White Horse Alliance - A350 Westbury Bypass Campaign

Inquiry day: 19

Inquiry date: 18 July 2008

See notes part 1; part 2

Inquiry index

Notes, part 1

Original document(PDF): Day_19_Nicolson.pdf

Day Nineteen

Mr Randle said the revised figures should be available by lunchtime on Friday. The information has already been sent for publication in the local press. It is intended that the information will be available on the boards at the back of the inquiry.

Mr Nicolson said that he would need the information and said he had heard from members of the public who said they would like the information in their possession.

Mr Langton said there is no regulatory requirement for this material to be published, but as a matter of good practice the material should be publicised. It is for the County to satisfy the Secretary of State that the publicity process has been carried out adequately. It is a matter for the County to decide how the information is distributed.

Mr Nicolson again inquired whether the information could be sent to a member of the public who had requested them. Mr Langton again said that this was a matter for the County.

Mr Kinnersly asked for an assurance that the Inspectors could say whether it would be suitable for distribution.

Mr Randle said it was the role of the County to decide how to distribute the information. When the information is available it will be possible to view the information at the inquiry.

Concern was raised that there will not be enough time to assess on the information and that there has not been time made available at the end of the inquiry in September to discuss the information.

Mr Langton said that the central error concerns the number of lorries in the traffic assignments. That error has already been corrected and the inquiry is proceeding with knowledge of the number of lorries. There may be matters arising from this, which is why the information needs to be publicised. If necessary time could be made available, but that is not the intention at the present time. The important thing is for the inspectors to have the information.

Mr Bowley asked for what the deadline would be for members of the public to submit their views on the information.

Mr Langton said this was a matter for the County. There has been a reasonable amount of time made available for consultation.

Mrs Locke said that August would be a difficult time for the public to comment on the figures. Mr Langton said he appreciated the difficulties, but said there was not an alternative.

Mr Kinnersly drew attention to the need for consultation on the weight limit with the West Wilts Trading Estate and noted the weight limit was not clearly mentioned in the press notice.

Mr Randle said that Mr Turner would be consulted on the figures.

Mrs Locke noted that the Chamber of Commerce had always worked extremely closely with the Council.

Mr Bullock confirmed that the information would be available at around half past twelve. Mr Bullock said he would endeavour to make the information electronically available at some point next week.

Andrew Nicolson

Mr Nicolson said he had requested other information from WCC, acting as an agent for the White Horse Alliance and also as an individual objector, and my particular interest has been in computer files of traffic modelling. Last night I sent Mrs Wilson a sequence of emails, a lot of them have been correspondence with Mr Bullock and with a corporate information officer. The state of play is serious enough to warrant the inspector's attention.

My general experience has been that it hasn't been easy or quick to get the information. You have been aware of a shuttle letter between the WHA and the WCC and may feel that all those requests have been met. From my perspective, that is not the case. Also made a few fresh requests for information relevant to matters that have come up in evidence. So the way things are now, I have been prevented from producing all my evidence that I intended to, because I've been lacking information that I have asked for. I have had two ways available to ask for the information. One is under the auspices of the inquiry, the WHA has status under Rule 6 and have been informed we would have all the information we would need. Even before the inquiry began, Mr Bullock assured the WHA that all the information requested would be provided. The other route has been through the Freedom of Information Act and the Environmental Information Regulations, which Mr Bullock said we need not recourse to, as we had WCC's full cooperation. Some of the information I asked for has been contentious, and it has been necessary for me to turn to the Council under those laws when Mr Bullock has taken the view that it wasn't for him to disclose that information. I think I am right in feeling that his view and mine was that this would be a more unwieldy way of getting the information.

I would like to turn to two or three examples to show that I feel disadvantaged by the lack of information. Just after 8am this morning an email came from Sharron Evans, the corporate information office, attaching sixteen spreadsheets of traffic counts from early 2008. This is information that has been on our 'shopping list' for quite some time. I had a helpful meeting with Mr Bullock and was told that this sort of information was not able to be provided electronically. Earlier this month the WHA did receive these tables as hard copies, and that of course is a very unwieldy way of handling this sort of numerical information.

A second example is computer files, described as input and output files, that relate to Saturn traffic model runs and to Coba runs and possibly Tuba runs and Tempro software exercises. There has been a number of different runs of these programmes for validating the traffic model, for forecasting, for preliminary assessment for variable demand. One of my first requests in December 2007 was for a list of the computer files. I was provided with one list of twelve files. These were all input files, as I understand relating to forecasts of the three options, east, far west and do minimum. Apart from that I have never had a list of files that would have been a first step for me to make sensible and reasonable requests for the files I might need.

I don't think I have received any output files. I have access to Saturn software. This list which has been appended invites me to make my own runs using the input files provided. I have to trust, because the system is automatic, that my outputs will be the same as WCC's because I haven't been provided with those. I believe Mr Helps has undertaken to come back with details of journey time surveys and whether some papers have showed individual journeys or averages.

The fourth example is information about contracts. In giving a reason why some computer files were not provided, my understanding was that the Council's contract with Mouchel was relevant, and so I asked to see that contract. But I was thinking about the Freedom of Information laws, when I put in a concession that I didn't need to see actual sums of money or names of individuals. I thought that would let the Council provide the contract without breaching commercial confidentiality. I would ask the same of the contract with Osbourne, the relevance being that WCC justifies its optimism bias in terms of its contractual arrangements with the Osbourne company. I think what happened to that request is that it was either ignored or not noticed, and then not taken seriously, and then passed to Ms Evans for the Council's FoIA function early this month. I am awaiting a response. There is information that Ms Evans has started by saying that providing the information would cost a large sum of money, but was eventually provided. In her last communication to me before today, Ms Evans said she felt that all the different information I was asking for should be aggregated for charging purposes. Since 3 July I have not heard from her further about a number of items. I understand that council officers work hard and have a number of duties, and it is my experience that information requested under these laws is often provided on the second to last day of the statutory period. But two facts remain. One is that those laws direct for the information to be supplied as soon as possible. The other is that it is information that I have requested for myself and for the WHA, in most cases having failed to get it through the cooperative channels, for the purpose of helping the inspectors to decide on the council's planning application and orders.

Mr Randle said no application had been made as a result of what we had just heard. Normally such complaints would be followed by a specific request. The inquiry should understand the purpose of the information placed before it.

Mr Nicolson said, I am afraid I am not an expert in procedure. I have prepared evidence on the basis of information I had, which I provided on the 19 May. I have given in supplementary rebuttal evidence and have referred to the information that has been dealt with in the last week. There has been an ongoing correspondence with Mr Bullock, and I have no idea whether this has been shared with Mr Randle. Have the strongest feeling that I would be able to prepare stronger and more wide ranging evidence if I had received in good time the information I have been asking for and its my view that the witnesses engaged by the WHA would also have been able to put a better and stronger case with some of this information, even though we don't know what the information would be like until we get it.

Mr Langton said to a degree you were coming to the inquiry slightly earlier than ideal. We have deferred Mr Smith and Mr Gillham. It seems to me that having read the proof that was put in, the evidence does make the points dealt with in the supplementary and rebuttal evidence. The public body is meant to have an internal complaints procedure, and if that is exhausted recourse can be made to the information commissioner.

Mr Nicolson said he had made his evidence as coherent as possible, but the traffic modelling exercise that had wanted to carry out go the heart of WCC's evidence, but without the information I cannot do those, so my evidence is missing a 'big lump in the middle.'

Mr Randle said he was concerned that WHA case is being extended. Mr Hopkins is not with us today and when he left us on Tuesday, he made it clear that evidentially he had closed his case. Mr Nicolson must be seen as appearing as an individual, having fed information to Mr Hopkins and the White Horse Alliance already.

Mr Kinnersly clarified that Mr Hopkins would be at the inquiry next Thursday.

Mr Randle said the for the first time, Mr Bullock and I are aware of the reason for the request for WCC's contracts with Osbourne and Mouchel.

Mr Nicolson said a citizen is not required to provide a reason for his request under the FoIA.

Evidence in Chief

Mr Nicolson read his supplementary and rebuttal proof.

Intend to deal further with the matter of induced traffic and to respond to Mr Helps' evidence in cross examination. Deal primarily with the traffic model. Deal with matters arising from the major scheme business case, CD9.8. This is not as comprehensive as I would wish due to its late submission. This evidence deals with likely costs of the scheme by addressing optimism bias. Challenge reliability of evidence, conclude that too defective to be relied on.

S2. Local model validation and local model forecasting. At the time of writing have become aware that Mr Helps has acknowledged errors. Now important to assess additional information provided by Mr Helps.

Unreliable costs. The MSBC presents contractor list in Appendix F. Understand this to be the scheme's risk register. Document seriously flawed. The risk allowance, referring to tables in appendix, is supplemented as the probability that something might happen, multiplied by the risk. There is no evidence that it has been revised since the 11 Dec. Typically a fortnightly review. No risk owner is shown for any of the risk. Individual ownership of risks is considered to be crucial for risk management. There are no risk attached to the town centre measures. The costing is only to two significant figures. Believe there must be great uncertainly as to their costs. There are no risks listed or costed under Category 2, 6 or 12. Many of the risks listed as zero probability risks seem to have a reasonable probability of occurring. Over 112 risks are shown as having zero probability. It would be better practice to attach a finite low probability to these risks. The time criticality of these risks are not commented on.

Estimated probabilities. Table shows how probabilities that are not 0% are distributed. 32 risks are 50/50. 2 other risks are over 50%. The rest, some 20-30 risks, are ranging between 5% and 40%. The risk management team is reluctant to attach over 50% risk, which is unrealistic in principle. A 50/50 assessment gives spurious accuracy to a risk.

Prophet formula. The calculation of risk allowance appears to be multiplied by 1.9. I take this to be the addition of profit at 10.9%. This factor of 1.109 gives spurious accuracy to figures. The precision comes from a multiplication factor. The calculation has been applied inconsistently, which increases the scope for error. There is no incentive for the contractor to minimise and mitigate risks. The more risks, the higher the contractor's level of profit. This results in an overrun-prone project. Contracts have been requested (see above).

Understated risks. Some risks appear to have understated probabilities and maximum impact. For example, none of the risks 3.04, 3.18, 3.21 – about work being delayed by protests – are above £100,000. This is not in accordance with empirical experience, where protests have caused delays amounting to millions of pounds. The scheme is accepted to be contentious.

The red risks. Pg7 indicates items changed by this review. Critical of these in a number of respect. Some are largest risks in register, totalling £8,192,300. Account for over 80%. No comments on how residual risks are to be managed. Major omission in management. Register shows crude estimates. With two exceptions, 9.45 and programme overrun due to accumulation of risks, the risks costs inclusive of 1.109 profit factors. Red risks to just 1 significant figure. Suggests poor or immature estimation process. All maximum figures are fives times the most likely costs, not assessed individually. All red risks show 0 as minimum cost. A reading of the risk description shows this is unlikely to be the case. A sensitivity test of increasing the minimum to half the most likely increases the total allowance by 8.33%. Red risks share a single probability of 50%. This is very unlikely to reflect the empirical probability. Without fixing the risks more precisely, the purpose of the risk register cannot be fulfilled.

Optimism bias. Scheme promoters have consistently underestimated costs. Council have used optimism bias of 15%, which they say is considered suitable for a scheme of this nature. This in itself does not justify lowering the optimism bias. Relevant government guidance comes from DfT guidance by Ben Flishberg of Alborg University and Tag unit 3.59, October 2006. Bias level should not be set by the promoters of the scheme. Local interests should be consulted, who have little or no interest in avoiding cost overruns. Fig2, pg21. Bias in the study is towards underestimating optimism bias. Budget uncertainty reduces as budget is spent. If Wiltshire has spent 10% of the budget, then the bias can be reduced by 10%. The MSBC has not been scrutinised by DfT. Bias should be 40-50%. Optimism bias not applied to town centre measures. Should be a higher optimism bias due to lack of detail. Measures may undergo huge changes. Promoter cannot have low bias and early stage risk register.

One set of files provided has enabled me to check the reliability of the model. Inputs are model of network; a matrix of trips derived from counts and surveys. Outputs a set of traffic flows including turning movements, set of journey speeds and times. These are for a given period. Append excerpts from automatic report from Saturn programme. Run for 2009 pm peak for Eastern bypass. Result was that the programme identified three non-fatal errors, 111 serious warnings, and 79 warnings. Such a large number of errors may explain the poor validity of the model.

Mr Nicolson added that when we refer to induced traffic, we refer to extra journeys made due to improved capacity, and to suppressed traffic, which refers journeys people do not make because of disincentives of travelling by car.

Mr Nicolson read section 2.7 of his main proof. The report does not consider the added traffic that would be generated economic developments that result from the scheme. This makes the scheme self defeating.

The modelling does not model the slowing of traffic that the town centre traffic management measures would bring about by design.

Cross Examination

What does being the principle of SD3M entail?

-Environmental matters – study proposals and schemes, produce reports.

Have you ever been involved in the promotion of a road scheme?


Have you opposed a road scheme?

-A36/A46 Batheaston bypass – wanted to modify scheme regarding cycling

-Avon Ringroad stage 2.

-Avon Ringroad M4 link

-South Bristol Ringroad

In relation to those you wouldn't have done work on induced traffic?

-Induced traffic related to Batheaston

Have you yourself carried out an induced traffic assessment of any road scheme?

-Not using quantitative tools that are now available.

Do you have the belief that any new road capacity will lead to induced traffic effect?

-There are restricted circumstances where there would not be, and more instances where there is very little

What is required is for an assessment to be made of induced traffic?

-Obvious to the professional that there will be significant reduced traffic.

You do not subscribe to the view that new capacity will lead to induced traffic, and you do not believe that an assessment is always necessary.


Circumstances where it is obvious, published guidance to support approach?

-Obvious that there will be significant induced traffic in circumstances where journey times are significantly reduced by a road scheme, where journey reliability is noticeably improved, where a road scheme crosses a physical obstacle such as an estuary, where a road scheme significantly relieves an urban area of traffic congestion, and particularly where a road scheme has an impact on a compact urban area in which journeys are carried out by a number of modes, car and other means of transport.

Any published guidance to support the approach?

-The Satra report on trunk roads in the generation of traffic, 1994, by the Standing Advisory Committee on Trunk Roads assessment addressed the issue. Fully set out the reasoning behind the idea that this phenomenon takes place.

Is it your view that Satra says you do not need to carry out some assessment?

-You do not need an assessment to decide whether induced traffic will take places

-An assessment still needed as to the extent of the induced traffic if going to sensibly promote the scheme.

Optimism bias. Supplementary proof, section 5. Indicated that the thrust behind wishing to see the contracts is based on the understanding that the 15% optimism bias is recorded within it.

-Gathered that early contractor involvement had been the grounds for the council's claim that the scheme was well costed.

-No idea what the contract requires.

Seen information in 'green bundle' that was given to the WHA?

-Seen some of the information

-Not speaking for the WHA.

WCC110. Inquiry reference. Meeting note, DfT 11 Dec 2007. Have seen before?

-Yes, or a meeting note like it.

Present: DfT, SG - Steve Greyson, various people from GOSW, WCC and Mouchel. Pg3, Section 5. SG commented on the 15% bias. In terms of the 15% bias, that is the DfT indicating that, not WCC?

-Team leader from DfT

That 15% came from the DfT. You were aware of that weren't you?


Aware of that before you wrote rebuttal statement, where you criticised use of 15%?


Supplementary proof, pg8. Scope for Optimism Bias. Not the discretion of promoters of scheme?

-Same DfT that confirmed that Tuba not required.

Aware that had not been left to the discretion of the scheme?

-Not aware that 15% a formal requirement from DfT.

Reference to 44% in that context has to be seen in the light of the 15%?

-!5% comment must be seen in the light of DfT's guidance

DfT representative not aware of own guidance?

-At least one other point when the DfT appear to ignore their own guidance.

-Take with pinch of salt

DfT makes it clear that standard 44% not be applied in the context of this scheme?

-Test for economic analysis of 45%

-Request made by officer of department

Officer had authority?

-No idea

Bias not applied to town centre measures. You are aware of the public consideration of town centre measures?

-As far as I am aware, little has been done in the context of process

Are you aware of the description that Mr Bullock gave of the prioritisation approach?

-Not aware

Supplementary pg9. Optimism bias in benefits. Making point that such exercises also seen in the light of optimism bias. Exaggerated NPV.

-Taken from DfT guidance

-Cannot find material that would want to rely on in the extracts that I have provided.

-Promoters claim a number of benefits, some of which are quantified, and there is an inbuilt tendency for the promoters to exaggerate the quantifiable benefits that they attribute to the scheme. This feeds in to the calculation of the present value of benefits and the final outcome is an exaggerated net present value.

When you wrote your original evidence you had the variable demand modelling preliminary assessment available?


Assessment Pg10, S4 - Summary. Para 4. Can confirm that this is the only assessment that has been carried out.

-Thought I had seen another, but have dealt with this one.

What you have done is gone through in your evidence and commented on assessment. Main proof, S2.1. Over the DfT limit. Quote from para 1.3.7. Word 'or' means can take either opening year or forecast year? Assessment cannot be criticised on that basis?

-Not on that basis.

You arrive at your criticism by ignoring the word 'or'.

-If the difference in scheme benefits is greater than 10% in the opening year or 15% in the forecast year, then we don't have a robust case.

-Meaning of word 'or' is that the number we should use in the opening year is 10%, we should use 15% in the forecast year.

You have mistaken 'or' with 'and'.

-'Or' is in there because author distinguishing from 10 and 15.

Section 2.2. Counter-intuitive horizon year results. Can you confirm that what has been set out in the assessment in that respect?

-No, because these numbers come after the selection of the elasticity figure.

Are you saying that between 2.1 and 2.2 that the guidance that was due to be followed was not followed.

-Said even earlier than that, that guidance was not followed.

-On basis of what said in 2.3.

When you say counter-intuitive, you are saying guidance has not been followed because of your comment in 2.3.

-Differences in percentages are calculated after the elasticity factor chosen, and so can't go along with anything that comes out of that.

Tell us in 2.2 that doesn't make any sense that figures go down further into the future.

-As congestion increases, the difference of having introduced the road scheme has a greater effect in generating induced traffic.

-Using common sense and professional expertise, we can say that induced traffic greater in later years.

Your subjective assessment.

-Said what professionals in this field have told us about induced traffic.

-What Satra assessment has discovered.

Low modal competition. You recognise that within guidance an elasticity factor is to be applied to the assessment, the extent of the elasticity factor will depend in part on modal competition.


Main proof 2.3.4. Other modes of transport

-Mr Edwards supports ideas that there is a busy train station, and well used buses.

Mr Helps produced evidence on relationship between use of railway and traffic. None of those conclusions were questioned in your cross examination of him.

-Not familiar.

Mr Helps carried out an assessment on inter-model relationship. In your evidence, you haven't carried out an assessment.

-Have done a non-quantitative assessment.

Are you content that your evidence is an illustrative example of the use of these facilities to allow us to judge whether there is high modal competition?

-There is not low-modal competition.

The issue between you and Mr Helps is the appropriateness of the elasticity.

-Mr Helps selects elasticity factor in a single sentence. He gives reason that modal competition was not assumed to be high.

-Travel by car has been dominant almost everywhere for decades. Was dominant when Satra found that induced traffic widespread and significant.

Are you aware of the basis of the research which led to the various elasticity factors?

-Aware of some

Aware that figures came from London congestion charge study?

-Not aware of that

-Numbers produced before London congestion charge was introduced.

Section 2.4. Misinterpretation of results. You refer to Table 2, then say it does not make sense to make speculative interpretations.

-Referring to the phrase 'this may reflect the fact.'

A comment about the statement following the assessment?


Section 2.4.2.

-Chose time elasticity, computer does calculations, generates figure.

-The suppression effects do result from the choice of elasticity.

Section 2.4.3. Some requirement to carry out a test?

-Guidance is not instructions, may not require sensitivity tests, but if at least one of the figures is outside the threshold the right thing to do is to carry out sensitivity tests.

Section 2.5. Invalid analysis. WCC/VDM Table 2. Which figure would 'without induced traffic for the do-minimum' be?

-Top left, 22554

'With induced traffic for Eastern bypass'?


You are saying should take 22554 and compare with 22953. But fixed trip matrix is the same number as the do-minimum.

-Table reading in rows, we have taken the wrong 22554 away from the higher number.

The point you are making has no effect?

-The numbers are the same, but the subtraction exercise operating on numbers from the wrong scenarios.

The point you have raised is of purely academic interest because the numbers are the same?

-From Fig2.1 onwards, the wrong figures are being subtracted.

You do not challenge the figure of 22554 in the context of do-minimum.

-Not equipped to challenge that figure.

What you say in 2.5.2 makes no difference?

-Makes difference because reader of table is reading the wrong numbers.

-Would carry out entirely different assessment.

The numbers would be the same?

-Yes, because there has been a misreading of the methodology.

Section 2.6. Excessively small road network modelled. There is no guidance about the extent of a network in a modelling exercise?

-Has to have certain minimum size.

-Model may need to carry a wider area, as induced traffic has a wide area effect.

Section 2.6.2. If you build Westbury bypass, traffic diverted from Bath, but Bath would fill up again, then Westbury would fill up.

-Yes, because congestion in Bath deters people from travelling in by car.

Section 2.6.3. Say induced traffic significant. You have not carried out an assessment. Are we back to your subjective view?

-Even this flawed assessment has found a significant level of induced traffic.

-Back to assessment that may top 15% of costs of scheme.

Section 2.7. No account of development effects on the scheme. Aware of restriction on traffic modelling in terms of development?

-Modellers have obligation to make professional judgement.

Aware of restrictions on taking into account development?

-One is permitted to take future development into account

Are you aware that when constructing traffic model, you base it on committed development?

-Aware that that is a practice.

You are asking for speculation.

-Asking for professional judgement.

SP2. You have seen Mr Helps' altered evidence?


Have you seen the information presented to the inquiry in relation to noise and air quality?


Unreliable costs. The risk register. Within those pages, I see a critique of tables within the appendices, but nowhere do you take us to the text of the document itself. Have you read the text?

-Read some, not sure whether read all, given to how recently it came.

-Mentioned a couple of pages, pg121 – risk assessment and pg122 – optimism bias.

-Section 6.5.1.

Para 3. Risk register detailed further in Delivery Case in Chapter 8. Did you have a copy of the whole MSBC?


You would have had access to commentary on risk analysis?


Did you look at any time at Chapter 8, Delivery Case?

-In passing.

One of the criticisms you make in pg6 'No Comments' is that there is nothing in comments that deal with certain items. Did you examine Fig 8.3 in pg151?

-No, my comments were addressed to risk register.

You will therefore be unaware of the process set out diagrammatically. Explains how major risks are to be managed.

-The risk register is an actual outcome in the risk management process.

-Diagram not significant.

Pg3, Ownership of risks. Making point that if we look at Appendix F, the column marked 'risk owner' is blank.


At the top of the table, what does it say?

-Risk / opportunity list contractor

If the contractor is the risk owner, your point is a bad one?

-No, because not all of the risks can be owned by the contractor. Ask where are the risks owned by the client.

You are saying that if we do the exercise we should, the scheme costs will rise, and the benefit/cost ratio reduced.


£2 million figure arrived at.

-Provided by Council. Reached by adding up two figures provided by council.

Revision. Would expect fortnightly review cycle?


-Wouldn't expect to present six month old risk list to a public inquiry or to DfT.

Town centre measures. Aware of the questions put to Mr Bullock on town centre measures?


Annex 4 of the MSBC. Have you looked at?

-When first provided with MSBC, wasn't provided with annexes initially.

Missing categories. Nowhere in your evidence do you explain particular relevance of matters?

-Self evident that matters are relevant to the cost of the scheme.

Zero probability. Been made aware that it was put to Mr Bullock as to the zero probability assessment?


State that more considered estimation, 50% probability would not be given to many more than one tenth of the risks. Where does that comment come from?

-Comes from inspection of the numbers given

-Combination of common sense and professional knowledge of project management.

-Each risk is individual and different.

Red risks. Red signifies change from previous information?

-Don't know whether changes or additions.

Section 6. Errors and warnings. Make comment that such a large quantity of errors may explain poor validity. This is a conclusion that because of the errors you can have no faith in the modelling exercise?

-Saying that if model run exposes that is riddled with errors that should tell us that it is unreliable.

Saying we should take modelling with a significant pinch of salt?


Inspector's Questions

Have you arranged traffic modelling yourself before?

-Only as a personal exercises, only been in the last six months that have worked first hand with Saturn modelling. Worked closely with Atkins.

Have you had any experience of Coba programme?

-Not before this exercise

-Have scrutinised cost-benefit analysis.

-The Saturn manual is much more usable than Coba manual.

Expertise in computer programming?

-Also in the use of software.

Error log a standard feature of programme?

-Yes, for this sort of programme.

Have you done any assessment of induced traffic?

-Not using software.

-Have studied more than one induced traffic preliminary assessment

-Been an analyst of other's assessments.

Example of induced traffic assessment?

-Cannot give specific example. Highway Agency scheme somewhere in England.

You were asked a question about the missing items on risk register. Said that public inquiry at zero cost.

-Public inquiry is in fact a cost to the public purse. Can't of been known how long it would take and how much it would cost. Any estimates made at the beginning may need to be adjusted upwards.

-By being an umbrella group, the WHA has helped the Council to keep the risk of cost overruns to a minimum.

Appendix F. Taken to pg1, risk opportunity, risk contractor. Yellow page. Pg1/6.

-Comment that blank apart from risk numbers and descriptions of risk. In both cases, would have expected a particular officer to be nominated as the owner of the risk. Only when risk given to individual person.

Induced traffic. 1.8%. Significance of 1.8%. Assuming figure correct, is it your view that significance lies with traffic or somewhere else.

-A 1.7 or 1.8% difference has resulted in an impact on the NPV 14%,6%, 4%. The 1.8 is leveraged upwards when we look at the benefits of the scheme.

-1.8% in itself is noticeable, as it could bring impacts above thresholds. Impact on whole economics of scheme much greater than 1.8%.

Notes, part 2

Original document(PDF): Day_16_Joyce.pdf

Day Nineteen

Michael Joyce (representing Mr and Mrs Avery)

Mr Joyce read his proof of evidence.

Mr Avery entered into discussions regarding the footpaths in his land. Two footpaths would be bisected by the bypass and the cement works access road. Consultations determined that it would be advantageous to join the two footpaths and to stop up Footpath Heighwood 28.

Mr and Mrs Avery were concerned to discover that what has been agreed has been altered by the SRO. It appears that the southern section of footpath 28 is to remain open. However footpath 18 is to be stopped up. A new footpath route will run adjacent to the cement works access road. These alterations are illogical and contrary to the interests of Mr and Mrs Avery and to footpaths users.

Mr and Mrs Avery propose that the original understanding be put into place.

Mr Bullock said that there could be some confusion. The original intention was to rationalise the footpaths. As a result of the planning application process it was brought to our attention that Heighwood Parish Council were unhappy with the stopping up of Footpath Heighwood 28.

Mr Morland said that HPC does not believe that Link Q is essential, nor does HPC believe that the stopping up of Heighwood 28 is essential.

Mr Joyce said that it made practical sense to join the two footpaths 15 and 28 as they already run virtually together. Understand that site will continue to be used for methane extraction, so that it will be many decades before there is the possibility for public access. It is logical to do away with a superfluous section of 28.

Mr Langton produced a letter from Lafarge withdrawing their objection on the basis of a letter from WCC.

Mr Randle said that the stopping up of Heighwood 28 was outside the scope of the inquiry.

Mr Joyce said that the process of compulsory purchase of land and then the restoration to its previous owner was unacceptably draconian. Mr Joyce said he wanted some kind of legal mechanism where the original landowner was guaranteed to receive his land back again subject to his discretion.

Mr Randle said that an exchange of letters may be needed as part of the inquiry process. Mr Randle said he wasn't certain that it could be attached as a condition of planning permission.

Mr Langton said that it would be necessary to resume the discussion at a later date, after WCC had had the chance to review some of the information they had provided.

Mr Langton said that all matters concerning publicity and consultation in relation to the revised information was a matter for WCC.

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