Wiltshire County Council had to put up a Major Scheme Business Case for the Department for Transport.
Little publicised, but it was also open to public comment.  Here is an edited selection of input to the DfT.

In this MSBC, Wiltshire (County) Council persistently presents a creative overview, aligned to WC's case, which is not well supported by independent documentation.  Wiltshire Council is rather sloppy about facts.

It says: 'the A350 is a national primary route which connects Junction 17 of the M4 to the Bournemouth / Poole conurbation and the port of Poole...'   But the A350 is not actually a viable main road between the M4 and Bournemouth & Poole, because of topographic restrictions to HGVs between Shaftesbury and Blandford, which are irresolvable without further major road construction schemes.

Wiltshire Council's MSBC mentions the potential road-to-rail freight terminal, which is planned to be adjacent to the existing Westbury railway station, but the eastern route proposed by W(C)C for its Westbury Bypass does not go to (or near) the station and is on the wrong side of the town.

Westbury station is a national railway hub.  Despite W(C)C's words, improved access to the railway station and future rail freight terminal is left out of the proposals in this MSBC, fundamentally because the eastern bypass route is wholly unsuitable.  Almost all manufacturing in Westbury is on the western side of the town, where the railway station is.  Wiltshire (County) Council wants to build a new road on the rural eastern side.

Nearby communities in West Wiltshire, such as Southwick, have more HGVs passing through than Westbury.  These local communities would suffer from further HGVs passing through were Wiltshire (County) Council's proposed Westbury Bypass scheme to be approved.

The Westbury Trading Estates and the envisaged Westbury Intermodal Freight Terminal are on the western side of Westbury, whereas WCC’s proposed road scheme is on the east.  To appear to get around this, Wiltshire (County) Council also proposes a 'Glenmore Link', which would be in effect a further road over to the west from the proposed eastern A350 bypass.   However, this Glenmore Link would only serve the West Wilts Trading Estate.  The other Westbury trading estates (such as the rapidly-growing Northacre Park), the railway station and the proposed inter-modal freight terminal would not be served by W(C)C’s proposals.

W(C)C’s business case is observably biased towards considerations applying within the town of Westbury, rather than considering Westbury and the surrounding area as a whole.

Wiltshire Council’s Westbury Bypass scheme as proposed would increase overall carbon equivalent emission to our atmosphere (as discreetly confirmed by Wiltshire Council’s latest revised data for the Inspectors).

Wiltshire Council is very unlikely to develop a 'comprehensive cycle network' as claimed in its MSBC.  Many roads here in West Wiltshire, under Wiltshire (County) Council's care, are relatively risky for bicycle riders, due to poor maintenance (eg: dangerous potholes) and so-called cycle ways which do not interconnect.

Wiltshire County Council has consistently omitted the results of its last public opinion survey, held in 2001, where 75% of the local people participating did not want an eastern bypass (and did not want a Westbury bypass which could be anywhere) but asked for a western route.  The unpopularity of the eastern option was one of the reasons for the district plan inspector recommending against safeguarding of the eastern Westbury bypass route.   Most Westbury people are against the eastern bypass scheme.    At the Inquiry, in 2008, there were twice as many local residents voicing their objections as those who wanted a bypass.

WCC's MSBC statement that 'the DfT confirmed in December 2006... that they anticipate funding the A350 Westbury Bypass in the next three years...' is not supported by any documentation from the DfT.  Wiltshire County Council highways engineers put up the claim: 'Dft letter Dec 2006, 'Anticipate funding in 3 years'' in a January 2007 presentation to objectors.   It was queried if it was factual.  Enquiries confirmed that there is no such December 2006 DfT letter.  After further querying, a WCC highways officer acknowledged that 'it might be an error'.   There is no letter in which the DfT says that it anticipates funding a Westbury Bypass.   The correspondence is actually heavily qualified.   But a non-existent December 2006 DfT letter or commitment or confirmation etc still seems to be regularly referred to by our Wiltshire Council.

WC's proposed eastern Westbury bypass would not significantly improve journey reliability along the A350, because the existing times to travel through Westbury do not vary greatly, whereas the worst local A350 congestion is actually in the Yarnbrook and West Ashton area, where the hold-ups can be prolonged.  The eastern Westbury bypass scheme proposed in W(C)C's MSBC would worsen this unresolved A350 bottleneck.

It might be noted that estimated A350 journey time saving for the eastern bypass scheme is just 2 minutes. There are 20 minute delays on the A350 at Yarnbrook.  W(C)C's proposed Eastern Westbury Bypass scheme would not resolve them.   The Far Western route would.    The proposed Eastern Westbury Bypass scheme cannot improve accessibility to the proposed intermodal freight terminal at Westbury.  The eastern bypass route is unsuitable.   The Eastern Westbury Bypass with Glenmore Link might improve accessibility for HGVs to the West Wilts Trading Estate, though not to the other Westbury trading estates or the railway station or the future freight terminal.  The far western route, by the railway and the trading estates, is well suited.

Inclusive of W(C)C’s own information, it is recognised that the alternative Far Western route would improve traffic flow across the area - without making some local conditions worse.  The Far Western to Standerwick option would be superior overall for reducing HGV flow in Westbury and the surrounding area.  Other data shows that an Eastern bypass around Westbury would much increase the HGV flow in the surrounding area.

This MSBC does not highlight the proposed 0.5km of new access road to the run down cement works (no longer operational and since closed), which would mean more public expense not serving a useful purpose.

W(C)C's consultants originally estimated the Far Western route to be of lower cost than the Eastern route.

W(C)C has not made a fair comparison between its preferred eastern Westbury bypass and the alternative western route.   Unsubstantiated extra works to the A36 and in Somerset are loaded on the western route, whereas comparative works (such as more bypasses) to relieve the obvious traffic congestion at Yarnbrook and West Ashton are not associated (as they should be, eg: cost) with the WCC eastern bypass scheme.

In its comparison of Eastern and Western route costs, it seems to be assumed by WCC or its consultants and partners that the terrain on the west is as varied as the escarpment landscape of the eastern route and that the far western route is longer.   The terrain that the far western route would pass through is observably easier.  And when all of the new road construction (with realignments and new cement works access road) of the eastern bypass scheme is taken into account it is found that it is actually about 7km. The far western route (complete with a Yarnbrook bypass also) is a similar 7km overall length of new road.

An estimate of the far western route cost by another independent objector showed, without contradiction, that the alternative far western route would actually be less costly than WCC’s preferred eastern bypass.

The South West Regional Assembly agreed particular Bristol/Bath to South Coast Study recommendations, which did not include an A350 Westbury Bypass.   The SWRA minutes show that A350 improvement and a Westbury bypass were discussed, but that neither were included in the agreed-to BBSCS recommendations.

Yet this MSBC says that 'the Westbury Eastern Bypass Scheme has received endorsement and support from regional bodies such as the South West Regional Assembly'.   It says 'statements of support for the scheme from regional bodies are included in Appendix C.'   But when we look in this Appendix C, there is only a single letter, from an officer at the SWRA.    It does not contain endorsement or support for the Westbury Eastern Bypass scheme.   'Eastern' does not appear at all within this letter.   The only link is the planning application number.    Also, this letter seems to be just this one officer’s opinion that the proposal complies with certain regional policies.  This officer's letter does not identify the policies which the Eastern A350 Westbury Bypass scheme does not comply with.  Clearly they exist.  Many were identified at the Planning Inquiry.  This SWRA officer's two-page letter refers to natural environmental issues within just one sentence.  Anyway, the Draft RSS that the officer’s letter largely relies upon has been superseded by the subsequent RSS EiP Panel report and Government review.   As pointed out..., the minutes of the 30 April 2004 South West Regional Assembly show that the SWRA agreed to particular recommendations which did not include an A350 Westbury Bypass - on a recorded vote of the South West Regional Assembly itself.

The South West Regional Assembly 'position' quoted in WCC's business case, that 'it is therefore considered that overall the proposal is in general conformity with the RSS' is the same letter from a single SWRA officer (not the Assembly) as also quoted in this MSBC as an 'endorsement' by the South West Regional Assembly. Neither claim is right.   The over-quoted SWRA officer letter commented on some considerations from one viewpoint only.  And, as we know, the draft RSS referred to is being superseded by a new, different, RSS.

Even from Wiltshire Council’s descriptions in its business case, it may be appreciated that many proposed structures along the eastern A350 bypass route through presently unspoiled lovely countryside would be large, disproportionate and unsightly.   Bat gantries would be 7 metres high (and over 20 metres across).

A proposed equestrian crossing for a bridle-way is intended to be an at-grade access onto the new road.
It would be an all-round hazard in the future (or force disuse of the right-of-way).

The supposition that areas of the Wellhead Valley, all of which is the aquifer (ie:water source), which are outside of the Source Protection Zone, such as at the former Bere's Mere Farm, do not need impermeable protection against toxic or water-contaminant spillage off the new road is not credible, because the whole of the sub-strata within the valley is permeable ground (chalk or sand) so any spillage outside the SPZ but within the valley would leach through.  The simple fact was presented within a proof at the Planning Inquiry, without contradiction.    There are no adequate safeguards proposed in the Eastern A350 Westbury Bypass scheme which would prevent a heavy vehicle carrying a contaminating liquid load coming off the new road as a consequence of an accident and causing catastrophic pollution of the public water source.

Wiltshire County Council does not appear to have said much about its proposed weight limit on the railway over-bridge at Station Road, which would force HGVs to use WCC’s bypass and upon which some of WCC's calculated traffic flow justification figures rely.  This bridge is currently carrying any weight of heavy goods vehicles and could anyway simply be strengthened.   In this MSBC there is also a description of a proposed pedestrian/cycle way which, rather than just be extended from the side of the bridge as is commonly done, would cause this same railway over-bridge at Station Road to be narrowed down to 3.6m.  This is another intended contrivance that, on the basis of HGVs being impeded from using the normal route to the station and the trading estates through Station Road, has been taken into account to slant justification figures associated with the Eastern Bypass scheme.

A table in WCC's MSBC provides an example of how the forecast HGV flow figures are slanted.   It can be seen how the Eastern Bypass is forecast to achieve a 96% reduction of HGVs through Station Road.   But, this is done by incorporating restrictions on HGVs using Station Road, in the way described above.  WCC’s table of forecast HGV flows does not show the same reduction in HGVs through Station Road for the Far Western Bypass (though the effect of the restrictions would be the same for the supposedly comparative routes).  The Inquiry Inspectors noted this slanted disparity in the presentation of the HGV traffic figures.

However, despite the unfair slanting, the Far Western Bypass would provide a superior balance of HGV flow reduction through residential areas.  Reductions through Westbury are comparable (especially if the relative Station Road HGV flow is equalised), whilst nearby community Southwick (presently having over twice the HGVs of Westbury) would benefit from large reductions of HGV flow.  Note that an Eastern Bypass would increase the number of HGVs going through Southwick (already with over twice the HGVs of Westbury).

Comparisons of the benefits of the alternative Far Western route have not been shown fairly by Wilts County Council in many ways.  Another example is the predominant presentation of A350 journeys and down-play of journeys also using the A361 and A36.  Yet there is the £7M WCC guess estimate for A36 improvements with a far western route, which has been presented without justification or corroboration.  Some different stories associated with W(C)C’s £7M for A36 works have been observed over the years..., originally for an avoidance of rat-running through the village of Berkley (though there are hardly any homes on the road), then, later, as heard at the end of the Planning Inquiry, a suggestion that the £7M cost claim had come from the Highways Agency, which, when enquired after, also turned out to be unsubstantiated...

Wiltshire County Council has not properly or fully evaluated relative consequences.  WCC's eastern bypass route passes fairly close to two Sites of Special Scientific Interest, right through the middle of the Special Landscape Area, over the Wellhead Valley Aquifer and over the public Water Source Protection Zone.  The alternative western route is not close to comparable environmentally sensitive areas.   It would follow the railway line for much of its length and need go near no homes.  These factual comparisons are in contrast to the table in the MSBC whose summary has been slanted to support the chosen eastern bypass scheme.  The eastern Westbury bypass route poses a risk of catastrophic contamination of the public water source, the measures proposed are inadequate or insufficiently comprehensive - yet significance is called 'neutral'.  By the designers who are W(C)C’s partners in the scheme.   The Far Western route is longer for particular A350 journeys presented by WCC.  The Far Western comparative scheme includes a bypass at Yarnbrook, where hold-ups can presently be of long duration.  The comparative atmospheric gas emissions of the far western route - which would bypass congested Yarnbrook, as well as Westbury - would probably be less than the eastern scheme.   The far western route would also provide shorter distances for many journeys for HGVs etc, eg: to/from the Westbury trading estates etc, so is better overall than the eastern scheme.

A later table in this MSBC actually shows that the cost benefit analysis net value of the far western route compares quite well with the eastern bypass scheme, even though factors have been unfairly slanted (as the examples noticed and pointed out) to disfavour the far western route.  On a genuine like-for-like basis the comparative alternative far western route would come top.

As widely recognised, although barely referred to by Wiltshire County Council, the historic preference of the Westbury area public has been for a route to the west.  Wiltshire County Council was wearing this down, by consistently repeating that it had to be an 'eastern bypass or nothing'.  For a far western route that follows the railway line and avoids going close to any homes, it is misleading to invoke significant public opposition from areas to the west of the town (which did not feature in the last opinion survey or quantity of letters).

The summary of objection and support presented by Wiltshire Council, in an item on public consultation, does not fairly reflect the actual scale of objection to the eastern Westbury bypass scheme.  There were over ten times as many individual letters of objection to the eastern bypass scheme as there are equivalent letters of actual support for this scheme.  WC was adding, as if equivalent support for its eastern bypass, planning application referenced forms asking for traffic relief for Westbury and the surrounding area.
Wiltshire Council's eastern Westbury bypass scheme would make traffic worse in the surrounding area.

WC’s Westbury Bypass scheme cost seems to be generally stated to be about £33M.  But final cost would be at least £38M, which is corroborated in a table of this MSBC.  The uplift on £33M is in the Optimism Bias 15% sum, which is required by the DfT and is in other words the traditional contingency sum for build cost over-run, which cannot be left out.  Back in 2004, the Bristol/Bath to South Coast Study consultants were told £14.4M.  The stated cost became £33M by 2007.  There is a record of under-presentation of the cost.

To try to deliver all of WC’s scheme objectives in one project would involve adding the cost of Yarnbrook and West Ashton bypasses to the cost of WC’s eastern Westbury bypass.  Yarnbrook and West Ashton highway improvement in WC's new 'expression of interest' to the SWRA is estimated by WCC at £17M.
So a fairer cost for Wiltshire Council's stated objectives is £38M + £17M = £55M.

And all of this money for a non-integrated road scheme which would not really work.

There is no overriding justification or a genuine business case for WC’s Westbury Bypass.

For a high cost, it would be a bypass of one town which would worsen congestion elsewhere.

Despite Westbury being a major railway hub, this road would have no public transport interface.

The eastern bypass is a Wiltshire Council vanity scheme, which does not deserve public funding.