The Case against a Grey Bypass for Arundel
The case against Grey, and similarly against any long new dual carriageway through the countryside and villages, is many-faceted.
Over the coming months we will share communications on each of these aspects as papers or blogs. These will be found as links expanding the summary points below. Please come back and check this page from time to time to see what's new.
In summary, these are:
Government, the Department for Transport and Highways England are not following the science.
They are failing to act on empirical science, ie evidence collected about whether practices work or don’t. Highways Agency studies a decade ago in 2009, as the Campaign for Better Transport reports, already showed Bypasses typically don’t work. They don't reduce traffic. Instead, they encourage more people to drive and often just move the problem a few miles away.
National and international traffic experts have stated the case for the cancellation of the Arundel Bypass. In terms of carbon emissions, transport is the worst-performing sector of the UK economy. Whereas emissions in all other sectors have fallen, emissions from transport are still going up. The Department for Transport has stated that the forecast rate of carbon reduction from transport is much slower than is needed.
The House of Commons Science & Technology Select Committee, in a report published in July 2019, Clean Growth: Technologies for meeting the UK’s emissions reduction targets, concluded (para 131):
The transport sector is now the largest-emitting sector of the UK economy. ... There are significant emissions associated with the manufacture of vehicles. In the long-term, widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation. The Government should not aim to achieve emissions reductions simply by replacing existing vehicles with lower-emissions versions.
Alongside the Government’s existing targets and policies, it must develop a strategy to stimulate a low-emissions transport system, with the metrics and targets to match. This should aim to reduce the number of vehicles required, for example by: promoting and improving public transport; reducing its cost relative to private transport; encouraging vehicle usership in place of ownership; and encouraging and supporting increased levels of walking and cycling.
The government is following the science to the extent of bringing forward the banning of conventional higher-emissions vehicles. But it is not following its own Science & Technology Select Committee's recommendations in permitting Highways England to plan and invest in increased numbers of vehicles, rather than managing for reduction and investing in alternative systems.
(Thanks to Mair Perkins for the illustration, licensed for reuse under Creative Commons Licence)
-In terms of carbon emissions, transport is the worst-performing sector of the economy. Whereas emissions in all other sectors have fallen, emissions from transport are still going up.
-The Department for Transport is developing a decarbonisation plan for the transport sector, and has stated that the forecast rate of carbon reduction from transport is much slower than is needed.
-The Climate Change Act 2008 now commits the UK to reduce net carbon emissions to zero by 2050, and to five-yearly carbon budgets between now and then. The Committee on Climate Change (CCC) has already shown that transport is not even on track to comply with existing carbon budgets (set when the target was to reduce emissions by 80% by 2050), let alone net-zero ones.
-However, in terms of impact on the climate, what matters is not so much the end date, as the total amount of CO2 that is emitted between now and then. Under the Paris Climate Agreement, the UK is committed to restricting the increase in global average temperatures to well below 2°C and preferably below 1.5°C. For this, cutting carbon emissions over the next decade will be crucial. (p. 3).
We believe that DfT should set a binding Paris-compliant carbon budget for all parts of the transport sector, including Highways England which is responsible for the SRN. By analogy with carbon budgets proposed for local authorities by the Tyndall Centre for Climate Change, we estimate that a fair, Paris-compliant budget for the SRN [Strategic Road Network] between now and 2032 is about 214 MtCO2. (p. 3)
RIS2 [the Government’s new roads programme] will make carbon emissions from the SRN go up, by about 20 MtCO2, during a period when we need to make them go down, by about 167 MtCO2. …This suggests that RIS2 is incompatible with our legal obligation to cut carbon emissions in line with the Paris Climate Agreement, the Climate Change Act budgets and the emerging principles for the Departement for Transport’s decarbonisation plan. We therefore believe that it should be cancelled. DfT has not published any assessment of the cumulative carbon impact of RIS2. (p. 4)
The COVID-19 pandemic has wrought enormous behaviour change, with both work and non-work journeys replaced by a variety of video conferencing solutions and greater use of local facilities. When rebuilding the economy, it is vital that investment supports behavioural shifts that will also help to achieve reductions in carbon emissions. Cancelling RIS2 would free up investment for this. (p. 5)
From Emeritus Professor of Transport Policy Phil Goodwin, Centre for Transport and Society, University of the West of England, Bristol, and University College London, on Highways England's failed carbon impact assessment approach:
Article in TransportXtra 7.8.2020 explains how Highways England's road scheme appraisal system is so designed as to automatically treat as negligible the carbon impact of each and every scheme it might propose
From the Victoria Transport Policy Institute's Executive Director Todd Litmann, on 'generated' or 'induced' traffic:
Traffic congestion tends to maintain equilibrium; traffic volumes increase to the point that congestion delays discourage additional peak-period trips. If road capacity increases, peak-period trips also increase until congestion again limits further traffic growth. The additional travel is called “generated traffic.” Generated traffic consists of diverted traffic (trips shifted in time, route and destination), and induced vehicle travel (shifts from other modes, longer trips and new vehicle trips). Research indicates that generated traffic often fills a significant portion of capacity added to congested urban road.
Generated traffic has three implications for transport planning. First, it reduces the congestion reduction benefits of road capacity expansion. Second, it increases many external costs. Third, it provides relatively small user benefits because it consists of vehicle travel that consumers are most willing to forego when their costs increase. It is important to account for these factors in analysis. This paper defines types of generated traffic, discusses generated traffic impacts, recommends ways to incorporate generated traffic into evaluation, and describes alternatives to roadway capacity expansion.
The above is the Abstract of a longer July 2020 article by Todd Litman, Generated Traffic and Induced Travel: Implications for Transport Planning. A version of this paper was published in the ITE Journal, Vol. 71, No. 4, Institute of Transportation Engineers (www.ite.org), April 2001, pp. 38-47.
In October 2020, Todd Litmann issued the following statement: "The A27 Arundel Bypass is an example of a costly project that contradicts virtually all other planning goals, including goals to encourage resource-efficient travel, preserve greenspace, and improve mobility options for non-drivers. I therefore recommend that it be canceled, and the resources be invested instead in more efficient and equitable travel options." See further in Victoria Transport Policy Institute: "A27 Arundel Bypass - Reasons to Cancel", 2.11.2020
From Professor John Whitelegg, Visiting Professor of Sustainable Transport at Liverpool John Moores University, Oct 2020:
Sir David Attenborough has said: “It may sound frightening, but the scientific evidence is that if we have not taken dramatic action within the next decade, we could face irreversible damage to the natural world and the collapse of our societies.” Taking ‘dramatic action’ means no more new road building or bypasses and serious attention to the rich menu of non-road-building alternatives that are zero carbon, lower cost than roads and do not damage nature, countryside or biodiversity.
Those who promote schemes like the A27 Arundel bypass are promoting a failed intervention that will not achieve its objectives, a costly and highly wasteful use of public money and an option that will make the climate emergency worse. The A27 Arundel Bypass must be cancelled immediately and the funding retained in that geographical area for world-best walking, cycling, public transport, car-free streets and towns, shared vehicles and sustainable freight transport.
See further Professor John Whitelegg: "The Arundel Bypass must be cancelled. Professor Whitelegg also outlines what a more effective approach than just banning petrol and diesel vehicles' sale might look like in this 17.11.2020 piece written for the Foundation for Integrated Transport.
This issue of the journal has a collection of commissioned articles on the shape of transport and mobility after Covid-19. The 6 authors were asked to produce ‘think pieces’ looking ahead to what the transport world could and should look like after the extra-ordinary coronavirus experience has subsided. These “think pieces” have also been submitted to the UK Department of Transport to inform its work on ‘Decarbonising Transport’ and ‘The Future of Transport Regulatory Review’. All the authors have a wealth of experience to bring to bear on the future of transport and mobility and the degree to which the virus crisis has shifted the prevailing deviant paradigm.
So why does government appear to be acting as if going over to electric cars means they can build major new roads indefinitely?
From House of Commons Science and Technology Committee 20.7.19 Report: "Clean Growth: Technologies for meeting the UK’s emissions reduction targets", para 131: Para 131 is quoted in the introduction to this section.
One objective which we (and the Committee) feel is critical, is highlighted: a reduction in ‘the number of vehicles required'.
Although electrification is an essential part of the long-term transition to zero emissions transport, it is not a panacea. Electric vehicles (EVs) today are lower emissions per mile driven than a petrol or diesel equivalent when the emissions from the fuel or electricity are counted (well to wheel).
However, across the whole lifecycle, from construction to decommissioning, an EV today emits broadly the same level of CO2 as an Internal Combustion Engine (ICE). As production processes shift to using renewable energy the whole life CO2 benefits of EVs will grow, but today there is no such thing as a ‘zero emissions vehicle’.
The realities of price, vehicle availability and consumer choices also influence the rate at which EVs can be brought into the fleet. Even with an accelerated phase-out date of 2032 or 2035 for ICEs, the emissions from the car fleet will still be well above local authorities’ necessary carbon reduction trajectories.
There is no decarbonisation strategy which can rely solely on changing the vehicles that people drive, so the uptake of EVs and how this is managed needs to be treated carefully, alongside efforts to encourage mode shift away from the car and to reduce the overall demand for travel.
An extended FoE paper brings together data from transport and climate science studies which show that even a very rapid switch to electric cars will not reduce greenhouse gas emissions enough, but that in addition, traffic levels need to be reduced by at least 20%. By contrast Highways England, in seeking to justify approaching half a billion pounds investment in the Arundel Bypass Grey Route, are choosing to predict and provide a wholly unsustainable traffic increase.
A 2018 European detailed study showed an average electric vehicle's emissions are 75% of those of an average petrol car (across lifetime of vehicle) across the EU - varying according to power supply mix. Over this hangs the carbon cost of continuing road expansion, and extra fossil fuelled power from increased demand on power network. Both road-building and car numbers must reduce to address the climate emergency.
Promises of more big roads are often made to raise voter confidence in economic prospects, but they are not what we need to rebuild today's economy or that of the future.
The economy is changing already
PM Boris Johnson spoke in September 2020 of the need to steer a "build back greener recovery" post-Covid; and in July 2020 Transport Secretary Grant Schapps also spoke of "green recovery" and announced "a 'revolution' in sustainable, climate-friendly transport". But their Department of Transport and its wholly-owned road-building company Highways England are still intent on delivering the opposite.
All over the world people are waking up to the need to take positive steps to accommodate and facilitate a new economic reality. "We're recovering, but to a different economy," said Federal Reserve chairman Jerome Powell on 12.11.20 during a virtual panel discussion at the European Central Bank's Forum on Central Banking. The pandemic has accelerated existing trends in the economy and society, including the increasing use of technology, telework and automation, he said. This will have lasting effects on how people live and work - and travel. As the climate science insists it must, to secure any viable future economy.
Value for money
Spending up to half a billion on the Grey Route across Arundel is a poor value for money investment by any standard. The reasons why this is so are set out in the paper on this link:
To summarize some key points:
Value for Money. The case supporting value for money is built by comparing forecasts of monetised benefits with forecasts of construction and other monetised costs; in this way a benefit to cost ratio (BCR) is produced. The BCR is overlain by a judgement to account for things that cannot be monetised, such as expected effects, risks and uncertainty so as to assess the net increase in overall public value. This outcome is labelled Value for Money. Highways England produces both the BCR and the value for money judgement, sometimes using its own unpublished guidance and otherwise using Department for Transport guidance. Both the costs and the benefits for the Grey option are open to question such that its BCR and thus its Value for Money are in serious doubt. Those who have been pressing Highways England for over a year on the issues involved have received no cogent responses, itself indicative of considerable problems. We now estimate that the BCR is very roughly one-third of the publicised figure, an outcome that would normally place it well outside the government guidelines for acceptance.
Costs. Grey starts off as the most expensive route option and the largest excluded cost issue we are aware of is the decision on the use of a viaduct in place of an embankment to cross the Arun floodplain. The additional cost could be in the region of £300 million, on top of Grey’s current upper cost estimate of £455 million. At the other end of the scale of currently unincluded costs is the compensation due in Walberton for the complete removal of the existing site access to an estate of 175 houses now under construction.
Benefits. There are several large benefits issues still outstanding after a year. One is the effect of the assumption in Highways England’s traffic model that both the Lyminster bypass and the 2017 Worthing Lancing scheme are already built. This assumption follows recent guidance by Highways England to itself, which overrides the fact that the Worthing Lancing scheme is not to be built. Other benefit issues outstanding are technical but clearly suggest that Highways England’s traffic model assumptions lead it significantly to overstate future traffic volumes for the Grey option; this is important because "benefits" are overwhelmingly dependent on these volumes.
Were the environmental and social costs to be monetized, the misspend scandal would be even more extreme.
Department for Transport VfM Indicator (https://www.gov.uk/government/publications/percentage-of-dft-s-appraised-project-spending-that-is-assessed-as-good-or-very-good-value-for-money)
Department for Transport Guidelines (https://www.gov.uk/guidance/transport-analysis-guidance-tag.)
Department for Transport VfM Framework https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/918479/value-for-money-framework.pdf).
This case is conclusively if not exhaustively set out in the responses of the Defra agencies, Natural England and Historic England, to the 2019 consultation. The whole area is 'extraordinary', according to Natural England. Severance and impacts by the Grey Route would be environmentally disastrous and impossible to adequately mitigate. Serious environmental damage includes direct and indirect, short and long term ecological, heritage, hydrological, landscape and climate impacts.
The Myth of Mitigation
Within the Mid Arun Valley, the natural habitats and landscape as at present managed, support rich biodiversity, including thriving bird communities, a large and stable Dormouse population, thousands of breeding toads, key reptile sites, a nationally important bat assemblage and several important invertebrate communities These communities have persisted for millennia, despite a changing world.
Mitigation and compensation (that may be maintained for 25 years and monitored for fewer years) are unlikely to result in net biodiversity gains for such a rich and largely interdependent assemblage.
The current Scheme is being proposed against a backdrop of continual species decline in the face of yet another factor - climate change - resulting in a layer of unpredictability (i.e. ponds drying, cold snaps, localised flooding, lack of availability of prey source at critical times etc.)
The numerous impacts should be used as a way to navigate to the least damaging Option for Arundel and its rich assemblage of wildlife, which, evaluating the operational and residual effects is the Cyan or Beige Option.
[Note: the ACT quote above was commenting within the framework of the options offered; elsewhere ACT pointed out the Arundel Alternative, not offered by Highways England, is less damaging than Cyan or Beige.]
"Resilience and functionality of this extraordinary ecosystem" requires an online, not offline solution
We have advised Highways England that the impacts on wildlife and landscape are considerably greater with offline schemes. This is because offline schemes include both habitat loss and the permanent severance of remaining habitats affecting the resilience and functionality of this extraordinary ecosystem, and diminishing its ability to adapt to the effects of climate change. Furthermore our landscape advice remains that, the online schemes offer the potential for the least damaging scheme in terms of landscape character and visual amenity.
We have advised that in order to ensure a robust assessment of the impacts of severance the critical factor is to assess each option in an integrated way at a landscape scale. We have provided Highways England with a joint letter from Natural England, the South Downs National Park, Environment Agency and the Forestry commission presenting our united concerns, of which severance is an overarching theme. (page 1)
It is with concern therefore that we advise that the impact of severance has not yet been adequately assessed in the brochure or accompanying supporting evidence. Without a clear and balanced assessment which highlights this major impact, a judgement of the true scale of environmental impact presented by offline options cannot be made.
This letter highlights our considerable concerns regarding landscape and the impacts that the options have for biodiversity via loss and severance of habitats. We will reiterate our advice that this area is extraordinary, necessitating a bespoke approach to assessment across the suite of priority and irreplaceable habitats and the associated array of species that this nationally important environment contains. (page 2)
The South Downs National Park
As presented, all the [6 Highways England] routes, including the route outside the SDNP (grey route), impact negatively on the SDNP and its setting. To varying degrees all would cause significant harm to the biodiversity, cultural heritage, access, recreation potential and landscape character of the SDNP
SDNPA urge Highways England to address, as a priority, the shared concerns raised in the Single Voice letter sent by the DEFRA family, which i) highlighted the issues of an embankment as compared with a viaduct – which conflict with HE assessments – ii) the issue of connectivity and also iii) the issue of environmental net gain.
-…the mainly on-line Cyan and Beige routes, though potentially the least damaging for most of the Special Qualities of the SDNP, would have very significant unmitigated/compensated impacts on Ancient Semi Natural Woodland, and the townscape. By contrast the Crimson, Magenta, Amber and Grey routes ... still have significant impacts on the SDNP special qualities and would have major impacts on its setting.
Flood risk and hydrological management are a big issue. The Grey route has been costed with an embankment forming a barrier across the Arun valley flood plain.
This report identifies Flood Risk (“we are still concerned that the impact the proposed options may have on tidal flood risk has not yet been properly considered.” page 2), Biodiversity (“major adverse risks to nature conservation from all six options presented,” page 4), Groundwater Protection (page 5-6), and Drainage (page 6).
…any option for the bypass should be considered in an integrated way at a landscape scale to ensure that the complex and interconnected ecosystem that is set within wider hydrological catchment are fully understood and reflected in design choices. (page 7)
Think globally, act locally
From Simon Rose, Arundel SCATE (linked to South Coast Alliance on Transport and the Environment), October 2020:
We know we have to tackle climate change, yet Highways England options would significantly increase carbon emissions. The UK Climate Assembly recommended we need to cut traffic to cut carbon emissions, and academic research also tells us we must cut traffic, even if we switch to electric vehicles in the most optimistic timescale. So why is Highways England planning for more traffic?
This area, described by Natural England as ‘extraordinary’, includes ancient hedgerows, rare wetland, old woodland and ancient trees which are important corridors for protected species such as dormice and rare bats. Further to the east, the road would carve up fields, marsh, river bank and reed beds, rich in birdlife, small mammals and butterflies. The riverbank where the road would cross, is a popular walk for Arundel people, dogs, birdwatchers and visitors. All potentially lost to acres of tarmac raised on a bank across the Arun Valley.
The historic environment
"The noise, townscape and historic environment impacts of Option 5BV1 (Grey) have been underestimated because the environmental assessment has not taken account of impacts on the Avisford Grange development at Walberton or some impacts on the historic environment. The latter includes: (a) the severance of Binsted as a historical settlement into three parts, isolating its most ancient and historically important building, St Mary’s Church; and (b) severance of the view along the Binsted Rife valley by crossing this very visible feature of the local historical landscape in an open area.” (p294)
Direct impacts of the overbridge ramps on listed buildings Meadow Lodge and Morleys Croft are also severe.
‘Binsted is a wonderful, mystical place, a little gem held in the past, vitally important in the life story of Laurie Lee. Here is an extraordinary example of a parish unblemished by the modern world, with an exquisite little Norman church whose timeless quietness and beauty must surely be left undisturbed in the 21st century.’
"The new dual carriageway will cross the Binsted Rife Valley on a viaduct a few yards from St Mary’s Church, Binsted, BN18 0LL, with traffic passing at the height of the top of the churchyard wall. St Mary’s must be the only 12th century church in the country to be built on the lip of a steep, secret valley created by melting ice at the end of the last Ice Age, and on top of an Iron Age earthwork.
"The earthwork under the church is part of the ‘War Dyke’ system around Arundel, linked to loops of the river Arun. Its massive banks run along the edge of the valley far into the South Downs. It divided the kingdom of Cogidubnus from an ‘Oppidum’ or enclave for trading with the Romans. The Grey route would sever the remains of the earthwork itself further south. ...
"In 1868 [the church] was restored by Thomas Graham Jackson, with a glass ‘Cosmati pavement’ in the chancel, like an Eastern carpet, in imitation of mediaeval work. The church is a place of pilgrimage, not just for its faithful congregation, but also for many who come here to enjoy its peace... The church has links to history going back 11,700 years to the end of the Ice Age, when the valley it overlooks was formed. The Iron Age earth bank system, War Dyke, is 2000 years old. The church itself is nearly 900 years old.
"This gem of history, prehistory and culture and would be devastated by the Grey route plan. The Grey route, 8km long, would ... cut through the ancient villages of Tortington and Binsted. It would destroy Binsted’s village life, such as its Strawberry Fair (which funds the upkeep of the church) and its Arts Festival. The death of Binsted village would be symbolised by the ruin of the precious cultural icon that is St Mary’s Church."
The Grey proposition is morally vitiated by democratic deficits, inadequate regard to people and wildlife both present and future, conflict with the imperatives of the climate and ecological emergency, conflict with cultural values. See for example the 15.10.2020 article by Tor Lawrence of Sussex Wildlife Trust, '£450 million to sever landscapes and principles'.
Political decisions need to keep pace with changing public awareness and perceptions, and the Department for Transport and Highways England, since they depend upon the public's money, should also take heed of this. The 2019 consultation, in which two thirds of respondents rejected all the big long bypass options for Arundel, suggests that politicians and Highways England have yet to catch up with changing public concerns.
There can be no place, if we are to tackle climate change adequately, for the type of silo thinking that promotes environmental achievement stories in one area, such as green business and technology, whilst leaving government bodies such as the Department for Transport and Highways England to continue facilitating increased carbon consumption both in road construction and in per capita travel. President-elect Joe Biden has, correctly, announced an "all-government" approach. Only such a consistent, integrated approach across all government departments can succeed. Should the climate emergency not be addressed in an adequately integrated way: it will become a key driver both of escalating inequality, and of political instability.
There is a less damaging and less costly alternative
The practical fact is that whereas Highways England's case for the Grey Bypass is based on many unproven assumptions and false figures, there is a better more easily buildable and affordable solution, the Arundel Alternative, for an explanation of this concept see www.arundelalternative.org . It represents best practices for transport. In summary:
The Arundel Alternative, an uninterrupted, 40mph, wide single carriageway, between the Ford Road roundabout and Crossbush junction, would avoid current pinch points to improve traffic flow. Consistent with best practices in transport, there would be far less intrusion into the landscape, improved traffic flow, walking and cycling access across town and to the railway station, and improved safety. The Arundel Alternative also minimises new traffic and carbon emissions. It is the most likely solution to be affordable economically, and to be acceptable to the Planning Inspectorate because it is far less damaging.
Working from home is becoming the norm
Highways England's big bypass proposals, however beneficial to themselves as a road-building company, and to their construction industry partners, fail to take into account essential long term cultural changes which are already under way. As many of us have found, working from home is not only possible, it is productive. Technology accommodates this change, and will continue to develop in this direction as both companies and their employees discover the benefits, which were documented in Acas’s government funded research study “Home is where the work is: A new study of homeworking in Acas – and beyond” https://archive.acas.org.uk/media/3898/Home-is-where-the-work-is-A-new-study-of-homeworking-in-Acas--and-beyond/pdf/Home-is-where-the-work-is-a-new-study-of-homeworking-in-Acas_and-beyond.pdf.
Up-to-date research on homeworking in the time of pandemic is being undertaken by many, including Dr. Daniel Susskind, Fellow in Economics, Balliol College, Oxford University (https://www.wired.co.uk/article/covid-workplace-automation), and academics at Cardiff University and the University of Southampton (https://www.cardiff.ac.uk/news/view/2432442-uk-productivity-could-be-improved-by-a-permanent-shift-towards-remote-working,-research-shows), to name a few.