|
||||||||||
|
|
||||||||||
|
Flawed consultation and Ministerial delays: the Highways Agency's grandiose scheme makes even less sense three years on... (an analysis by Blackwater Valley resident Ken Winckle) Three years on the Highways Agency's flawed proposall continues to blight the area. The public consultation process was flawed which may partly explain why Ministers have not been able to agree a way forward. Three years on the terms of the debate have also changed and the original granadiose project makes less sense than ever. Ministers and MP’s have commented and made recommendations on various aspects of this process all of which I agree with and I look forward to seeing improvements in future phases of this project. However I am concerned that the issues that have been identified are essentially administrative whilst other more fundamental failings appear to have been overlooked. The following points are in my view of great importance: 1. It has already been noted that in the Public Consultation document the Highways Agency (HA) ‘preferred’ Southern Route was marked up as a solid black line whilst the other routes received a token grey broken line. However the HA went beyond this and committed the time and the expense to produce a video simulation of what it would be like to drive along the Southern route. 2 Whilst an Environmental Impact Study was carried out, it was no more than a paper exercise and no site evaluations were undertaken. Nevertheless, this study was deemed sufficient for the conclusion to be drawn that there were no significant environmental differences between the route options and that environmental considerations were therefore in effect neutral so far as route selection was concerned. As an aside I find it shocking that the HA felt justified in funding the preparation of a video simulation of driving the Southern Route but did not consider site environmental assessments necessary as a precursor to drawing very significant conclusions on environmental variance between the routes. As a further point of information, when the main HA contractor Hyder did eventually visit the Blackwater valley their environmental representative commented that it would be an environmental disaster to build a new highway through the area. In the absence of serious HA, ie government driven work to assess the environmental importance of the area other bodies have been forced to undertake this work and results have repeatedly shown that this as yet untouched part of the Essex countryside would be irreparably damaged if the southern Route were to be built. 3 The HA deemed the Southern Route to be ’preferred’ because it generated more economic value than any of the other options and because all the options were, in environmental terms, essentially equal. A number of flaws in the economics as set out in the Technical Report have been pointed out and most of these have been resolved by the HA. There remain a number of issues however that are of concern. The first of these is the decision by the HA to uniquely uplift the economic value of the Southern Route by allocating to it A12 incremental value arising as a result of an A12 improvement that occurs only with the Southern Route. It seems disingenuous to construct the economic case for the Southern Route in this way when it would be equally if not more logical to allocate that value gain to the A12 which is in fact what the HA does but only after a period of eight years by which time they predict the A12 will have undergone major improvements. This eight year tranche of benefit NPV is a major contributor to raising the NPV of the Southern Route above that of the other routes. The second concern is that the economic evaluation that was used to justify Southern Route ’preferred’ status contained a computational error that gave it more value than it otherwise would have had. Whilst this has been now dealt with by the HA , it should nevertheless be noted that the HA went into public consultation in a poor state of preparedness which is nothing short of negligent for the obvious reason that the process was promoting the Southern Route and inviting public comment on incorrect information. The third concern is that of cost estimation. The very fact that the cost estimate has, in the space of three years, doubled plainly points out once again that insufficient work had been done before going into public consultation. Obviously cost is a major variable in the determination of benefit and therefore the economic evaluations for all of the routes must be called into question. Nevertheless it was these evaluations that were used to elevate the Southern Route to ’preferred’ status. The fourth concern is that of timing. In the three years that have elapsed since the commencement of consultation, the commissioning of the road has been delayed by five years. This plainly demonstrates that neither the HA or the HMG departments involved had the faintest idea of what the timing was likely to be. As is the case with costs, timing plays a fundamental part in computing economic value and on these two issues alone it remains my view that it was absurd to go into public consultation at all, let alone with one route being emphatically elevated above the others on the grounds of enhanced economic benefit and no relative environmental impact. From a technical perspective I am very disappointed to see that a major HMG agency sees fit to put into the public domain data which has not been rigorously checked for errors nor apparently has it been analysed for uncertainty. At all stages in any project work, let alone a £200 million plus public purse investment, costs, timings and other key variables should be stochastically modelled for most likely outcomes. Whether the HA and its contractor did this is not clear. However the fact of the matter is that no evidence to indicate that this was done can be found in the Technical Report and even if it was carried out it failed to prevent the HA from going into the public domain with a set of costs and timings that were wildly optimistic and palpably unachievable. The HA and those of you in the Transport Ministry who have management oversight responsibilities should thoroughly examine the technical procedures and accountability controls that govern this type of work so as to prevent similar situations from arising in the future. (I dare say work of this nature is currently in hand following the Christmas/New Year debacle involving Railtrack projects which in all probability suffered the same sort of optimistic fingers crossed planning as appears to be the case with the A120). The conclusion that I draw from all of this is that the so called public consultation process in 2005 was actually nothing of the sort. It was in reality a hard sell of the Southern Route that was badly timed and has left the public in North Essex poorly informed, totally confused and in many instances severely blighted. The HA has repeatedly stated that it did not allocate preferred status to the Southern Route. This in my view is nothing more than semantic elasticity, the fact of the matter being that since the day that the Public Consultation document was published the Southern Route has dominated the debate. Current Political and Commercial Debate 1 It is widely felt amongst those who are associated with and/or live in the Blackwater valley that the environmental, recreational and historical value of this small unspoilt area of North Essex continues to be seriously underestimated. The notion that a new Southern Route 4/6 lane highway might be built through the valley is deeply shocking since it would irrevocably damage the environment in both the flora/fauna sense and in the community sense. It would drive a new traffic corridor through an area consisting of three ancient villages that has remained essentially unchanged for centuries. Regardless of what planning scenarios might be envisaged it is an inevitability that with new highways comes economic development, ie commercial and residential land exploitation. With a Southerly route effectively creating a new third corridor between the existing A12 and A120 corridors, the well preserved independent and rural nature of the adjacent villages of Kelvedon, Coggeshall and Feering would be lost as planning boundaries are changed under the influence of a new road. 2 The A120 passed through Coggeshall until the late 1970’s at which time it was rerouted as a bypass to the North of the village. Whilst the scale of that project was geared to 1980’s traffic volumes and therefore built as a two lane highway, the Northern option was chosen, presumably on economic and environmental grounds, over the alternative of building a bypass to the South and through the Blackwater valley. It seems totally absurd therefore to contemplate, 30 years later, a Southerly bypass in the form of the Southern Route rather than upgrading the existing A120 Northerly bypass. 3 Even as recently as 2005 scientific and economic forecasts in areas such as traffic growth and global warming were, I suspect, considerably different from those that are currently in place. Presumably HMG policies for transport/infrastructure development and environmental management are therefore also different from those that provided the framework for the HA work leading up to the public consultation exercise. Aside from the fact that different technical forecasts will change economic evaluations, it seems to me to be important that the upgrading of the A120 be managed in accordance with prevailing views of the future and that the general public when next consulted be made fully aware of what those HMG views are including what changes if any have been made since 2005. 4 Given that, in the space of three years, the commissioning date for the upgraded A120 has been delayed by five years, there appears to have been a major disconnect somewhere in HMG/Regional/Local planning systems. It seems incredulous that the HA were allowed to enter the public domain with a consultation document that presented an unachievable plan. Are we expected to believe that none of the parties involved understood the funding constraints at the time or is it the case that the correct political framework was not adequately constructed to position the project in its rightful place in the greater scheme of viable infrastructure development. Either way, by proceeding in the way that it has, much damage has been done to the credibility of the HA and of course to the many residents of the area that have been blighted by this whole affair. 5 The notion that this section of highway should form part of a Trans European Network seems to be rather far fetched. That road arrangement already exists in the form of the A14 and the A12 and would be little enhanced by a loop in between which would achieve little more than to feed traffic up the M11 to the A14 or down to the M11 to the M25 as is already being done by the existing roads. Do Ministers, MP’s and local politicians, or for that matter, the beaurocrats and technocrats of Brussels really believe that the desecration of the Blackwater valley is a worthwhile price to pay for a marginal enhancement of a Trans European Network that is effectively already in place. 6 From the snippets of information that emerge from the HA it seems that they now have solutions for the various bottlenecks that currently bedevil the A120. In the apparent absence of any plausible finance plan that would enable the full project to proceed for goodness knows how long (I assume that the currently indicated 2018 commissioning date is once again a best that can be achieved, ie optimistic date) would it not be more appropriate to break the project down into smaller parts that can be actioned in a controlled and prompt manner. For example a rebuild of the MacDonald’s roundabout alone would transform the functionality of the road. 7 As you will be aware, since the conclusion of Public Consultation this project has been characterised by repeated ministerial statements advising that decisions would be forthcoming in the near term, ie in a matter of months. Each statement has been followed by a similar one and we now find ourselves two and a half years later no better advised than we were at the outset. I note from your recent meeting with my MP Brooks Newmark that you are resolved to deal with this matter - please do not let the citizens of North Essex down by lapsing into further bouts of procrastination. |