South East Manchester Multi-Modal Strategy (SEMMMS) Refresh: Response to Public Consultation on Draft Strategy

By Dr Simon Temple BSc MSc PhD FCILT

1. Introduction

This paper sets out my response to the draft SEMMMS Refresh Strategy, issued for public consultation on 21st May 2018. Section 2 of this document sets out the key points of my response and more detailed comments on each chapter are set out in the Sections that follow.

As in most strategy documents, there is much in the strategy that is non-controversial and with which it would be hard to disagree. In the interests of being concise in this response, I have focussed on areas where I consider the document to be inadequate or incorrect.

2. Key Points

• The document provides a misleading impression of the content of the original SEMMMS Strategy (implying it was much more highway oriented than it actually was) and does not accurately reflect the very significant elements that have not been delivered. There is no attempt to learn lessons from this.
• The document asserts that highway congestion is increasing, when traffic flows have reduced on major local roads and there is increasing evidence that this represents a long term change in travel behaviour.
• The strategy appears to have been developed to comprise schemes across all modes, to create a notional “balanced” strategy without a rigorous analytical approach to constructing the optimum package of measures.
• The transport modelling techniques used in the assessment are inadequate and inappropriate for the purpose of strategy development
• Strategic Priority 7 focusses on 2 major highway schemes which would have severe environmental impacts, encourage unsustainable land use development, result in increased congestion elsewhere and take a high proportion of the potential transport funding for the area.
• The proposed governance arrangements for strategy implementation would facilitate the highway, walking and cycling measures proposed, but not the recommended public transport interventions. This makes it highly likely that the outcome would be that an unsustainable road-based set of measures would be implemented.

 

3. Chapter 1 – Introduction and Background

The document rightly starts by referring to the 2001 SEMMMS strategy and discussing those elements that have, and have not, been implemented. However this account is dishonest, selective and highly misleading. It refers to 5 projects that have been implemented (of which 3 are highway schemes and 2 are bus-based initiatives) and two that have not (1 highway and one Metrolink/ tram-train). From this one would infer that the original strategy was primarily highway-based. This is not the case. In reality 3 of the 4 highway projects listed were components of one project – the SEMMMS Relief Road. Several Metrolink/ tram-train projects have been combined under a single heading. There is no mention of the key heavy rail proposal within the original strategy, which advocated a 15 minute interval service on all local rail routes in the study area. The original strategy proposed an extensive network of high quality bus corridors, of which only the A6 corridor has been implemented (and only to a limited extent south of Stockport Town Centre). There is no mention of the walking, cycling and behaviour change initiatives that were important components of the 2001 strategy and which have not been implemented to any significant extent. The overall effect is to create a false impression of the original strategy and therefore to prevent a fair comparison with what is now proposed.

In addition there is no attempt to learn lessons from what has occurred. These could include topics such as:

• Have the schemes that have been implemented been successful?
• Did the unimplemented schemes fail because of inadequate specification, poor value for money, environmental constraints, lack of funding or lack of will?
• Have schemes fallen foul of institutional barriers and how can these be avoided in the refreshed strategy?

The 2001 Strategy was very clear that “the benefits of the strategy will only be seen if it is implemented as a whole. If implementation as a whole should prove not possible, the entire strategy will need to be reviewed” (SEMMMS Final Report, September 2001, Para. 7.1). The implications of the fact that this has not occurred are not considered. An important lesson is the need for an overarching agency or Programme Board with the powers, and funding, to deliver the overall strategy – this is not even considered as an issue.

Worse, the new document makes it clear that the various projects can be implemented piecemeal, subject to individual business cases: “the funding and delivery of key interventions would require extensive further investigations of delivery constraints, evaluation of value for money and a funding plan” (Section 1.3, page 18). While this may not be the intention of the authors, the result might be that implementation focussed solely on certain elements of the strategy, for example the highway schemes, which are within the competency of a single agency.

4. Chapter 2 – Understanding the Transport Issues, Opportunities and Challenges

 A missing opportunity in this section is the planning of development to promote sustainable travel. Sprawling, low density suburban development is difficult to serve effectively by public transport and reinforces car-based patterns of travel. Conversely, focussing development within urban centres and around key public transport nodes encourages a shift to more sustainable transport modes and reduces the need to make use of motorised transport. Clearly SEMMMS is not a land use strategy, but this wider opportunity should be highlighted, especially given the laudable ambition to bring land use and transport strategy closer together.

The document asserts that “there is increasing highway congestion, especially on the main strategic corridors”, but does not provide evidence to support this. Data on current journey speeds on the A6 and A34 are provided and these show – unsurprisingly – that speeds are higher overnight than at peak times. The value of this comparison is limited as it would be unrealistic to expect constant journey speeds at all times. There is no comparison with previous years to support the statement that congestion is increasing. Examination of the Department for Transport’s traffic count database suggests some increases in traffic flow since the previous strategy was completed, but also significant falls. Some examples are given below for A6 and A34. These do not support the general statement above.

 

Traffic Flow at Selected Sites on A6 and A34 (Annual Average Daily Flow)

Site	Flow (2001)	Flow (2016)	Change (%)
A6 (south of Manchester boundary)	28931	23523	-19
A6 (Stockport centre)	33702	23186	-31
A6 (Stepping Hill)	40919	34107	-17
A6 (north of A523 junction)	35886	30893	-14
A6 (High Lane)	23093	23432	+1
A34 (north of M60)	40299	33092	-18
A34 (south of M60)	62024	68773	+9
A34 (Stanley Green)	46251	48903	+6

 

Overall, the DfT database shows a 4% reduction in traffic flows across all the A road count sites in Stockport Borough. This is consistent with national trends. This should be seen in the context of the, rightly identified, increase in crowding on the rail network and of government policy which has held down fuel prices since 2010, while increasing regulated rail fares above CPI inflation rates.

5. Chapter 3 – Planning for the Future

The document rightly notes the close linkage between transport and land use strategy, recognising the possible need to revise the SEMMMS Refresh proposals, once the revised Greater Manchester Spatial Framework becomes available. As noted in the document, this is likely to result in more emphasis on development in town centres and on brownfield sites. Given the scale of development anticipated in Greater Manchester by 2040, this could significantly affect travel patterns with consequent impacts on the strategy. Accordingly, SEMMMS Refresh should not reach definitive conclusions before the land use strategy is more clearly defined. It would certainly be wrong to assume the land use allocations in the previous draft GMSF.

In relation to Manchester Airport, the document adopts a “predict and provide” approach to airport growth without considering the environmental and social impacts of this level of increase in air traffic.

The draft Strategy rightly notes that travel patterns are changing and new technologies may impact on future demand. However, it does not appear that adequate account has been taken of changes that are already occurring, as noted by the recent report of the Commission on Travel Demand. This report notes that “we travel substantially less today, per head of population, than we did one or two decades ago. We make 16% fewer trips than 1996, travel 10% fewer miles than in 2002 and spend 22 hours less travelling than we did a decade ago. This was not anticipated. It is not fully explained by our current models. Our assessment is that it is a combination of longer-term societal shifts in activities such as how we work and how we shop, changing demographics, shifts in income across the population as well as policies in the transport sector which have encouraged urbanisation. The recession has played a part as has the shift to mobile internet and other advances in information and communication technologies. However, the trends predate both of these. The outcomes are not a ‘blip’ from a one off event.” These changes may explain the reduction in road traffic flows noted above.

6. Chapter 4 – Vision and Objectives

 The Vision, Objectives and Key Actions documented in this chapter are not unreasonable but, in applying them, it will be necessary to consider how to address interventions that perform well on some criteria, but poorly on others. It is also important to consider how to apply the Key Actions. For example, there are a range of possible interventions that could be presented as assisting in “tackling congestion and improving journey time reliability.” These could range from highway improvements (though these could ultimately be self-defeating) to public transport investment or behavioural change initiatives.

7. Chapter 5 – Developing the Interventions

 The document sets out a series of alternative approaches to developing packages of interventions:

• Enhanced highways;
• Enhanced sustainable transport;
• Focus on technology and innovation; and
• Balanced multi-modal.

The first of these is rightly dismissed as being unsustainable and the third as being too uncertain. The “balanced” approach is favoured over a focus on enhanced sustainable transport on the basis that “there are limitations on how far the public transport system can be advanced to meet the needs of the population, particularly in more rural areas.” There is no evidence provided to support this assertion, especially as the majority of the problems that need to be tackled are not in “more rural areas”. In any event the term “balanced” is not defined and is value laden – nobody would want to support an “unbalanced” strategy. It appears that the term is used to mean a strategy that contains a number of interventions relating to each mode, rather than a strategy which seeks to achieve the best balance between the various objectives set out in Chapter 4, which might be significantly different.

It appears that the modelling undertaken during the development of the strategy was fundamentally inadequate. The adopted modelling tool appears to have been a SATURN highway assignment model. This is an appropriate tool for analysing how existing, or forecast future, road traffic would switch between routes and how journeys would become faster or slower as a result of interventions that affect the road network. The model cannot assess how transport interventions would result in changes in:

• The number of trips made;
• Time of travel;
• The origins and destinations of journeys; or
• Transfer between travel modes.

Future changes in travel patterns due to changing behaviour, land use development, car ownership and other factors can only be considered through external modifications to the trip matrix. Similarly, the impact of public transport, walking and cycling schemes or policies to encourage behavioural change are only assessed in terms of the effects of changes to the highway network on vehicle routeing. Any assessment of modal transfer would be by a judgement-based change to the vehicle matrix.

As such SATURN is a completely inappropriate and inadequate tool for the development of a multi-modal transport strategy, and no confidence can be placed on results from the modelling for the purpose of strategy development.

Recognition of this is implicit in the choice of highway demand forecasting scenarios, with one scenario reflecting the assumed impact of sustainable transport measures (and this is made explicit in Appendix C). However, in the absence of an adequate modelling tool, there can be no confidence that these impacts are assessed reliably and therefore that the most appropriate schemes are included in the strategy. There is also a concern that the Reference Scenario (from which the Mode Shift Scenario is derived) may not reflect recent trends in travel demand, as discussed above.

While the early sifting of possible options is described, the document does not discuss the overall appraisal of the options to create the overall strategy. As a result it is not clear that the recommendations represent a coherent approach to meeting the area’s current and future transport problems and are not simply a wish list of projects.

8. Chapter 6 – Recommended Interventions

Many of the interventions proposed in this chapter would deliver significant benefits and are welcome.

The main area of concern relates to Strategic Priority 7, which advocates construction of the A6 to M60 Link Road and the A6 Disley and High Lane Bypass. These projects are unacceptable for the following reasons:

1. They would have severe environmental impacts in the Lower Goyt Valley, in Offerton and on the outskirts of High Lane and Disley. Previous assessments of the Disley and High Lane Bypass in the 1980s did not find an option with acceptable impacts on the natural and built environments.
2. They would result in modal transfer from rail to road, undermining the viability of the desirable public transport investments proposed in the A6 corridor and creating extra traffic on other roads.
3. They would result in induced traffic, with negative impacts on local roads connecting to the new links and pressure for further schemes to relieve New Mills and communities further south.
4. They would encourage the early development of sites close to the new road, contradicting Stockport Council’s “Town Centre First” approach to development. In the longer term it would encourage car dependency and the development of car dependant sites.
5. As noted, the M60 is congested and the A6 – M60 Link Road would become a new strategic route to Manchester Airport and the M56 in conjunction with the A6 – MARR project. While traffic on A roads in Stockport has fallen since 2001, the DfT count data shows an 18% increase in traffic on the motorway network in the Borough. Inevitably a significant proportion of this traffic would divert to the new link road. This would (a) result in congestion at junctions and constrain the ability of local residents to access the new road (b) have noise and air quality impacts along the route and (c) result in induced traffic on the M60 to fill up the released capacity.
6. In the short term there might be some local air quality improvements, but extra traffic would create new air quality hot spots; assuming the development of low emission vehicles had not alleviated the current problem locations in any case.
7. At an estimated (possibly underestimated) cost of £477 million for the A6 to M60 Link and a perhaps similar order of cost for the Disley and High Lane Bypass, these schemes would be likely to take most of the funding available for transport improvements in the study area for the foreseeable future. Accordingly they would preclude implementation of many of the other proposed, and highly desirable, interventions.

The Strategy does advocate measures to lock in the released capacity on the A6 through public transport priority, cycling schemes and measures to make the road more pedestrian-friendly. However the business case work for the A6 – M60 Link Road does not include these measures so there is no certainty that they would be delivered before induced traffic filled up the released highway capacity, or at all.

While Strategic Priority 7 is the main area of concern, there are a number of other issues with the proposals, as noted below.

The introduction to this Chapter recognises that the overall benefits of the strategy will only be achieved if it is implemented in full, but there is no consideration of the challenges involved in achieving this in practice. These include divided responsibilities and the scale of funding required.

The BRT routes proposed in SP2 appear to be appropriate, but they will only be effective if a comprehensive approach is taken to their planning and delivery including:

• Bus priority and sections of off-road busway;
• High quality stops with good access to surrounding land uses;
• High quality vehicles;
• Excellent information provision and branding; and
• Staff customer service training.

All of these are critical to the success of the proposed routes.

While these routes would make a valuable contribution to meeting travel needs to the airport and along the A34, they are much more limited than the bus routes recommended for improvement in the 2001 strategy and, in particular, they would do little to improve bus access to Stockport.

The document is weak on potential rail improvements and focuses mainly on new stations and potential station improvements. While desirable, these would not be sufficient to deliver the step change in rail use needed to contribute to a more sustainable future transport network. Higher frequency and additional capacity are needed, together with greater reliability and better trains. Results should be available from TfGM’s South East Manchester Rail Study to inform the strategy for much of the SEMMMS area. It is important that TfGM’s findings are set in a multi-modal context to demonstrate their overall contribution.

9. Chapter 7 – Early Priorities

The general approach advocated in this Chapter appears reasonable, although there seems to be an undue emphasis on on-line highway schemes for early implementation. Logically, most of the major investment projects will take longer to bring forward. In relation to the A6 – M60 Link and the A6 Disley and High Lane Bypass, the issue is not so much one of timing, but of the proposal to take them forward at all.

10. Chapter 8 – Delivering the Strategy

 This is perhaps the weakest Chapter of the document. It does not provide any indication of how implementation of the strategy could be funded, beyond giving a list of current funding streams. It is not at all clear how much might be available from each of these for the partner authorities and in what timescales.

A bigger concern is the proposal that the implementation of the strategy should be taken forward by Cheshire East and Stockport Councils. As highway authorities, they have a clear remit and powers to take forward highway projects together with walking and cycling schemes. They have little ability to promote public transport investment. Although they propose to work with a long list of partner organisations who do have the relevant powers and funding, these agencies will not be co-owners of the strategy and there is no certainty that the proposals in the strategy will match their own priorities. Accordingly it is very likely that the highway proposals will be taken forward swiftly, while the rail, bus and tram-train ones are not. This would result in a primarily highway-based investment strategy, albeit with a multi-modal ‘greenwash’. A much more credible approach would be to establish a Programme Board comprising Cheshire East and Stockport Councils together with – at least – TfGM, Transport for the North and DfT. This would be charged with the delivery of the overall strategy.