Transport appraisals in Wales and road scheme appraisals in particular, do not answer the questions that decision makers should be asking under the Well-being of Future Generations Act, nor do they reflect what is actually important to citizens.
Transport appraisal needs to reflect, for example, wider quality of life and well-being issues including health, the balance between leisure activities and work, social connections and relationships and the environment. We want to see appraisal systems that adequately capture the impacts of congestion, carbon emissions, pollution, noise and accidents.
Weltag, the Welsh Transport Appraisal Guidance – linked to the UK's Transport analysis guidance Webtag, is the primary decision-making tool for transport investment in Wales. It has recently been the subject of review and consultation.
Weltag consultation finer points
As a broad point of principle, we are inclined to be supportive of the proposed changes to WelTAG. They simplify a complex approach; they make the system more flexible; and they introduce a broader base to making the case for schemes in terms of restoring a balance in the weighting of the benefit cost ratio (BCR) relative to other aspects of the evidence.
However, there are a number of areas of challenges in terms of application and in terms of technical details which we have highlighted in our response to the consultation.
We feel that for WelTAG to be more equitable and for it to better address the demands of the Wellbeing of Future Generations Act, these issues need to be addressed more explicitly.
There are some real positives to the proposed changes to WelTAG guidance
A less restrictive approach to the transport appraisal process, and the alignment of the transport appraisal process with the Well-being of Future Generations Act (WFGA) approach in Wales are positive changes. Emphasising a strong alignment with the Active Travel Act, which, whilst implicit, does not appear to be explicit, would further enhance the value of the process.
Advisory thresholds for schemes requiring appraisal
The removal of an arbitrary lower limit of £5m for schemes provides a much more flexible tool for appraising active travel schemes. We have often expressed a concern that the ‘weight of expectation’ of evidence in support of active travel schemes exceeds that for e.g. road schemes. We have perceived (not necessarily in a Welsh context) that the evidence required to support a £5m scheme is in excess of what is required for a £5m road scheme – and that the resource required to produce that evidence is more difficult to access.
What we need to know is that active travel schemes can be assessed on the same basis as road schemes – or even that the better alignment with policy positions means that the threshold is lowered.
Expanding the breadth of material that can be used in transport appraisal
The expansion of the breadth of material that can be used in the appraisal process is a very pragmatic and sensible proposal. However, it does raise issues around transparency and scrutiny. Transparency is paramount. We see any number of appraisal exercises within relatively prescriptive frameworks where the ways that data is processed, applied and interpreted are far from clear.
Review groups for transport appraisal exercises
In principle, the proposal to convene review groups around transport appraisal exercises around feels eminently sensible. An adequately skilled and informed group could add substantial value to the process and could be a key route to sanctioning the proposal.
However, the approach does present problems in terms of real and perceived integrity, whether wilful or unintentional. At one level, there is the risk of the ‘echo chamber’ effect, where a group can find it’s conviction in a scheme reinforced by weight of peer-opinion. At altogether another level, there is a risk of vested interests becoming embedded in the decision making process.
Just to bring this concern to life a little: What would be the composition of the panel reviewing the case for the M4 proposal? We are not aware that there is currently representation in decision making from groups who would reasonably be expected to express a view that the scheme is ill-considered. How could a voice for these groups be ensured? The converse is also true. How would a walking and cycling scheme be assured of input of a contrarian view to case-building and decision making?
Use of the five cases
The fact that the transport and strategic case can be expressed more forthrightly than may have been expected at times in the past is a very positive move. Our view is that a clear articulation of why the scheme is considered appropriate, in what context, and from a range of perspectives, is a really helpful means of stimulating debate about the scheme. Of paramount importance is how this is then opened up to wider audiences. It is crucial that the cases can be reviewed in the context, particularly the context of, for example, option generation.
The guidance is not clear enough about the scope and breadth of option generation. This is common across all forms of transport appraisal. How does one, in the context of e.g. a ‘local congestion’ challenge, reconcile the possible solutions offered by everything from behaviour change to road building?
We think that there should be a mechanism that introduces a hierarchy within the toolkit of potential solutions, such that lower cost and more readily policy-aligned solutions can be prioritised. So we would advocate, for example, the due consideration of behaviour change schemes first, and then walking and cycling infrastructure, before moving on to more infrastructure-intensive forms of intervention.
In addition, Sustrans response to the consultation raises long-standing concerns about a number of the technical details behind the proposed approaches:
- The treatment of fuel tax.
- The treatment of time-savings.
- The treatment of carbon dioxide emissions.
- The treatment of physical activity.
- Additional benefits of cycling and walking.
- The treatment of behaviour change interventions.
- Treatment of ‘wider economic benefits’.
There is much scope to improve transport appraisal in Wales, and the legislative imperative of the Well-being of Future Generations Act and the Active Travel Act can provide a real impetus to make these improvements.