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Introduction
A1.1 The consultation paper The Appraisal of Trunk Road Investment was published in August 1998 and was issued to about 550 organisations or individuals. Seventy three responses offered substantive comments on the proposals and Table A1.1 provides a categorisation of these respondents.
Table A1: Responses to consultation paper by category
A1.2 This annex provides an analysis of the main comments submitted and offers a response to them. This is presented under the 5 broad headings provided by the appraisal criteria but some general points are recorded at the end. Given the detail of some of the comments offered, it is not possible for a summary to capture all of the points raised but all of the responses have been considered carefully and adjustments made to the appraisal framework where appropriate.
Integration
A1.3 On integrated transport, the single issue which attracted most comment concerned the fact that the appraisal method (as noted in Chapter 7) had not been developed to the point where it could be used in a cross modal/multi modal fashion to allow roads investment to be considered alongside other transport initiatives. There was a view that this was inconsistent with an integrated transport strategy which was seeking to promote public transport with some respondents arguing that new trunk roads would make car use even more attractive than at present and potentially compete custom away from public transport.
A1.4 The Scottish Executive understands these concerns. Work is underway (in an exercise in which we are co-operating with the Department of the Environment, Transport and the Regions) to develop the methodology for multi modal appraisal. Based on this work, the Executive will produce generic guidance on multi-modal transport appraisal for use in a variety of circumstances. This guidance will promote good practice in transport appraisal and will cover multi-modal corridor studies and also area-based assessments. It will be appropriate both for the assessment of broad strategies and of more detailed plans and proposals and the guidance will contain advice on the level of assessment detail necessary in different circumstances. Future multi-modal corridor studies will be considerably aided by the availability of Version 3 of the Central Scotland Transport Model (CSTM3). This model, which covers a large part of Central Scotland, has been developed by the Scottish Office/Scottish Executive and has been specifically designed to inform multi modal studies.
A1.5 The Scottish Executive agrees that multi modal studies have an important role to play in assessing transport options in some circumstances. However, to remove the uncertainty created by this Review, it is important that some decisions on major trunk road schemes are taken now, in advance of the development of the multi modal methodology.
A1.6 A further set of comments related to integrated transport suggested that the method did not allow an assessment of the extent to which trunk road proposals matched local transportation strategies or complemented local roads planning. The Scottish Executive is now in a good position to take an overview of local priorities through the new system of local transport strategies. The road schemes to be included in the future road building programme all have the very strong support of the relevant local authorities and there is one particularly clear example in the approved list of complementarity between local and trunk roads. Local authorities will also be important partners in planned corridor studies.
A1.7 On integration with land use planning, there were some suggestions that a range of sub-criteria should be employed for this indicator eg the extent to which a scheme would assist efforts to regenerate vacant and derelict sites or to expand industrial areas thereby generating job opportunities. These issues are, indeed addressed by the method but under the local economic development heading.
A1.8 On integration with policies to promote social inclusion, some doubt was expressed that new trunk road building could make a major contribution here. The consultation paper did not suggest that trunk road building, alone, would have a significant impact but suggested that, in certain circumstances, it could be supportive of area regeneration initiatives. Some respondents suggested that local unemployment rates or statistics on local socio-economic conditions should be used to give priority to schemes serving socially excluded areas. In response to this, local unemployment rates have now been included in the appraisal method.
A1.9 Turning to local economic development, conflicting views were expressed under this heading. Some respondents argued that the roads programme should ensure that infrastructure did not impose a constraint on successful businesses/regions as expansion in these businesses/areas would benefit the Scottish economy. Others argued for investment to be focused on depressed areas (using unemployment rates as a measure as suggested under 'social exclusion'). A number of respondents suggested that the proposed method was biased in favour of heavily trafficked urban areas and that an indicator should be incorporated into the method to recognise the importance of a good strategic roads system to rural areas in general and peripheral areas in particular, in avoiding depopulation. There was also, however, a warning that improved links to economically depressed areas can benefit centralised distribution networks to the disadvantage of local suppliers, very much in line with the conclusions of the Standing Advisory Committee on Trunk Road Assessment (SACTRA) reported in Chapter 4. In line with the SACTRA advice, the appraisal method takes a cautious approach to the assessment of the local economic development benefits of new roads by looking for hard evidence that a new road will lead to development or will support a local regeneration or economic development strategy and this approach can be applied in both urban and rural areas, alongside the more general impacts assessed under the economy heading.
Economy
A1.10 This section of the appraisal method attracted a substantial volume of comments, some of them of a fairly technical level. One set of comments suggested that the use of projected traffic flows, often showing significant traffic growth, in the calculation of journey time savings and vehicle operating cost saving represented a perpetuation of the 'predict and provide' approach. The argument was that schemes with high traffic growth (some of which might be generated by the new road itself) would emerge strongly from the appraisal process as the unit time and operating costs figures would be factored up by a steadily increasing figure over the 30 year appraisal period. To reflect this comment, an important change has been introduced into the method. Those elements of the appraisal which depend on monetary assessments (ie journey time savings, vehicle operating costs savings and accident reduction benefits) are now calculated both on the basis of forecast traffic growth and on the basis of zero traffic growth. This allows the decision maker to see quickly the extent to which scheme benefits are dependent upon traffic growth.
A1.11 There was also a range of comments on the values associated with time savings accruing to different types of road users. These included:
A1.12 In general, the Scottish Executive considers that the broad approach taken to the valuation of time savings, which has been developed over a number of years and which has been endorsed in the recent SACTRA approach, is appropriate. The unit values assigned to different categories of road users are based on survey and research information. However, the Executive is interested in the extent to which the assessed benefits of new roads are dependent on substantial volumes of cars making commuting journeys as this is one segment of the transport system where there should be significant potential to encourage greater use of public transport. It is not possible simply to zero rate time savings accruing to car commuters nor to assess whether adequate public transport is available to them: the detailed information required to implement this is simply unavailable. However, to give some insight into this issue, a new measure has been devised to give some indication of the scale of commuter traffic using a scheme. This measures the ratio of peak hour to off-peak hour traffic flows. A relatively high score on this new measure would indicate that the road would be used by significant numbers of commuters and that their journey time savings would be having considerable weight in the calculations of benefits.
A1.13 Some respondents observed that inconsistencies could be introduced into the appraisal through the use of different traffic forecasting models for different schemes, noting that some schemes were in areas where local models had been developed while, in other cases, National Road Traffic Forecasts figures had to be applied. Similarly, different models are available to translate the forecasts into economic assessments. The approach we have employed does make use of different models but we are confident that there are sound reasons for this and that the appropriate approach has been used in each case.
A1.14 Finally under economy, there was a suggestion that the traffic statistics used in the assessment obscured seasonal pressures on significant tourist routes and that this should be taken into account in the method. In fact, the method accommodates this by considering the profile of traffic flows over a year.
Safety
A1.15 There were relatively few comments on this criterion and those offered were generally supportive of the proposed approach. One respondent suggested that the network-wide effects on safety of a new road scheme should be calculated. The argument was that, if a new scheme increased overall mileage travelled, this would produce some increase in accidents elsewhere on the network which should be offset against any savings on the improved route itself. In fact, the method already allows for this and so no change is required to accommodate this point.
Environmental impact
A1.16 This element of the appraisal method attracted relatively few comments. The main points made were:
Noise and vibration It was argued that the method should take into account noise impacts of people not in properties (eg walkers and cyclists). This factor has not been taken into the revised appraisal framework. Outdoor locations which are commonly used by people and which have a low ambient noise level (less than 50 dB(A)) are identified and included in full environmental assessment work. However, for the New Appraisal Methodology, it was considered that noise impact on property represented the vast majority of environmental noise effects and permitted good comparison between schemes and options.
Air quality One respondent asked why only nitrogen dioxide, PM10s and carbon dioxide were taken into account and suggested that other pollutants, such as NOx, should be considered. Again, this addition has not been incorporated into the method. While most of the oxides of nitrogen emissions from road traffic are in the form of Nitric Oxide, their impact must be evaluated in terms of their contribution to Nitrogen Dioxide levels in the air since this is the compound considered more environmentally damaging. It is also the subject of EU and national air quality standards.
Water quality Respondents noted that the appraisal method should: take into account that drainage and flood defences were critical components of road design; consider the effects of road works on silt inputs into rivers as this could be particularly damaging to fish during certain seasons; recognise that economically and socially important migratory fish populations could be affected severely by badly designed road crossings and culverts and that problems can be caused for the upstream migration of fish to their spawning grounds by bridge footings and culverts. These factors, as they relate to both design and construction, are taken into account in the method and are the subject of consultation with the Scottish Environment Protection Agency and fishing interests.
Ecology A number of respondents suggested that the method overlooked biodiversity and that there was a need for a separate sub criteria covering biodiversity, including impact on designated species, impact on local biodiversity and consistency with Biodiversity Action Plans. The detailed methodology allows for this.
Heritage There was a comment that the heritage indicator omitted archaeological sites including scheduled ancient monuments and that Gardens and Designated Landscapes should be taken into account in the method. The list of designations given in the consultation paper, however, claimed only to be illustrative rather than definitive. The suggested factors are, in fact, taken into account in the detailed method.
Agricultural land classification There was a suggestion that the appraisal should take into account the impact on all agricultural land, not just prime agricultural land. The method does, in fact, take into account non-prime land but, at some stages of the method, applies a lower threshold for prime land.
Other environmental factors Several respondents suggested that the appraisal framework should measure the level of primary aggregate demand that would arise from a scheme. This would mean that schemes that were able to use secondary or recycled materials would, other things being equal, be rated more highly than those, which relied upon 100% primary aggregates. There was also a suggestion that street lighting associated with new trunk roads caused environmental harm, especially in rural areas, and that the appraisal method should take this into account. On aggregate use, a measurement of primary aggregate consumption was included in an early pilot study aimed at developing the New Appraisal Methodology. While it is a useful measurement for assessing alternative options for an individual scheme and it is used in design to balance earthworks, minimise costs etc, it was not found to be particularly useful in terms of the Strategic Roads Review where new schemes of differing lengths are involved. It was, therefore, dropped from the final method. On street lighting, the extent to which significant additional light will be visible in the night landscape and the impact of lighting infrastructure are taken into account under the headings of Visual Impact and Landscape Character.
Accessibility
A1.17 This aspect of the framework attracted relatively few comments. The points raised included:
Pedestrians and cyclists It was suggested that countryside access paths should be added to the list of key community facilities and the impact of schemes on established Rights of Way and other footpaths, bridleways and cycleways should be taken into account, focusing on number of closures and lengths of diversions. These points are all, in fact, taken into account in the method.
Community severance One respondent commented that a high weight should be given to this factor to benefit bypasses of rural towns. Relatively low traffic volumes would mean that these schemes would not score highly on some other elements of the appraisal framework. The appraisal method does not use a weighting system. It lays out the appraisal information in a consistent way across schemes and it is for the decision maker to conclude how much weight should be attached to the various criteria.
Public transport It was suggested that a monetised appraisal in relation to public transport option costs (relating to a given road proposal), could form an integral and important part of the approach. This is being addressed in the development of the multi modal appraisal method.
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