Highways Inquiry Procedure Rules 1994 Doc Ref: OBJ/0125 2 For a local inquiry into: SUMMARY PROOF OF EVIDENCE Gerald Kells Transport Policy and Campaigns Advisor For Friends of the Earth Cymru / Cyfeillion y Ddaear Cymru (Friends of the Earth England, Wales and Northern Ireland) February 2017 The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor) Connecting Road) Scheme 201- The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East of Magor) Connecting Road) (Amendment) Scheme 201- The London to Fishguard Trunk Road (East of Magor to Castleton) Order 201- The M4 Motorway (West of Magor to East of Castleton) and the A48(M) Motorway (West of Castleton to St Mellons)(Variation of Various Schemes) Scheme 201- The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and The London to Fishguard Trunk Road (east of Magor to Castleton) (Side Roads) Order 201- The Welsh Ministers (The M4 Motorway (Junction 23 (East of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and the M48 Motorway (Junction 23 (East of Magor) Connecting Road) and the London to Fishguard Trunk Road (East of Magor to Castleton)) Compulsory Purchase Order 201- The M4 Motorway (Junction 23 (East Of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) (Supplementary) Scheme 201- The Welsh Ministers (The M4 Motorway (Junction 23 (East Of Magor) to West of Junction 29 (Castleton) and Connecting Roads) and The M48 Motorway (Junction 23 (East Of Magor) Connecting Road) and The London to Fishguard Trunk Road (East of Magor to Castleton)) Supplementary Compulsory Purchase Order 201-
1. Introduction 1.1 My name is Gerald Kells. I am an Independent Policy and Campaigns Advisor, with a background in transport, planning and environmental issues. 1.2 My evidence considers the need for the M4 Bypass and its impact on traffic and transport more widely. My conclusions have implications for noise, air quality and climate change. 1.3 To the best of my knowledge my evidence is true and I confirm that the opinions expressed are my true opinions. Page No 1
2. The Case 2.0 Summary 2.0.1 Friends of the Earth Cymru believe the case for the road is unproven because: 1. The traffic growth assumptions are unproven 2. Alternative options should be further considered 3. The road is likely to generate additional traffic 4. The benefits of the road are overstated and not equal 5. The benefits are outweighed by the disbenefits 6. Partly as a result the economic case is not fit for purpose 2.0.2 The conclusion we draw is that the road should not be proceeded with and that alternative more sustainable strategies should be pursued. Page No 2
2.1 The traffic growth assumptions are unproven 2.1.1 The case for the road relies heavily on the traffic forecasts but historic DfT traffic growth assumptions have consistently been wrong, usually too high. 2.1.2 Some lowering of growth has coincided with a recession. However, it is not clear that this is the only factor or that traffic will return to the assumed growth rate. This is further bought into question by a contrasting rise in rail patronage in Wales. 2.1.3 At a more local level traffic growth depends on the network being capable of accommodating that growth. Congestion on the M4 and surrounding roads will suppress demand. 2.1.4 And there is a question about how substantially traffic through the Brynglas Tunnel can grow, because of the physical capacity and because local traffic will avoid it at busy periods. 2.1.5 Elsewhere, although the predicted traffic growth leads to the motorway running closer to capacity, it is still, for the most part, avoiding stop-start conditions. The introduction of traffic management measures could manage the most congested periods. Page No 3
2.2 Alternative Options Should Be Considered Further 2.2.1 FoE Cymru has sets out a number of options which would address congestion on the M4 in a more benign way leading to a reduction of up to 22% in traffic on the M4. While this may include some overlap there could also be cumulative benefits increasing the potential for change. 2.2.2 The Welsh Government model suggests 48% of traffic on the M4 is local so there is considerable scope for reducing local traffic and benefiting sustainable transport in the area. 2.2.3 Options for traffic control on the motorway could be implemented and monitored. In particular a partial closure at Jn 26, linked to other demand management measures in an overall package, would allow the through traffic to flow more freely. 2.2.4 While these measures would not eliminate all congestion, taken together, they could bring the motorway largely within operating capacity. 2.2.5 School trips and holiday journeys could be addressed through a targeted approach of promoting and funding alternatives. Page No 4
2.3 The Road is Likely to Generate Traffic 2.3.1 The Welsh Government assume traffic growth on the motorway network is largely from reassignment but even this leads to more motorway traffic when the M4 and Relief Road are put together. 2.3.2 It also leads to additional traffic on roads either side of the core area, including the M4 to the West and the M48. This then impacts on other non-motorway routes. 2.3.4 We suspect traffic on the Severn Bridges may also rise significantly which would represent a disbenefit and reduce overall time-saving benefits. 2.3.5 More fundamentally the introduction of a major new road would have significant impacts on modal choice and on the generation of traffic, which would increase over time from trip reassignment, modal shift and lifestyle changes. 2.3.6 Given that the M4 is passing through a congested urban area one would expect released capacity to lead to traffic reassignment and overall traffic growth. 2.3.7 I do not concur with the Welsh Government that New roads increase capacity, however it is not capacity that affects the demand for travel, but the ease of travel provided. 2.3.8 Some effects might be seen fairly quickly, for example, changes in choices of leisure or retail destination, others, such as choices about where people live and work, would take longer to materialise, but one would expect to see these responses within a 20 year time span as people move houses and jobs, enter or leave the jobs market. 2.3.9 Removing or reducing the tolls on the Severn Bridge in conjunction with the opening of a new Motorway link would also influence the distance of journeys and other future life Page No 5
choices, effecting modal choice between road and rail in particular. This would have implications for pollution and climate change. 2.3.10 Some form of Stated Preference testing might elicit useful answers but the level of growth is hard to predict since people do not yet know what choices they will make or how transport provision will influence them. 2.3.11 Unlike the remedial measures FoE Cymru is suggesting, the proposed scheme would discourage modal shift by increasing the marginal benefits (and perceived benefits) of car use over public transport. 2.3.12 We would expect to see traffic rising to fill the gap, a phenomenon seen with other motorway schemes round urban areas such as the M6 Toll. Page No 6
2.4 The Benefits of the Scheme are Overstated and Unequal 2.4.1 The assumed benefits in terms of congestion delays are limited to the peak hours during the week. There is a 3 minute benefit from shortening the route but more dramatic advantages rely on the assumption that the new road will not lead to changes in behaviour. Even if those reductions occur the benefits will be enjoyed by a very small segment of drivers on the busiest days. 2.4.2 Such time benefits need to be offset with disbenefits accruing to all drivers from additional traffic on the wider network, including additional delays on local roads which access the existing M4 or at either end of the new road. 2.4.3 And, while such short predicted time savings may not be significant to individual users or transfer into actual economic benefits, they make up a great part of the assumed benefits because of the numbers involved. 2.4.4 There may be a perceived benefit in terms of journey reliability but our alternative approach should also achieve greater reliability and more constant flow on the M4. Unlike the new motorway, which benefits a limited group of people, our option benefits everyone. 2.4.5 Nor is the road needed for wider regeneration benefits or to access existing development sites. Page No 7
2.5 The benefits are outweighed by the disbenefits Gerald Kells for Friends of the Earth Cymru - OBJ/0125 2 2.5.1 There are significant disbenefits. 2.5.2 In particular, the scheme would introduce a new source of noise and air pollution to environmentally sensitive areas, while having marginal impacts on existing problems. 2.5.3 The loss of countryside and damage to nature sites, both directly and indirectly, would also be significant. 2.5.4 More broadly, we would expect an increase in overall traffic to fuel climate change and so undermine the Welsh Government s Well Being goals. Our alternative approach would help reduce CO2 levels and we argue is more in the spirit of the Welsh Planning Policy goal to effect behavioural change. Page No 8
2.6 Partly as a result the economic case is not fit for purpose Gerald Kells for Friends of the Earth Cymru - OBJ/0125 2 2.6.1 The economic case for the road is based almost entirely on time savings. We are not convinced of those benefits, or that they will transfer into real economic benefits. Moreover, if background traffic growth is exaggerated time savings would also be. On the other hand if traffic increases beyond 2037 because of the scheme returning congestion would create additional costs. 2.6.2 It is also not clear to me if maintenance costs are included in the COBA assessment. 2.6.3 More widely FoE Cymru set out a number of areas where costs may have been underestimated. We refer to the lack of inclusion of Inflation and VAT. There is an optimism bias of 51m in the assumed costs which seems relatively low for such a complex and expensive scheme. Page No 9
3. Conclusions 3.1 In conclusion, Friends of the Earth Cymru does not believe the proposed new motorway is justified. 3.2 Instead we argue for a package of measures to manage traffic on the M4, along with significant investment in public transport. This would not only reduce congestion but have other public benefits and act as a catalyst for developing a more sustainable local network in the future. 3.3. We do not believe the benefits of the scheme outweigh the disbenefits and we have concerns about the high costs associated with the scheme and the risks that they will increase. 3.4 But this is not just a transport scheme, it has significant impacts on the environment, including the loss of countryside, natural sites and in the longer term increased CO2 emissions. 3.5 The scheme should not, therefore, go ahead. Page No 10