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BRIEFING PAPER ON FEASIBILITY STUDY to Luton Northern Bypass

A report commissioned by South Beds FoE from the transport consultant Alan James, on the feasibility study produced by Halcrow on the Luton Northern Bypass

 

INTRODUCTION

 

South Bedfordshire Friends of the Earth have commissioned an appraisal of the Feasibility Study by Halcrow into the construction and potential route options of a Luton Northern Bypass.  In particular, FoE asked for advice on the assessment of need for the Luton Northern Bypass and the potential for other transport options not involving major road construction. 

 

The timescale between the availability of the feasibility study report on 22 May and the meeting of local authority members on 16 June to discuss the report has not allowed a full appraisal of the Halcrow report.  Due to other commitments, a response prior to 16 June had to be completed by 30 May, and can be no more than a briefing paper focusing on the main issues.  A more detailed input to areas of discussion raised by this paper can follow in due course.

 

The Brief for the feasibility study concentrates on route options for the Luton Northern Bypass, which includes establishing the need for the road.  It does not give equal priority to the equally fundamental issue of whether a Luton Northern Bypass is possible, given the environmental constraints in the route corridor.  The Brief in any case sets the feasibility study off on the wrong footing as far as WebTAG guidance goes, by placing the emphasis on assessing a road scheme instead of looking at overall transport solutions to overall transport problems. 

 

While the feasibility study has included some consideration of how much can be achieved by non-road solutions, and states (para 11.8) that this was done prior to appraisal of route options, the Brief establishes that alternatives were always being considered in the context of the feasibility of the Luton Northern Bypass.  Even if the context were genuinely seeking to establish whether there was a need, as opposed to seeking to justify the Luton Northern Bypass, it is not the same as the open-minded approach to transport solutions without preconceived ideas of preferred modes that is demanded by WebTAG and endorsed by the 2005 LTP major scheme guidance.

 

This short paper considers the three main aspects of the feasibility study outlined above:-

 

?         Need for a Luton Northern Bypass

?         Environmental feasibility of a Luton Northern Bypass

?         Alternatives to a Luton Northern Bypass     

 

  

2.  NEED FOR A LUTON NORTHERN BYPASS

 

The Halcrow feasibility study states that:-

 

“ the primary objective of the study has been to reach a conclusion as to:-

Whether there is a need, or otherwise, for any form of a Luton Northern Bypass; and

If it is decided that there is a need, to suggest what the form of such a road should be” (feasibility study para 30.1)

 

It concludes that the principal benefits of a Luton Northern Bypass would be to improve:-

Traffic efficiency, road safety, and accessibility

in the northern part of Luton

Traffic conditions on minor east-west roads

to the north of Luton

 

Need 

Whilst the clear thrust of the Halcrow report is that the traffic benefits of a Luton Northern Bypass are worthwhile, that without it problems would worsen significantly in the areas outlined, and that alternative options without a Luton Northern Bypass would not deliver significant benefits, the report stops well short of saying that the need has been established.  The Executive Summary states that the choices are “‘political’ rather than technical” (p xiii) - in other words, Halcrow feel unable to advise whether the traffic and accessibility benefits of the scheme (as they perceive them, but which are open to challenge as discussed below) outweigh the large adverse environmental impacts.

 

Perhaps the main reason why a clear-cut need cannot be established is that the Luton Northern Bypass - and indeed other committed road schemes in the area -  do not set transport in the Luton area onto a positive trajectory which it would not otherwise achieve.  The feasibility study concludes that committed schemes such as the M1 widening, Dunstable Northern Bypass, and East Luton corridor improvements, will mean that “traffic conditions in most parts of the study area will not be significantly worse than those that exist today” (30.2, p410).  The report then claims that conditions in north Luton and on the minor east-west roads would be significantly worse than at present without the Luton Northern Bypass.

 

The problem with this argument - setting aside for now the question of whether it is correct, given that there appears to be little if any discussion of induced traffic in the feasibility study - is that it does not promise a future in which traffic conditions improve through road building but would deteriorate without it.  Instead, the indication is that conditions will worsen anyhow compared with the present, but will be less worse with new roads than without them.  It is therefore at most only a matter of degree, of “how much worse” will traffic conditions be, set against a hypothetical and untestable future state.  This being the case, it is not possible to assert “need”, because there is no threshold by which need can be defined.

 

In any case, even by its own parameters the feasibility study does not demonstrate all that significant a worsening of traffic conditions without a Luton Northern Bypass.  Table 11.1 gives an analysis of traffic efficiency without a Luton Northern Bypass, which shows that in the AM peak in 2021:-

 

- around two-thirds of links, and 86% of junctions, would operate without problems

- almost 88% of links, and 92% of junctions, would operate with ‘no’ or ‘slight’ problems

- Links and junctions with ‘serious’ problems do not increase compared with 2001, and the proportion remains very small        

 

Even acknowledging that under this analysis the incidence of category changes is greater in north Luton and the east-west routes to the north of Luton (feasibility study figures 11.5/ 11.6), the degree of difference hardly makes a compelling need case for the Luton Northern Bypass.  The differences are incremental rather than fundamental.

 

Induced traffic 

So far this analysis has used Halcrow’s figures, but there is a question over the treatment of induced traffic effects in the feasibility study.  They do not appear to be discussed specifically; WebTAG guidance states that an induced traffic assessment should be undertaken in accordance with DMRB 12.2.2, and if a variable matrix is not used the reasons for not doing so must be stated (TAG 1.4, summary table of requirements).  There are various indications in the feasibility study that very small increases in traffic would occur in bypass scenarios compared with other alternatives (eg feasibility study table 27.1) but the differences are minimal.

 

It is not credible to suggest that induced traffic effects will be minimal in relation to road schemes with complex effects on traffic movements in and around congested urban areas.  Decades of experience now show that the purported benefits of new roads are often quickly eroded by increases in overall traffic due to increased road capacity.  Traffic tends to expand to fill the available roadspace, which is why it is now widely accepted that “we cannot build our way out of congestion”.  There must therefore be serious doubt whether the claimed benefits in traffic efficiency discussed above would actually happen, or be sustained over any length of time.

 

Regional traffic 

The feasibility study does not appear to conclude that benefits to longer distance traffic are a major factor in the need for a Luton Northern Bypass: the main benefits are in north Luton and the minor east-west roads north of Luton.  The possible importance of a Luton Northern Bypass as a link in an orbital route and between the M1/ A6/ A505, which was raised as a question in the Brief, is discounted.  It is understood that there are wider concerns about the creation of a ‘London outer orbital’ route by stealth through linked ‘local’ schemes, or a too-convenient link between the M1 and the A1 leading to undesirable reassignment for trunk route traffic. 

 

It is clearly preferable for local transport schemes to address predominantly local issues and avoid the ‘trunk routes by stealth’ which dogged and ultimately contributed to the halt in major road building in the 1990s, but this creates problems in relation to major adverse environmental impacts on areas with national conservation designation, since much of the guidance is framed in terms of conservation objectives not being overridden except in cases of compelling national interest.  Large adverse impacts on AONBs, SSSIs, or other scheduled sites, cannot readily be justified in terms of incremental benefits to parts of a town network or minor local roads.

 

 

3.  ENVIRONMENTAL FEASIBILITY

 

As discussed in the Introduction, the question is not just “Is a Luton Northern Bypass necessary?” But “is a Luton Northern Bypass possible?”.  Ideally the second question should have been answered first, since there is little point in discussing the need for or the fine detail of something which could clearly be a non-starter.

 

The 2004 transport white paper “The Future of Transport” reaffirms that:-

 

“there continues to be a strong presumption against schemes that would significantly affect environmentally sensitive sites, or important species or habitats” (eg para 10.29)

 

This is a continuation of policies dating back to at least the Roads White Paper of 1987, often stating more specifically that new roads would not be constructed in designated areas unless there was compelling need.  The policy for National Parks and AONBs (which have the same landscape conservation status) is set out in detail in PPS7 (formerly PPG7), which states that:-

 

22. Major developments should not take place in these designated areas, except in exceptional circumstances. This policy includes major development proposals that raise issues of national significance. Because of the serious impact that major developments may have on these areas of natural beauty, and taking account of the recreational opportunities that they provide, applications for all such developments should be subject to the most rigorous examination. Major development proposals should be demonstrated to be in the public interest before being allowed to proceed. Consideration of such applications should therefore include an assessment of:

(i) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

(ii) the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

(iii) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.”

This leaves some scope for discussion of local effects and balanced assessment of impacts, but framed in the overarching context that “Major developments should not take place in these designated areas, except in exceptional circumstances” (my emphasis).  It can hardly be said that nudging conditions at some traffic hot-spots in parts of Luton ranks as “exceptional circumstances”, even if it were agreed that the Luton Northern Bypass would achieve this.

 

WebTAG provides detailed guidance on appraisal of landscape impacts on nationally designated areas, and these are largely followed in Halcrow’s assessment of impacts as ‘large adverse’ for any route option involving routes C, E, F, or G.  However, their assessment of route ‘AD’ is ‘slight adverse’ on landscape impact, which is questionable.  Route D is much the same as the ‘Safeguarded route’, which the feasibility study appraises as having a ‘large adverse’ impact.  It still runs through the AONB, albeit close to the edge rather than well inside it as are routes E, F, G, and its impact on the AONB extends beyond its curtilage.  WebTAG (Unit 3.3.7, Table 2) does not allow for impact on nationally recognised countryside to be less than ‘moderate adverse’, and the distinctions between ‘moderate’ and ‘large’ adverse impact are judgements of degree: for designated landscape it is the difference between being in “conflict” or “serious conflict”.  The importance of even a ‘moderate adverse’ impact on an AONB should not be underestimated.

 

In any case, route AD is assessed as having a ‘large adverse’ impact on both heritage and biodiversity grounds.  The latter is potentially significant, as it raises issues of law as well as guidance.  In WebTAG, a ‘large adverse’ biodiversity impact means that:-

 

“There should be a strong presumption against options in (this) category, with more than 1:1 compensation (net gain within the Natural Area) for the very occasional cases where development is allowed as a last resort” (WebTAG Unit 3.3.10, Table 3 Footnote B)

 

In legal terms, there is a requirement to carry out appropriate assessment to ensure that there are not unacceptable impacts under the EU Habitats Directive.  Given the ‘large adverse’ biodiversity impact for some options, and the presence of sites of at least national designation, this is a consideration which cannot be discounted.  The Lancaster Western Bypass option was abandoned by Lancashire County Council after it received advice from a leading planning barrister that:-

 

“In the light of ... an array of conflict with EC legislation and national legislation ... I would regard the choice of (this) route as the preferred route not only as extraordinary but as one that was perverse on the part of the County Council.  It would be a decision lacking in logic and one that no reasonable planning authority properly directing itself could come to” (Advice to Lancashire County Council by Frances Patterson QC, August 2004)

 

Whilst advice from one case cannot be applied directly to another, and there were European as well as national designations involved in the Lancaster Western Bypass, the message is clear that statutory designations for nature conservation have to be respected very seriously.

 

Apart from the question of landscape impact of route D, discussed above, the feasibility study accurately reflects the severity of environmental impact of the Luton Northern Bypass.  It reflects the language of PPS7 in setting out the choice to be faced with the Luton Northern Bypass:-

 

“Such a scheme should therefore only be contemplated if it is decided that the needs within the northern part of Luton and to the north exceed the value of the affected environmental assets and can not be solved in any other way” (feasibility study 30.4 point 5)

 

The feasibility study declines to advise further on this decision, regarding it as essentially political rather than technical.  It is however difficult to see how a purported, unproven, and contested local benefit can outweigh the array of national conservation interests which all agree would be subjected to large adverse impacts, when there are repeated presumptions against new road construction other than in exceptional circumstances as a last resort. 

 

 

Arguably, if there had initially been a broad range of options to solve local transport problems, rather than a narrow focus on the bypass itself, a Luton Northern Bypass could have been ruled out in the early stages of option appraisal because of the degree of environmental impact, and more attention could have been given to other solutions.  Instead, a lot of effort has perhaps gone into asking the wrong question, and failing to come up with an answer.

 

4.  NON-ROAD ALTERNATIVES

 

The feasibility study (Chapter 27) looks at the potential for alternative interventions to the Luton Northern Bypass to deliver improvements to local transport.  It considers four specific measures - widening Vauxhall Way; improved bus services in the northern areas of Luton; ‘demand management’ in Luton town centre (specifically, the effects of a £2 congestion charge); and Park and Ride.  It concludes (feasibility study table 27.1) that none of these measures, nor even all four in tandem, would reduce overall traffic levels by more than 1% (and the preferred bypass options would increase overall traffic levels by less than 1%).

 

Unlike a Luton Northern Bypass, the alternatives are claimed not to effect any worthwhile reduction on specific roads in the north of Luton or the minor east-west roads to the north.  The feasibility study does suggest that the town centre demand management would reduce town centre traffic, though the figures in Table 27.1 for trips to, from, or within the town centre do not bear this out - they are still less than 1% different from the ‘do-minimum’ reference case for 2021.  The report further suggests that the alternative measures could be useful in conjunction with the Luton Northern Bypass, but not without it.

 

Appraisal of feasibility study findings 

 

There is much to question about these conclusions.  Above all, the ‘alternatives’ do not remotely represent a strategic option to take traffic reduction and modal shift as far as they can be taken by non-road solutions and then see what if anything still needs to be done.  They are emphatically not a fully worked up option, or series of options, that would satisfy the need in LTP major scheme guidance and WebTAG to produce credible public transport options which would be put forward as genuine candidates for appraisal.

 

There are several specific problems with the treatment of alternatives and the conclusions reached by Halcrow:-

 

The conclusion that improved bus services, demand management, and park and ride will have negligible effects on traffic levels is in serious conflict with the LTP strategies of both Luton and Bedfordshire, and with the Regional Transport Strategy.  The RTS defines Luton/ Dunstable and Bedford as “Regional Interchange Centres” in which

 

  “Public Transport facilities to, from, between, and within are to be greatly enhanced to encourage public transport use and traffic management measures should also be implemented in RICS to discourage the use of cars” (from Bedfordshire LTP 2, para 2.41)

 

  The Luton LTP 2 is spearheaded by promotion of sustainable transport options, to reduce car use and thereby congestion and air quality problems. 

  The feasibility study is in effect saying that these aspirations are pointless, because sustainable transport measures such as improving bus services, demand management, and park and ride, do not reduce traffic, so in this respect do not work.

 

The feasibility study also contradicts other demand management initiatives in Luton, notably the Luton Airport surface access strategy.  This has a target to reduce the modal share of cars for passenger travel to the airport by over 13 percentage points between 2004-2015, using a mix of demand management and supported public transport improvements resulting predominantly in a significant increase in public transport use.  If it succeeds, using the airport’s figures it will reduce passenger trips by car to the airport by 1.6 million per annum, or an average of 4,400 person-trips each way per day on the local road network, compared with levels which would otherwise occur in the absence of a demand management strategy.  It is not clear what if any assumptions have been made in the Halcrow study about modal shift in airport trips, and this is only one of many potential suppliers of modal shift.

It is generally unclear the extent to which LTP 2 proposals for ‘soft measures’ have been factored into the modelling by Halcrow.  Presumably major infrastructure like Translink has been incorporated, but it is unclear whether any account has been taken of the host of minor measures at the heart of the cumulative delivery of sustainable transport measures.

It is especially unclear whether the effect of public transport improvements, or park and ride, have been modelled purely on travel time (which probably would deliver relatively little modal shift) or the wide range of other factors - such as cost, service frequency, vehicle quality, information levels, access to bus stops - all of which influence travel choice.

There is no mention in the feasibility study of walking and cycling.  At the 2001 Census, Luton had amongst the lowest levels of commuter cycling of urban areas of comparable size in England, and one of the lowest levels of walking.  Walking and cycling combined often have 2 to 3 times the modal share of public transport in medium sized towns (and in extreme cases like York and Cambridge 4 to 6 times!), so their contribution should not be undervalued.  Where current modal share is low, as in Luton, the potential for growth is correspondingly high.

 

There needs to be a clearer statement about what is and is not included in the feasibility study traffic forecasting assumptions, and a much more convincing and concerted integrated non-road option presented for appraisal, before any credibility could be attached to the feasibility study conclusion that non-bypass options would not work.

 

Potential achievement of non-bypass options

 

It would be a major exercise - though one which should be done to identify what could be achieved by ‘soft measures’ (including infrastructure investment in walking, cycling, and public transport) in the Luton area, and to appraise the extent to which such an option or series of options would meet the transport objectives of the area.  There are however some pointers.

 

The DfT “Smarter Choices” report, which accompanied the 2004 Transport White Paper, concluded that demand management measures alone (excluding infrastructure investment) could cut car traffic significantly:-

 

- Urban peak hour traffic could be cut by 21%, and off-peak by 13%

- Nationally, the central estimate for potential reduction in traffic volumes is 11%

 

This requires ‘soft’ measures to be taken seriously and delivered concertedly.  It also requires to be done in the context of the 2004 White Paper’s strategy to target road space increases specifically at capacity bottlenecks, and - crucially - “lock in the benefits” of capacity increases rather than watch them be eroded by ever-rising traffic levels.  The implementation of soft measures is not helped by new roads which pull the balance of advantage back towards car use, even if only temporarily until traffic growth cancels out the advantage.

 

An indication of what could be achieved in Luton can be gained by looking at what has been achieved elsewhere in broadly similar contexts.  A few local authorities of comparable size to Luton have become recognised as beacons of best practice over the past few years, notably York, Nottingham, Brighton: but there are unsung places, such as Reading, Portsmouth, Hull, which have significantly higher usage of public transport, walking, and/ or cycling than Luton. 

 

A review of the then current performance of 17 comparable local authorities has been undertaken, using journey to work data from the 2001 Census.  The authorities were selected on the basis of the size of the employed population, excluding authorities in metropolitan areas: there are actually relatively few free-standing urban areas the size of Luton-Dunstable (82,000 employed population) so a wider size range of generally 50,000-110,000 has been used, including some towns which though somewhat smaller or larger than Luton give useful comparisons.  The towns closest in size to Luton are Reading, Portsmouth, York, Swindon, Derby, and Hull: smaller towns include Darlington, Cambridge, Ipswich, Preston: larger towns include Northampton, Southampton, Nottingham, Leicester, Brighton.

 

The comparison shows that:-

  • Luton had the second lowest combined modal share of walking, cycling, and bus use (21.18%, compared with an average - mean and median value - of 30%)

  • Luton had the lowest level of cycling (1.76% modal share, compared with a mean of 6%, median ca 4%), and levels of walking just below average (13.32%, though the spread of percentage modal shares for walking is relatively small, with all but two of the authorities between 10-15%)

  • Luton was one of 4 authorities with bus modal share below 8%, compared with a mean of 10.7%: but two of the others - York and Cambridge - had very high levels of walking and cycling.  Bus modal shares were quite variable, with 5 authorities above 12% and the highest (Nottingham) at 21.4%

  • Conversely, Luton had the third highest levels of car use (64.2%, including those travelling as passengers): 5 authorities had levels of car use below 55%, and 2 more just above 55%.

  • Of the 6 towns closest in size to Luton, four (Reading, Portsmouth, York, and Hull) were above average for share of sustainable transport modes, and only Swindon was with Luton in the bottom quartile.

It should be stressed that no one place can be used to suggest that another place should be able to achieve that level of modal share of any given mode, because there are always specific characteristics of geography, climate, and social mix to take into account.  However, other places can be used to show how much they have achieved with their particular mix, and lessons can be transferred and applied even if modal share targets cannot.  It would be futile to suggest that Luton could ever achieve the 26% cycling modal share of Cambridge, but it is fair to suggest that if one mode is disadvantaged - for example cycling because of topography - another sustainable mode should be able to compensate: for example, Brighton has less than 3% cycling modal share, but over 17% bus.  Luton’s problem is that it presently performs rather modestly on all the more sustainable modes.

 

York provides an exceptionally useful insight into what can be achieved by concerted policy action over several years.  Through the 1990s York was at the forefront of promoting walking and cycling, and the 2001 Census shows it second only to Cambridge for combined modal share of these modes: however, the modal share of bus was barely 7%, below that of Luton.  In the 2001-06 LTP, York concentrated on raising the modal share of bus use, and achieved an overall 49% increase over 5 years to 2006!  York’s LTP 2 target is to increase bus passenger trips from 12 million in 2003-04 to 17.5 million in 2010-11, a further 46% increase on top of the 49% increase recorded over the past 5 years.  Satisfaction with buses now stands at 71%, and the LTP 2 target is to raise this to 80%: comparative figures for Luton are 49% and 55%.

 

There are a number of lessons from York for Luton:- 

  • York began promoting bus use in 2001 from a lower base than was being achieved in Luton at the time, and has achieved very significant rises in patronage.

  • The context for bus usage in York is in many ways similar to Luton: it is a similar size, has similar levels of car ownership, has pockets of serious multiple deprivation (often unrecognised because of the tourist imagery), is a place with a lot of outward commuting to a nearby conurbation (Leeds), and has probably less roadspace than most towns for bus priority.

  • York has promoted bus usage on the back of already high levels of walking and cycling; Luton may be argued to be only just beginning to tap the market for changing travel behaviour, and is unlikely to achieve York-levels of cycling, so there is arguably a basis for even more spectacular growth in bus usage.

  • Similar towns to York have achieved far less than York: Derby and Darlington are both relatively flat and relatively dry, and Derby has a student population, but neither is anywhere near the levels of cycling achieved by York.  There is a “York premium”, beyond its intrinsic advantages, which is down to the commitment of the local authority to achieve radical increases in its levels of walking, cycling, and public transport.

  • There are important spin-offs in areas such as road safety.  York achieved the government’s 2006 cycling accident reduction target before the LTP 1 period even began, in spite of - or arguably because of - the high levels of cycling promoted during the 1990s.

There can and should be a degree of confidence that Luton can achieve much more by way of traffic reduction and modal shift, with consequent improvements in congestion and air quality, by active promotion of non-car modes, than is indicated by the Luton Northern Bypass feasibility study.  The transport modelling by Halcrow for 2021, which suggests simultaneously that new roads will not engender induced traffic, and that promotion of alternatives will have no effect on levels of car use, is a counsel of despair which is the antithesis of current government policy and should not be accepted.   

  

 

CONCLUSIONS 

  • The need for the Luton Northern Bypass has not been established.  At best, assuming no induced traffic effects, it brings some incremental benefits to some parts of the road network, but does not cross any threshold of change by making conditions improve rather than deteriorate.  At worst, assuming induced traffic as is almost universally experienced when new road capacity is provided to relieve congested urban conditions, the Luton Northern Bypass will achieve little or nothing, other than promoting the current trajectory of traffic growth which government policy is seeking to arrest

  • The Luton Northern Bypass is arguably unbuildable, because of the severity of environmental constraints

  • The feasibility study is not credible in its conclusion that non-road alternatives to the Luton Northern Bypass would have negligible effects on traffic levels in and around Luton.  Experience elsewhere shows that much higher shares of walking, cycling, or public transport are possible than those currently being achieved in Luton.

In saying that a decision to proceed with a Luton Northern Bypass is “political rather than technical”, Halcrow are in effect concluding that, in spite of their dismissal of alternatives, they are unable to say that the need for the bypass outweighs the serious environmental impacts.  This paper reaches a different conclusion based on a different starting point: the serious adverse environmental impacts should rule out a Luton Northern Bypass, and there is no need to be so pessimistic about the ability of alternatives to deliver an improved, sustainable transport scenario for Luton, more in line with the strategy, objectives, and aspirations of the Local Transport Plan, the Regional Transport Strategy, and national government policy.   

 

Alan James

30 May 2006

 

National

Friends of the Earth

 

 

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