|Wiltshire Council's Implausible Bypass Business Case|
Wiltshire (County) Council concocted a 'Major Scheme Business Case' for Department for Transport funding. Failure to obtain planning permission means that there will never be funding for a Westbury Bypass scheme. However, here is an edited selection of previous input to the DfT about W(C)C's unbelievable business case.
Between initiation and failure of the project, Wiltshire County Council changed its name to Wiltshire Council.
In its MSBC, Wiltshire (County) Council has persistently presented a creative version, aligned to its views, which is not well supported by independent documentation or facts associated with WC's bypass scheme.
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 yet further major road construction schemes (also through fine countryside).
Wiltshire Council's MSBC mentions the potential road-to-rail freight terminal, that is planned to be adjacent to the existing Westbury railway station, but the eastern route proposed by W(C)C for its Westbury Bypass did not go to (or near) the railway station and was 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 was left out of the proposals in W(C)C's MSBC, basically 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 wanted 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 since-failed Eastern Westbury Bypass project to have been approved.
The Westbury Trading Estates and proposed Westbury Intermodal Freight Terminal are on the western side of Westbury, whereas WCCís proposed road scheme was on the east. To seem to get around this, Wiltshire (County) Council also proposed the 'Glenmore Link', which would have been a further road over to the west from the proposed Eastern A350 Bypass. But, this Glenmore Link would have only served the West Wilts Trading Estate. The other Westbury trading estates (such as the big and rapidly-growing Northacre Park), the railway station and the inter-modal freight terminal would not have been served by W(C)Cís proposals.
W(C)Cís business case was observably biased towards considerations applying within the town of Westbury, rather than considering Westbury and the surrounding area as a whole.
Wiltshire Councilís eastern Westbury Bypass plan would have increased overall carbon equivalent emissions to our atmosphere (as discreetly confirmed by Wiltshire Councilís 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 consistently omitted the outcome 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 were 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 said that it anticipated funding a Westbury Bypass. Despite knowing this, Wiltshire Council repeated its misleading version before Westbury Town Council. DfT correspondence is actually heavily qualified. But a non-existent December 2006 DfT letter or confirmation or 'commitment' or 'promise' or 'half-promise' or 'indication' still seems to be referred to by Wiltshire Council.
WC's proposed eastern Westbury bypass would not have much improved 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 WC's MSBC would have worsened this real A350 bottleneck.
It may 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 failed Eastern Westbury Bypass project would not have resolved them. The Far Western route would. The Eastern Westbury Bypass scheme could not have improved accessibility to the proposed intermodal freight terminal at Westbury. The eastern bypass route is unsuitable. The Eastern Westbury Bypass with Glenmore Link might have improved access for HGVs to the West Wilts Trading Estate, though not to the other Westbury trading estates or the railway station or the freight terminal. The far western route, by the railway and the trading estates, is well suited.
Inclusive of W(C)Cís own information, it is recognised that the alternative Far Western route could 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 in the surrounding area. Data shows that the eastern route around Westbury would have greatly increased the HGV flow in the surrounding area.
W(C)Cís MSBC did not highlight the proposed 0.5km of new access road to the now run down cement works (a feature of the eastern route) which would have meant more public money not serving a useful purpose.
W(C)C's consultants initially estimated the Far Western route to be of lower cost than the Eastern route.
W(C)C had not made a fair comparison between its preferred eastern Westbury bypass and the alternative western route. Unsubstantiated extra works for the A36 and Somerset were loaded on the western route, whereas comparative works (such as more bypasses) to relieve the obvious traffic congestion at Yarnbrook and West Ashton were not associated (as they should have been) with the W(C)C eastern bypass scheme.
In its comparison of Eastern and Western route costs, it seemed 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 WCCís 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 said 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 officerís 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 officerís letter mainly relied upon had 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 has now been superseded.
Even from Wiltshire Councilís descriptions in its business case, it may be appreciated that many proposed structures along the eastern A350 bypass route through presently unspoiled countryside were to be large, disproportionate and unsightly. Bat gantries would have been 7 metres high (and over 20 metres across).
A proposed equestrian crossing for a bridleway was intended to be an at-grade access onto the new road and would have been an all-round hazard in the future (or would have forced 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, did 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 were 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 (or loss) of the public water source.
Wiltshire County Council did not seem to have said much about its weight limit on the railway over-bridge, at Station Road, which was intended to compel HGVs to use WCCís bypass and upon which some of WCC's calculated traffic flow justification figures relied. This bridge has been 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 was 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, had been taken into account to slant justification figures.
A table in WCC's MSBC is an example of how the forecast HGV flow figures were slanted. It was shown how the Eastern Bypass was forecast to achieve a 96% reduction of HGVs through Station Road. But it was done by incorporating restrictions on HGVs using Station Road, in the manner described above. WCCís table of forecast HGV flows for the Far Western Bypass did not show the same reduction in HGVs through Station Road. Yet the effect of the restrictions would be the same for the ostensibly comparative routes. The Inquiry Inspectors noted this blatantly-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 very large reductions of HGV flow. An Eastern Bypass would have increased 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 had not been shown fairly by Wiltshire 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 had been presented without justification or corroboration. Some different stories associated with W(C)Cís £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, the suggestion that the £7M upgrade requirement had come from the Highways Agency, which, when enquired after, also turned out to be unsubstantiated.
Wiltshire County Council had not fully or fairly evaluated relative consequences. W(C)C's Eastern Bypass route passed 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 had been slanted to support the chosen eastern bypass scheme. The eastern Westbury bypass route posed a risk of catastrophic contamination of the public water source, the measures proposed were inadequate or insufficiently comprehensive, yet significance is called 'neutral'. By the designers who were WCCís partners in the scheme.   The Far Western route is longer for particular A350 journeys presented by WCC. But the 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 had been blatantly slanted (as the examples noticed and pointed out) to disfavour the western route. On a genuine like-for-like basis, the comparative alternative far western route would have obviously come out as easily the best choice.
As widely recognised, though 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 peristently repeating that it had to be an 'eastern bypass or nothing'. For a western route which follows the railway line and avoids going close to any homes, it was misleading to claim significant public opposition from areas to the west of the town (that 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 in, as if equivalent support for its eastern bypass, planning application referenced forms which asked for traffic relief for Westbury and the surrounding area. WC's eastern Westbury bypass scheme would have caused increased traffic through the surrounding area.
The Westbury Bypass project cost is generally stated to be about £33M. But gross cost would have been at least £38M, as was found within a table of this MSBC. The uplift on £33M is the 15% Optimism Bias 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. In 2004, the Bristol/Bath to South Coast Study consultants were told £14.4M. By 2007, the cost became £33M+! There is a history of under-presentation of the cost of this scheme.
To try to deliver all of WCís scheme objectives in one project would involve adding the cost of Yarnbrook and West Ashton
bypasses to the cost of WCís eastern Westbury bypass. Yarnbrook and West Ashton highway improvement in WC's new
'expression of interest' to the SWRA was estimated by WC at £17M.
And all of this money for a non-integrated road project which would not have really worked.
There was no sound justification nor a genuine business case for WCís Westbury Bypass scheme.
It would have been a costly bypass of one town, which would have worsened congestion elsewhere.
Despite Westbury being a major railway hub, this road was to provide no public transport interface.
The eastern bypass was a Wiltshire Council vanity project, which did not deserve public funding.
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