A303 Stonehenge Scheme Public Consultation: Environmental Data

A Shuttleworth made this Freedom of Information request to Highways England Company Limited

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was refused by Highways England Company Limited.

Dear Highways England Company Limited,

As part of the A303 Stonehenge Scheme Public Consultation process, Highways England has published a Technical Appraisal Report with several Appendices which are meant to provide sufficient technical detail to defend their recommendations for routes, etc. This is a formal request for information (RFI) to supplement informal requests made of the Public Consultation team.

TAR Appendix D is meant to provide environmental information that should justify one route or another or demonstrate no difference in the environmental impact of the two routes. It contains, at best, a few bald contentions, with no underpinning data, details of methodologies or references to support these contentions. For example, para 2.2.65 of Appendix D states:

"A noise analysis was carried out to identify potential changes as a result of the scheme. This was compared to current census data to assess the impact on nearby vulnerable groups. At this stage, the assessment considered changes to the route location along with changes in traffic flow as a result of the scheme.”

The output of this assessment is given in para 3.7.3:

"All options within Corridor D are classed as Moderate Beneficial, as these alignments would remove through traffic from Winterbourne Stoke and noise impacts on this section of the A303. Concentrations of children who would be particularly impacted by these changes have been identified in impacted areas for all alignments".

Para 2.2.66 of Annex D says very much the same in terms of Air Quality:

"An air quality analysis was carried out to identify potential changes as a result of the scheme. This was compared to current census data to assess the impact on vulnerable groups. At this stage, the assessment considered changes to the route location along with changes in traffic flow as a result of the scheme.”

With the assessment in para 3.7.4:

All options within Corridor D are classed as Moderate Beneficial, as these alignments would remove through traffic from Winterbourne Stoke and air quality impacts on this section of the A303. Concentrations of children who would be particularly impacted by these changes have been identified in impacted areas for all alignments.

There is too little detail of the science underpinning these assessments for anyone, but especially independent subject matter experts, to critically view the claims

As a bare minimum we wish to be made available:

1. The methodologies used for these analyses
2. Evidence for the verification and validation of the methodology by independent subject matter experts
3. The underpinning assumptions used in the analyses and their derivation.
4. All raw data sets and evidence of their date and place of origin.
5. Details of any modeling studies undertaken to estimate the likely noise and environmental pollution arising from each of the to bypass options.
6. Details of the Verification and Validation of these models.

This information is required to advise route selection of the northern and southern options for the Winterbourne Stoke bypass - by 5th March 2017

Yours faithfully,

A Shuttleworth

Highways England, Highways England Company Limited

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6. mailto:[Highways England request email]

A303Stonehenge, Highways England Company Limited

6 Attachments

Dear A Shuttleworth,

 

Please find attached the response to your FOI request.

 

Best regards

 

 

Andrew Alcorn

Project Manager for A303 Amesbury – Berwick Down

Major Projects Complex Infrastructure Programme

Highways England

Highways England | Temple Quay House | 2 The Square | Temple Quay |
Bristol | BS1 6HA

 

[1]cid:image003.png@01D26BFE.16C4B0E0 [2]@A303Stonehenge
[3]cid:image004.png@01D26BFE.16C4B0E0 [4]facebook.com/A303Stonehenge/
Website [5]www.highways.gov.uk/a303stonehenge/consultation

 

 

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Highways England Company Limited | General enquiries: 0300 123 5000
|National Traffic Operations Centre, 3 Ridgeway, Quinton Business Park,
Birmingham B32 1AF |
[6]https://www.gov.uk/government/organisati... |
[7][Highways England request email]

 

Registered in England and Wales no 9346363 | Registered Office: Bridge
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7. mailto:[Highways England request email]

Dear Highways England Company Limited,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Highways England Company Limited's handling of my FOI request 'A303 Stonehenge Scheme Public Consultation: Environmental Data'.

I believe Mr Alcorn has been somewhat creative in his responses and has rather ducked the issue. For instance, Question 2

2. Evidence for the verification and validation of the methodology by independent
subject matter experts
The methodologies used are prescribed government methodologies that are used by
Highways England for all such major road improvement schemes. They have been
developed over many years by subject matter experts and are kept under central
review. They are not verified/validated every time they are used on individual projects.
The approach we take as Highways England on each major project is to employ expert
leading consultants to carry out the work, in this case a joint venture of Atkins and Arup.
The work is controlled and quality assured both by our consultants and by checks within
Highways England.

The question did not ask if the methods are verified and validated every time they are used, but if they have EVER been independently verified and validated and if so, by whom and when. Routine use, is not evidence of independent verification and validation.

Question 3 asks:

3. The underpinning assumptions used in the analyses and their derivation
Mr Alcorn answered:

The underpinning assumptions are also set out in Chapter 18, Section 18.2 of the TAR,
with their derivation being consistent with the prescribed methodologies.

As Mr Alcorn well knows, section 18.2.1 makes mention of the CRTN, a model (call it a methodology if you will) that has been used. Mr Alcorn has not provided the underpinning assumptions requested, nor do they appear in section 18.2 of the TAR as claimed. These assumptions include such elements as:
Time period, percentage of HGV's, Gradients assumed, Type of road surface, source/receiver height differences, percentage of absorbent cover, average path height, angle of view, facade details and any other assumptions used by HE or its contractors to employ CRTN. The only information provided is vehicle number (Q4).

Question 5, the answer provided seems both disingenuous and cynical. The appraisal process is, by all common definitions, an output derived from the use of several models (ie CRTN and DMRB) indeed the WebTAG process is also a model. The answer provided is most misleading.

The A303 Stonehenge Scheme Public Consultation is meant to be an exercise in openness with the public. The very fact that this submission was necessary and that an internal review is now sought suggests strongly that the stated aims of the process has failed.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/a...

Yours faithfully,

A Shuttleworth

Highways England, Highways England Company Limited

This is an automated response:

 

Thank you for your email to Highways England.

 

If you are reporting a real time issue which requires immediate attention
please call the Customer Contact Centre on 0300 123 5000. 

 

A map of the roads for which we are responsible can be found here
[1]http://www.highways.gov.uk/publications/... If
the road you’re interested in isn’t on this map it will fall under the
jurisdiction of the local authority.  You can find details of local
authorities using the search facility on the gov.uk website
at: [2]https://www.gov.uk/find-your-local-council

 

If your email does relate to an issue on Highways England's network it
will be passed to the relevant team within Highways England and they will
respond to you within a maximum of 15 working days.

 

If you have made a request under the Freedom of Information Act your
request we will respond to you within a maximum of 20 working days. Your
request will be dealt with in line with government guidelines:
[3]https://www.gov.uk/make-a-freedom-of-inf...

 

 

To help us improve our service please click [4]here to complete a short
survey.

 

Kind Regards,

 

Highways England Customer Contact Centre.

This email may contain information which is confidential and is intended
only for use of the recipient/s named above. If you are not an intended
recipient, you are hereby notified that any copying, distribution,
disclosure, reliance upon or other use of the contents of this email is
strictly prohibited. If you have received this email in error, please
notify the sender and destroy it.

 

Highways England Company Limited | General enquiries: 0300 123 5000
|National Traffic Operations Centre, 3 Ridgeway, Quinton Business Park,
Birmingham B32 1AF |
[5]https://www.gov.uk/government/organisati... |
[6][Highways England request email]

 

Registered in England and Wales no 9346363 | Registered Office: Bridge
House, 1 Walnut Tree Close, Guildford, Surrey GU1 4LZ 

 

Consider the environment. Please don't print this e-mail unless you really
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References

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https://www.gov.uk/find-your-local-council
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6. mailto:[Highways England request email]

FOI Advice, Highways England Company Limited

Dear Mr Shuttleworth

I refer to your request for an internal review dated 14 February 2017.

I anticipate to have a response sent out to you by 24 March 2017. Please accept my apologies for the delay in providing you with an outcome of that review and any inconvenience caused.

Yours sincerely

Layla Beckett, Freedom of Information Officer
Highways England | Piccadilly Gate | Store Street | Manchester | M1 2WD
Web: http://www.highways.gov.uk

show quoted sections

FOI Advice, Highways England Company Limited

Our Ref 748285

Dear Mr Shuttleworth

I refer to your request for an internal review regarding the Environmental Data for the A303 Stonehenge Scheme.

As part of the internal review I have investigated whether the team that handled the initial response have complied with the Freedom of Information Act.

I note that your main reason for requesting a review is that "Mr Alcorn has been somewhat creative in his responses and has rather ducked the issue". You've also stated that the response to Q5 is "disingenuous and cynical"

I am sorry that you believe the information we have provided is insufficient. My investigation has concluded that a full explanation was provided and that we have disclosed all the information we hold in answer to your request. I also note from your comments, that the basis of your request for an internal review is that you disagree with the contents of our response. This unfortunately falls outside the scope of the Freedom of Information and/or the Environmental Information Regulations Act and therefore my view is that we have complied with Freedom of Information legislation

I understand that this may not be the outcome you expected. If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Yours sincerely

Layla Beckett, Freedom of Information Officer
Highways England | Piccadilly Gate | Store Street | Manchester | M1 2WD
Web: http://www.highways.gov.uk

show quoted sections

A Shuttleworth left an annotation ()

Highways England responded to the request for an internal review directly and not through the WhatDoTheyKnow Site. The response was as follows:

Dear Dr Shuttleworth
Freedom of Information request: predicted noise level data
I am writing to advise you that we do hold information that is relevant to your request of 29 January but regret to inform you of my decision not to disclose this information.
The information you requested is being withheld in reliance on the exemption in section 22 (http://www.legislation.gov.uk/ukpga/2000...) of the Freedom of Information Act 2000 because the information requested is intended for future publication in future stages of the scheme’s development.
In applying this exception we have had to balance the public interest in withholding the information against the public interest in disclosure. The key public interest factors in favour of disclosure included that it could generate a wider understanding of the overall impact of the scheme across the local community, it could support organisational transparency and could inform the public to understand how and what initial evaluations are done during the early stages of scheme development.

However the key public interest factors against disclosure were that information could be taken out of context or misunderstood if disclosed at this early stage of scheme development, that releasing the requested data could prejudice the next stage of engagement when more accurate data becomes available and that the information requested could be misrepresented in order to undermine the decision-making process.

If you are unhappy with the way we have handled your request you may ask for an internal review. Our internal review process is available at: https://www.gov.uk/government/organisati... procedure

If you require a print copy, please phone the Information Line on 0300 123 5000, or e- mail info@highwaysengland.co.uk. You should contact me if you wish to complain.
Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ
Highways England Company Limited registered in England and Wales number 09346363
Temple Quay House 2 The Square Temple Quay
Bristol BS1 6HA
22 March 2017

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
If you have any queries about this letter, please contact me. Please remember to quote reference number 747,683 in any future communications.

Yours sincerely
Derek Parody
Project Director for A303 Stonehenge
Major Projects Complex Infrastructure Programme