travel, if saving travelling time does not
reduce unproductive time, the time saving has no value to business.
For a project starting in 15 years time, it is not credible that
technology will not permit business travellers to be fully productive.
5.6 For leisure travellers and commuters, willingness to pay
is the basis for valuing time savings, which relates to the degree
of disutility of travelling time. Different values are identified
for different travel activities - ie waiting for transport is
costed at 2.5 times actually travelling, walking to access public
transport is valued at twice the value of travelling[84],
but there is no value specific to useful time on trains.
5.7 While leisure and commuting time on trains cannot be used
as flexibly as time at home or some other free time, it may be
used in an increasingly broad range of activities that must be
substantially eroding previous disutility[85].
5.8 HS2 Ltd estimate that time savings are worth more than
£13 billion[86]
(£23 billion[87]
including reliability) and this is mainly the value to business.
It seems unlikely that the savings are worth more than a small
fraction of this (perhaps a quarter). A £10 billion
reduction alone would reduce the NBR from 2.7 to 1.87. The road
and rail alternatives would not be similarly affected: time in
cars is likely to remain much less useful, and the rail package
benefit is mainly crowding reduction (worth £5 billion[88]
for HS2, and trains are less crowded under RP2 than HS2) and from
increasing service frequency (reducing waiting time that is not
useful time).
5.9 The cost of business time will increase with employee
costs, which are expected to rise due to continual improvements
in productivity. However, if the relevant travel time is productive,
increases in the unit value have no effect. For commuting and
leisure time, the money value of time can be expected to increase,
because the utility of money falls with increasing income. But
the disutility of time during long rail journeys is or will become
low, so that while the value of time savings generally can be
expected to increase in money value, these savings will be of
modest value.
5.10 Serious crowding may prevent travelling time from being
useful. This is a further reason for increasing capacity incrementally
in line with emerging demand and in advance of HS2's start data.
Out of date data
5.11 The value of business travel time on trains has not been
updated to reflect recent trends. Business travel by train is
increasing (despite a fall in total business travel), so that
while rail business travellers' average salary was previously
much higher than the all transport average, the additional business
travellers will have reduced the rail average.
5.12 By using 2002 information[89],
DfT are substantially overestimating business rail travellers'
salary levels. If the numbers of business travellers increase
by a further 360%[90]
to 2033 (as HS2 Ltd forecast), while population only grows by
16.6%[91], using 2002
data will give a substantial overestimate of value.
5.13 This illustrates how important it is that webtag parameters
are evidence based and properly reflect known trends.
6. IGNORES A
MATERIAL MONETARY
COST
6.1 DfT assessments deliberately leave out a social cost that
can be monetarised - the reduction in value of properties near
line of route[92]. This
cost is not included anywhere in DfT's assessment framework.
The costs of compensation are included, but these are relatively
small. Blight is not due to a redistributive effect (with losses
offset by gains elsewhere), but a result of degrading the local
environment.
6.2 Property blight data is not readily available because
currently the individual and not public purse meets the costs
of the blight that transport infrastructure projects generate.
It is, however, not difficult in principle to estimate the costs
of property blight, as relatively simple techniques can establish
divergences in property value trends for a locality. An unsuccessful
attempt was made in the 1990s, as reported by the Interdepartmental
Work Group on Blight[93]
However, modern positional software has been extensively used
to map dwellings and other buildings, making the identification
of the large numbers of properties needed to provide reliable
analysis easier. A study to quantify the effects of blight is
being planned for HS2[94].
6.3 Just as social benefits (eg time savings) are included
in the cost benefit assessment, the social cost of blight should
also be included - irrespective of who pays it.
7. COMPETITION
7.1 DfT assessments are persistently marred by a failure to
adequately consider competition. The Channel Tunnel failed to
take account the response of ferry companies. The CTRL failed
to addressed the impact of low-price air travel. The high speed
Kent commuter services have failed to recognise that passengers
would prefer the residual "classic" services with lower
fares and overall shorter journey times to commuters' places of
work.
7.2 HS2 Ltd assume-away the competition between HS2 and conventional
services:
" HS2's approach has effectively assumed a regulatory framework
that allows the joint (social) optimisation of both high speed
and classic rail services."[95]
7.3 Unless competition is suppressed, conventional long distance
services will compete with HS2. Competition will reduce both the
number of passenger on HS2 and overall revenues, which may force
HS2 to run with an operating subsidy. The natural use for surplus
long distance rail capacity is not to provide more local services
(that are already only provided at their current level due to
subsidy) but to undercut the high speed services on price (as
Chiltern Railways does to the WCML services for London-Birmingham).
7.4 If HS2 fails to deliver additional fares income because
of competition, this alone reduces the NBR to 1.20. The DfT assessment
process should involve proper consideration of competition.
September 2010
62
Select Committee on Public Accounts, Thirty eighth Report, 27
March 2006. Back
63
"Delivering a Sustainable Railway, Summary of Key Research
and Analysis, July 2007", DfT. Slide TPF9a, page 27. Back
64
"Delivering a Sustainable Railway", Cm 7176, Dft, July
2007, paragraph 6.6, page 60. Back
65
"Planning Ahead 2010", page 6, section 2.10, Network
Rail, ATOC and Rail Freight Operators Association, August 2010. Back
66
"The prospects for longer distance coach, rail, air and car
travel in Britain" J M Dargay, January 2010. Back
67
"Command Paper 7827", March 2010, section 5.38 page
91, growth without HS2 uplift. Back
68
National Travel Survey, 2009, Tables NTS0403 and NTS0404. Back
69
"Saturation of demand for daily travel", David Metz,
May 2010. published in "Transport Reviews". Back
70
"A review of high speed rail - HS2 proposals", Bluespace
Thinking Ltd, April 2010, section 4. Back
71
DfT op cit, slide EST1, page 3. Back
72
After Dr Metz based on NTS 2008 Table 2.1 with GDP trend added. Back
73
Reducing all benefits in the proportion to the reduction in forecast
passengers (assuming HS2 uplift equals background growth in demand,
as in HS2 Ltd analysis). Back
74
"Delivering a Sustainable Railway", Cm 7176, Dft, July
2007, page 9. Back
75
"A Review of the Intercity Express Programme", Sir Andrew
Foster, June 2010, page 22. Back
76
Webtag elasticities for rail travel on GVA for journeys to London
are 2 to 3 times those of journeys from London (Table 11.1, Tag
3.15.4), meaning that growth will be predominantly to London. Back
77
High Speed 2 Strategic Alternatives Study Strategic Outline Business
Case, Table 3.7, page 38. Back
78
"High Speed 2 Strategic Alternatives Study: Rail Interventions
Report"., page 34. Back
79
Lengthening 31 sets to 11-car from 9-car and having 4 new 11-car
sets are planned for operation in 2012. This increases capacity
by 32% (source Virgin Rail 31 July 2008). Lengthening the rest
of the fleet to 11-car creates a further increase in capacity
of 14%, and extending all to 12-car a further 19%, totalling 65%. Back
80
described in High Speed 2 "Strategic Alternatives" Study:
Rail Interventions Report, and the economic assessment is in "High
Speed 2 Strategic Alternatives Study: - Strategic outline business
case". Back
81
Command Paper 7827, Section 2.20 to 2.22. Back
82
See for example "Travel Time Use in the Information Age:
Report", Centre for Transport & Society, UWE, Bristol,
and Centre for Mobilities Research, Lancaster University, October
2007, or "The use of travel time by rail passengers in Great
Britain", Glenn Lyons, Juliet Jain and David Holley, January
2007. Back
83
"The Productive Use of Rail Travel Time and Value of Travel
Time Saving for Travellers in the course of Work" The Mott
MacDonald IWT Consortium, 2008. Back
84
Webtag 3.5.6D, paragraphs 1.2.19 and 1.2.20. Back
85
See "Values of Travel Time Savings in the UK", P J Mackie,
M Wardman et al, January 2002, page 50. Back
86
"High Speed 2 Demand Model Analysis" section 10.4.3. Back
87
From HS2 Ltd spreadsheet HS2_Day1cWiderImpacts_MidRange.xls, sheet
SummarybyArea, obtained under FOI10-039 by Dr J Savin, 4 June
2010. Back
88
"High Speed 2 Demand Model Analysis" section 10.4.3. Back
89
Tag Unit 3.5.6, Dft, March 2010. Back
90
24% of Virgin Rail's customers are travelling on business (source
"National Passenger Survey Wave 2,1 Autumn 2009, Virgin Trains"
Passenger Focus, page 21), which is forecast by HS2 Ltd to increase
to 30% with an overall demand that increases by 267%. Back
91 "
National Population projections 2008 base" ONS, 21 October
2009, Table 1. Back
92
HS2 Ltd gives this explanation of the assessment that they had
made in a meeting on 17 August 2010. Back
93
"Interdepartmental Working Group on Blight : Final Report",
December 1997. Back
94
by HS2 Action Alliance working with Councils, eg Buckinghamshire
County Council. Back
95
"Outline for Technical Annex", 091123-ACP technical
note, HS2 Ltd, page 19 "Remaining Issues", This document
records issues raised by the Analytical Challenge Panel. Back
|