Representation by Keith Buchan
- Date submitted
- 16 September 2021
- Submitted by
- Members of the public/businesses
I am writing to register as an objector to this scheme in somewhat unusual circumstances. I am a Chartered Transport Planning Professional and have some 40 years experience in transport planning. I now spend most of my time working for the Transport Planning Society running their qualifications and professional development scheme. I am currently acting as an expert adviser to the CPRE PDSY. Since March 2021 I have been trying to obtain what I would consider to be basic information from the then Highways Agency, now renamed National Highways. This was for two reasons: first to scrutinise the work supporting the scheme and secondly to help in the finalising of better performing alternatives to the proposed scheme. The scrutiny point is important – in 2007 a scheme was abandoned after serious flaws were found in the modelling. It is important to note that this is a scheme falling within Greater Manchester at one end and the setting of the National Park at the other. It therefore poses complex transport planning problems whose solutions should frame infrastructure proposals, not be led by them. Further details on this will be delivered in the technical report to my client which they intend to submit to you in support of their objection. I am using whatever data I have to hand. To be clear this alternative package includes measures to lower the demand on the network (passenger and freight); to manage traffic through the two corridors so that its impact is reduced; and to support sustainable travel. This is in line with Government policies including the legal acceptance of the Sixth Carbon Budget in June this year and the publication of the DfT Decarbonisation Strategy in July. The latter is in line with the Greater Manchester 50-50 vision for local travel which would have a major impact on the forecasts used for the scheme. The issue of how to deal with forecasting and uncertainty has always been present in WebTAG, but the publication of the DfT Uncertainty Toolkit in May 2021 gives clear further guidance. The uncertainty log provided for this scheme does not comply with this or indeed the earlier guidance. A “low” traffic forecast is mentioned but no detail is provided. What concerns me is that there has been a succession of failures to supply basic information and reply to reasonable requests for clarification. It is important to note that a WebTAG compliant appraisal may or may not have been completed – but it has not been supplied. The Transport Assessment (TA) is not the same as an Appraisal (we teach this to our entry level graduates) although the TA supplied appears to refer to one. This is completely unacceptable on many grounds including professional practise and I have started a formal complaint with National Highways on their failure to respond. My specific objection is that insufficient evidence has been presented to the DCO to test compliance with Government policy or guidance. From what has been submitted it would appear that it does not.