Highways England has sent letters to many who responded to the 2019 consultation (though not to all), asking them to fill in a new survey form if their opinion has changed as a result of corrections to the shoddy workmanship of its 2019 consultation information. The online survey form is designed for previous respondents who have changed their opinion, but in fact anyone can respond, click here to email Highways England on this topic. If you care about environmental and transport issues, please do respond by the 1st March deadline.
This blog gives you information to help you with your response. At the end is a summary "How to Respond".
The purpose of this new consultation seems to be to introduce errors to the public in an impossibly confusing way, so HE can say no-one wanted to comment on them or change their responses. The ‘corrections’ are to new versions of their documents, that were issued in September 2019 – not to the original versions from the start of the consultation. Few people will have time to compare all the different versions. And since HE say the corrections do not affect their ‘conclusions’, this is a disincentive to take part at all. This bad process will lead to challenges. What might you say in your own challenge response now?
- The ruinous effect of the offline routes on villages, and the true cost to wildlife, have been left out of the documents right from the beginning - most of HE’s latest ‘corrections’ make no difference to that.
- The 'corrections' can be said to shine a light on how unacceptable and badly managed the whole process has been. The Consultation documents were ‘corrected’ part way through the consultation, and these new corrections are to that ‘corrected’ version. But many people will have taken home the original brochure on 30 August and continued to refer to it, unaware anything had been ‘corrected’.
- The 'corrections' show how Highways England distorted the truth. For instance, in the Brochure’s comparative table of routes, under ‘Cultural Heritage’, the original brochure said for ‘Magenta’: ‘Slight adverse significance of effect on below-ground archaeology for remaining Grade II listed buildings and other heritage assets.’ Tortington Priory and Lyminster have been mentioned. This was meant to cover everything else. It’s nonsense. Grade II listed buildings are not valued for their below-ground archaeology. And there’s no mention of Tortington and Binsted villages. The two successive ‘corrections’ removed the nonsense, but only added ‘slight’ or ‘moderate’ adverse effects to numerous listed buildings ‘outside Arundel’.
- The 'corrections' address points of detail but fail to address major errors of omission - all the important facts that Highways England chose to leave out. For example, ‘cultural heritage’ is not restricted to listed buildings as HE choose to think. There are 10 listed buildings in Binsted, but the truth is that not just Binsted’s 10 listed buildings, but the 38-house village as a whole represents the cultural heritage of a traditional rural community and landscape that would be ruined by the Magenta route. An HE representative has said in a radio interview that up to 20 homes would be purchased by HE. Binsted would become a ghost village. Two houses (close to the Amber route) have already been bought and lie empty. None of this appears in the tables quoted by Highways England, nor in any of the corrections.
- The 'corrections' have not adequately described or corrected a major and highly misleading "error" about Woodland impacts. HE used this 'error' to make a false case in the Brochure that the Online (Cyan/Beige) routes were more environmentally damaging than the Magenta route. HE now admit that in 2019 they gave the wrong figures for the amount of woodland impacted by the ‘online’ routes, by using outdated government information (showing the Arboretum as still wooded). The area of woodland impacted, was made out to be double the true area. They knew this information was incorrect but chose to mislead the public with it. These wrong figures were highlighted in the Brochure and helped persuade Local Councils to support the massively damaging Magenta route. It appears to have been a deliberate decision to deceive the public.
- A major error of omission, still uncorrected, is that Highways England failed to consider the Arundel Alternative option, a much less damaging, shorter single carriageway improvement put forward by local people. HE say it would not have enough ‘capacity’ - but providing new road space has been shown for decades to increase traffic, hence also carbon emissions. HE themselves predict 42% more traffic at Fontwell if they build the bypass options currently on offer - what a waste of resources.
Chris Gillham of Winchester Friends of the Earth commented in his response to the Transport for the South East Strategy: ‘Put a price on the priceless and with all the jiggery-pokery of time-saving analysis you can spreadsheet up a benefit that justifies destroying it.’ The Arundel Consultation Brochure, corrections or no corrections, seems to be ‘spreadsheeting up’ a case for a major destructive new road in an ‘extraordinary’ area (as Natural England described it in their 2019 response), by leaving out inconvenient facts like villages, or the true scale of woodland wildlife impacts.
The CEO of Friends of The Earth suggested in 2019 that Highways England, whose only purpose is to build roads, should be abolished. Their continuing incompetence and dishonesty adds to that case.
The scheme is hugely damaging to wildlife, communities, and the climate, and is way over budget. The ruinous effect of the offline routes on villages, and the true cost to wildlife, have been left out of the documents right from the beginning. Most of Highways England's latest ‘corrections’ make no difference to that. The consultation documents are still biased in favour of the more-damaging offline routes.
Details of the Arundel Alternative are on www.arundelalternative.org. The new consultation is on https://highwaysengland.citizenspace.com/he/a27-arundel-2019-further-consultation-corrections/. Respond by 1.3.2020.
How to Respond
Highways England are running a new ‘mini-consultation’ about the Arundel bypass, with ‘corrected’ versions of documents on their website. It lasts till March 1 2020. The new consultation is on https://highwaysenlgnad.citizenspace.com/he/a27-arundel-2019-further-consultation-corrections/. You need not complete the questionnaire they offer. You can simply write an email express your views, to A27ArundelBypass@highwaysengland.co.uk Responses can be sent in until 1 March 2020. Here are some of the points people are making in response:
I would like to object, not only to Highways England’s proposals for the A27 at Arundel, but also the way it has consulted. The current consultation is deeply flawed because:
- Not everyone who responded previously has been notified about this consultation
- The way the errors are presented is confusing and difficult to follow and will deter people from responding in any meaningful way
- Most people will not remember what information they used to come to their conclusions – many could have responded based on the initial documents which had even more errors, which are not highlighted here
- Highways England are discouraging people from responding by saying that the errors do not change any of their conclusions. People will think why bother if it will make no difference?
- Highways England has still failed to correct seriously misleading information in its consultation documents
- Examples can be found in the blog above