The elaborately spun web that is the business case for the Mersey Gateway Bridge, letter to Local Transport Today by Lillian Burns

in Local Transport Today, no. 549, 9 July - 22 July 2010

The North West Transport Roundtable, along with Friends of the Earth, were the principal objectors at the public inquiry into the Mersey Gateway Bridge. Our proofs of evidence, explanatory notes for the inspector and post inquiry correspondence are posted on the 'documents' page of this website, logged between April and August, 2009.

As of the beginning of August 2010, the inspector's recommendations following the inquiry and the government's reactions to them had still not been published. NW TAR were therefore somewhat taken aback when Local Transport Today carried a three-page illustrated feature article promoting Halton Borough Council's case for the bridge (LTT 449) without any balancing editorial presenting the case against it. We requested a feature article in response to give us a proper opportunity to explain our case but this was not granted. However, a point by point rebuttal letter by Lillian Burns, Convenor of the NW TAR, was carried in full in the following edition (LTT 550, 23 July - 5 August), along with a letter from Professor Alan Wenban-Smith, one of the two expert witnesses who appeared for the objectors at the inquiry who emphasised the weakness of the economic case for the bridge. Letters by Prof. Wenban-Smith on the failings of the transport appraisal system, instancing the Mersey Gateway Bridge case, have been carried in Local Transport Today and were used as the 'perspectives' page features on the NW TAR website in October 2009 and April 2010.

Dear Sir,

Letter to the Editor of Local Transport Today

Your last edition (LTT 549, 9-22 July) carried a three-page feature presenting Halton Borough Council's case for their Mersey Gateway Bridge scheme. Headed 'The Mersey Gateway Bridge project: still charging ahead?', it read as though the government had announced its official endorsement for the scheme following last year's public inquiry (it has not and the inspector's findings have yet to be published). I trust you will allow me a full reply.

The article included an off-hand dismissal by Halton's chief executive, David Parr, of the case mounted by environmental NGOs at the inquiry, implying they/ we were flummoxed by the Council's claim that the scheme would reduce CO2 emissions. This was far from the case. Our expert climate change witness, Keith Buchan, showed that, over the lifetime of the scheme, CO2 emissions would increase. He also highlighted flaws in Halton's traffic modelling. And Professor Alan Wenban-Smith clearly demonstrated how the economics case failed to stand up. Since the inquiry, he has frequently used the Mersey Gateway as a prime example of how the government's transport appraisal process is flawed and why it needs to change. LTT has carried three of his letters (and a feature article) on this subject (LTT 527, 541 and 549).

In addition, your journalist, Rik Thomas, reported the cost of the scheme as #431 m. because that is what is still, erroneously, stated on the Mersey Gateway website. Yet Steve Nicholson, the project director, estimated in his proof of evidence presented to the inquiry that the cost would be #604 m. - almost two thirds of a billion pounds.

At the inquiry, the principal (Rule 6) objectors were an alliance of the North West Transport Roundtable (NW TAR) and Friends of the Earth (FOE) who together presented a very laudable challenge to the promoter's case.

We contended then, and still maintain, that this scheme fails to meet key DFT appraisal criteria, the requirement in PPG 13 to reduce the need to travel and the requirements of the Climate Change Act and it was not arrived at as a result of alternatives having been exhaustively tested. Whilst it may produce an iconic new structure, all it would be in effect is more road capacity on stilts - and the stilts would have to be bored into what has been a chemical dumping ground for 150 years, just upstream from internationally designated sites. The potential 'price' to be paid for the structure, both in real economic terms and in social, health and environmental terms, is far too great and the returns are highly dubious.

In summary, the case we presented was as follows:

• The requirements of the Treasury Green Book and the DfT's appraisal guidance (webTAG) were not met insofar as a range of options for achieving local and national objectives was not generated and tested. There was thus no test of the proposal to build a new road bridge against a best performing alternative, so value for money could not be proved.
• The promoters did not come up with a realistic 'do minimum' case; it was - in effect - 'do nothing'. They did not, for instance, model the imposition of varying levels of tolls on the existing Silver Jubilee Bridge (SJB), some options for which could have included allowing for certain special and free concessions. We pointed out that income from such an initiative could fund better cycling and walking approaches to the SJB and indeed a very robust Sustainable Transport Strategy. (Halton B.C. belatedly put forward an extremely modest Sustainable Transport Strategy which was very roughly costed at #500, 000). Our approach to tolling, it should be emphasised, was a subtle one. We were mindful throughout that much of Halton has deprivation issues and we did not want to see local people disadvantaged, but we were merely making the point that simply tolling the existing bridge was not even tested - and there could be exemptions for local residents.
• The promoter's original economic case was based on the same broad level of tolls being applied on the new bridge and on the SJB as exist for the Mersey Tunnels and assumed that the tolls would be constant in real terms. (This despite the fact that the new bridge would be built and run by a concessionaire, whereas Halton B.C. own the SJB). Based on these assumptions, the new bridge would show only the tiniest profit before 2030 and virtually all the scheme's net benefits (98%) related to the period after then, though this later period was not modelled. However, this shaky economic model would be further jeopardised by the introduction of discounts which were only proposed during the inquiry but not quantified and therefore it was not possible to subject them to analysis. Also, we made the point that if discounts were introduced into the equation, this would not only postpone the point at which a concessionaire could show a net income but it would have the tendency to generate additional traffic and to dissipate any regeneration benefits.
• Earlier political claims that the new bridge would lead to thousands of jobs in Halton could not be justified. The Amion Wider Economic Impact Report and the promoter's economic witness could find only 1,233 new jobs including 98 directly associated with the bridge itself (ie. security, admin. and maintenance) and only 65 of these 98 jobs were expected to go to local people. That amounted to a total of 1,200 new jobs for Halton residents for an outlay of #604 m. - half a million pounds investment per job. Claims for wider regeneration across the sub-region were also over-stated.
• Virtually no regard was paid by the promoters to the Climate Change Act. The promoters claimed that CO2 emissions in the vicinity of the SJB would be reduced because of their proposal to 'de-link' the SJB to deter through traffic and to replace a traffic lane on it with facilities for walking and cycling. But, 'de-linking' consisted of nothing more than traffic choosing to exit a main carriageway at a junction and, whilst the SJB would be reduced by one lane in each direction, the new Mersey Gateway would add massive extra capacity amounting to six traffic lanes. The overall effect was that instead of the required (national) 19% reduction in carbon emissions between 2005 and 2020, there would be an increase of 26 - 27%.
• The promoter's Health Impact Assessment (HIA) failed to adopt the 'precautionary principle' approach recommended by Lancaster University, despite the potential the scheme would have for releasing toxic sediments. (The Widnes/ Runcorn area of the River Mersey has been the centre of a chemical industry dating back to the mid 19th century and, until recent laws preventing the practice, the river was used as the waste dumping ground for all the businesses on its banks). The HIA also failed to tackle air and noise pollution impacts on health.
• The Mersey Estuary is subjected to an excessively strong, daily tidal surge (hence the proposal for a tidal barrage) which reaches inland as far as Warrington. DEFRA's UK climate change projections predict the North West will experience an increase of 16% in average winter rainfall and their flood risk map shows Warrington as ranking 10th in the UK in terms of numbers of properties at significant risk of flooding, ie. a total of over six and a half thousand. The Mersey Gateway would be carried on support stanchions 33 ft. in diameter, but the cofferdams around them during construction would be 100 ft. across. The Alliance of NW TAR and FOE questioned the impacts this would have on the flow of the river and pointed to the rushed physical modelling exercise that had been carried out for the promoters by University College London. In summary, they admitted they were not happy with their own work, which was confined to one section only of the estuary, because of the time constraints on them. They also said that, in their opinion, the computational modelling carried out by the hydrologists, which covered the whole estuary, had limitations and could not readily reproduce the variability in channel form and what happens in nature. Bearing in mind that the estuary is classified by the Environment Agency as 'heavily modified', (the same rating as the Ship Canal), there is no margin of error for works to produce worse water quality and potential flooding impacts are a major concern.
• The Alliance demonstrated during the inquiry that the scheme did not comply with the Development Plan. The promoters did not argue with this. Nor could they argue with us pointing out that 'Smart Choices' had been ignored altogether or that the scheme decimated what little Green Belt Halton has in its central area. In compensation for the latter point, the promoters were offering a new riverside wildlife park, but when we asked why this could not be provided any way, there was no answer.

Much of our evidence is posted on the ' documents' page of the North West Transport Roundtable website (www.nwtar.org.uk), logged from March to August 2009 inc., ending with post inquiry correspondence that flags up decisions made after the inquiry that reduce the case for the scheme.

I concluded my closing statement at the inquiry with the following words, which I stand by: "This is not a robust project; it is an elaborately spun web which does not hang together and which falls apart on close inspection. It is not sound and it should not be endorsed".

Yours sincerely,

LILLIAN BURNS, Convenor, North West Transport Roundtable