Dear Highways England Company Limited,

Highways England stated (letter, 27th September 2019) that its Transport Planning Group’s Revised Traffic Forecasting Guidance of 7th January 2018 was prepared and issued without correspondence with the Department for Transport. That guidance was due to be updated as a result of a National Audit Office report to the Committee of Public Accounts whose recommendations were accepted by HM Treasury in October 2019, referenced below. That update - to provide a clearly defined approach to whole programmes of interacting projects - was due before April 2020.

I would like please to be provided with:
1. Copies of any replacement, update or variation to the guidance issued since 7th January 2018
2. Copies of any correspondence between yourselves and the Department for Transport, HM Treasury and the Committee for Public Accounts directly related that guidance or its replacement, update or variation between 1st January 2018 and 1st April 2021.
3. Copies of any correspondence between yourselves and the Department for Transport, HM Treasury and the Committee for Public Accounts that might indicate why the clearly defined approach due by April last year has been delayed or postponed

Yours faithfully,

Ref: One Hundred and Fourth Report of Session 2017-19 Department for Transport
4.4 “…. . HE continues to develop guidance on how to treat commitments to a whole programme of interacting projects, while individual projects within that programme remain uncertain and potentially unfunded. The target date for this approach to be clearly defined is March 2020.”

Highways England, Highways England Company Limited

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Himlin, Roger, Highways England Company Limited

Dear Mr Cuss

 

Thank you for your request for information about the treatment of
interacting road schemes dated 1 April 2021. I am dealing with it under
the terms of the Freedom of Information Act 2000/Environmental Information
Regulations 2004.

 

In order to answer your request properly, I was wondering whether you
would be able to provide me with some more information, specifically with
regards to the letter you mentioned (dated 27^th September 2019). Our
Freedom of Information request team do not have a letter on file for an
FoI request of that date, so I can only conclude that it was a letter sent
to a third party?

 

As one of the original authors of our “Programmatic Appraisal” guidance, I
am unaware of what letter this might be, or to who it may have been sent.

 

I look forward to your reply so that I can help you further.

 

Kind regards

 

Roger

 

Roger Himlin, Principal Transport Planner, Transport Planning Group

[Pronouns: he, him, his]
Highways England | Piccadilly Gate | Store Street | Manchester | M1 2WD
Tel: +44 (0) 300 4705227 | Mobile: + 44 (0) 7710 365 782
Web: [1]https://highwaysengland.co.uk

 

=========================

HE has new, easy-to-read [2]guidance on appraisal. Check it out!

 

We’ve also got a new suite of documents to help with [3]analytical quality
assurance. Have you read them yet?

=========================

 

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Dear Himlin, Roger,
Thank you for your reply.
The letter I received dated 27th September 2019 was from Valerie Stephens, Senior Project Manager for the A27 Arundel Bypass team in Guildford and my contact with HE at the time along with Alan Feist. The letter enclosed the TPG guidance itself and a copy of a letter from Jim O'Sullivan to the local MPs confirming that the single option Worthing and Lancing proposal was not proceeding.
Ms Stephens' words, in a standalone paragraph, were "We don’t have any records of correspondence between Highways England and Department for Transport on this issue." This was in reply to a query of mine, puzzled how an scheme that was not going ahead was nonetheless assumed to be going ahead - for the purposes of establishing the BCR of the Arundel bypass options - and I wished to check if it had been done with DfT knowledge.
Yours sincerely,
Ed Cuss

Dear Himlin, Roger,
In case it has not been received, I am resending my note to you of 8th April, below, in reply to yours of that date:

Dear Himlin, Roger,
Thank you for your reply.
The letter I received dated 27th September 2019 was from Valerie Stephens, Senior Project Manager for the A27 Arundel Bypass team in Guildford and my contact with HE at the time along with Alan Feist. The letter enclosed the TPG guidance itself and a copy of a letter from Jim O'Sullivan to the local MPs confirming that the single option Worthing and Lancing proposal was not proceeding.
Ms Stephens' words, in a standalone paragraph, were "We don’t have any records of correspondence between Highways England and Department for Transport on this issue." This was in reply to a query of mine, puzzled how an scheme that was not going ahead was nonetheless assumed to be going ahead - for the purposes of establishing the BCR of the Arundel bypass options - and I wished to check if it had been done with DfT knowledge.
Yours sincerely,
Ed Cuss

Yours sincerely,

Ed Cuss

Himlin, Roger, Highways England Company Limited

1 Attachment

Dear Mr Cuss

 

Thank you for your request for information about the treatment of
interacting road schemes originally dated 1 April 2021 and the
clarification dated 8 April 2021. I am dealing with it under the terms of
the Freedom of Information Act 2000.

 

I must begin my reply by advising you that I have established that only
some of the information you requested is held by Highways England.

 

You asked to be provided with:

1. Copies of any replacement, update or variation to the guidance issued
since 7th January 2018

2. Copies of any correspondence between yourselves and the Department for
Transport, HM Treasury and the Committee for Public Accounts directly
related that guidance or its replacement, update or variation between 1st
January 2018 and 1st April 2021.

3. Copies of any correspondence between yourselves and the Department for
Transport, HM Treasury and the Committee for Public Accounts that might
indicate why the clearly defined approach due by April last year has been
delayed or postponed.

 

I can provide you with the attached document, which satisfies your request
for (1), any replacement guidance issued since 7 January 2018. We do not
hold any correspondence that would satisfy parts (2) and (3) of your
request, however, the remainder of my reply, below, should explain the
situation to your satisfaction.

 

From your reply, dated 8 April 2021, to my email asking for clarity
regarding your initial question, I believe that the thrust of your query
is “how a scheme that was not going ahead was nonetheless assumed to be
going ahead - for the purposes of establishing the BCR of the Arundel
bypass options”. If I have correctly identified your query, I am happy to
address the sequence of events and the development of the guidance that
you are referring to.

 

The appraisal of Arundel was, alongside all of Highways England’s major
scheme business cases, developed using the DfT’s Transport Analysis
Guidance (TAG). Part of TAG, specifically Unit M4 “Forecasting and
Uncertainty”, discusses how a “core scenario” should be developed during a
scheme’s appraisal, which is used within a scheme’s business case to help
inform the decisions made regarding whether the scheme should be taken
forward.

 

Unit M4 introduces the concept of an “Uncertainty Log”, in which all
nearby transport schemes that could affect the scheme in question are
entered, alongside any developments that may introduce new traffic in the
area. Each entry into the Uncertainty Log is then given a rating of Near
Certain, More than Likely, Reasonably Foreseeable or Hypothetical. The
definitions of these ratings can be found in Appendix A. The Core Scenario
is then constructed using those schemes and developments that are rated as
Near Certain or More than Likely.

 

Prior to the publication of the first Roads Investment Strategy, it was
accepted practice that those involved in the development of a scheme would
need to make judgements on each entry in the Uncertainty Log on an
individual case-by-case basis. However, following the publication of the
Roads Investment Strategy, Highways England’s Chief Analyst at the time
asked for direction to be issued from Highways England’s Transport
Planning Group to all consultants developing models for Highways England
schemes that schemes that were part of the Roads Investment Strategy
should be treated as More than Likely as they were, to use the language
from TAG, “…likely to happen but there is some uncertainty.”

 

This direction was not discussed with the Department at the time as they
do not generally advise on individual applications of the Transport
Analysis Guidance set of documents. The Department provide the documents
so that scheme promoters can develop their business cases, but are clear
that the documents are simply “guidance”.

 

In the case of the A27 Arundel scheme, this meant that the A27 Worthing to
Lancing scheme was included in the core scenario. However, as there was
some uncertainty beginning to develop concerning the A27 Worthing to
Lancing scheme, a sensitivity test was also undertaken without the scheme
in the A27 Arundel model.

 

Both sets of modelling answers were available to decision makers within
Highways England and, by the time any decision had to be made on the A27
Arundel business case, it was clear that the A27 Worthing to Lancing
scheme would not be progressed. The sensitivity test, therefore, would
have been given due weight in any decision process.

 

Highways England have since withdrawn the direction to its consultants, to
treat schemes in a published Roads Investment Strategy as “More than
Likely”, and has provided more nuanced direction (within the attached
guidance, dated June 2020) that relates the rating given to how far each
scheme has gone through their development process.

 

I hope this answer explains clearly what happened during the A27 Arundel
case.

 

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:
[1]https://www.gov.uk/government/organisati...

If you require a print copy, please phone the Information Line on 0300 123
5000; or e-mail [2][Highways England request email]. You should contact me if
you wish to complain.

 

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 101996 in any future communications.

 

Yours sincerely

Roger Himlin

 

 

Roger Himlin, Principal Transport Planner, Transport Planning Group

[Pronouns: he, him, his]
Highways England | Piccadilly Gate | Store Street | Manchester | M1 2WD
Tel: +44 (0) 300 4705227 | Mobile: + 44 (0) 7710 365 782
Web: [3]https://highwaysengland.co.uk

 

=========================

HE has new, easy-to-read [4]guidance on appraisal. Check it out!

 

We’ve also got a new suite of documents to help with [5]analytical quality
assurance. Have you read them yet?

=========================

 

This email may contain information which is confidential and is intended
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recipient, you are hereby notified that any copying, distribution,
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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 |
[6]https://www.gov.uk/government/organisati... |
[7][Highways England request email]

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

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Dear Himlin, Roger,

Thank you very much for the notably fast response to my enquiry, which answers the questions I put comprehensively and with admirable clarity.

HE’s A27 Arundel team was asked on 26th February 2021 for TPG guidance you now enclose, but failed to provide it. Your explanation raises further queries of course, in particular I am left to question the Arundel Scheme Assessment Report of October 2020, which was based on the 2018 TPG guidance that had in fact been withdrawn several months earlier.

The Arundel preferred route announcement was also based on the withdrawn 2018 TPG guidance, rather than on its replacement. This meant that in assessing the scheme options’ value for money, the preferred route was chosen using a benefit cost ratio of 1.95, as stated in the SAR, rather than the more correct 1.46 (compare SAR paras 10.8.1.6 and 17.7.3). This suggests that the preferred option was incorrectly credited with an indicative medium value for money judgement rather than a low value for money judgement.

Although you say that due weight would have been given to the low value figure in any decision process, the published documents suggest this was not the case. The SAR refers neither to the abandonment of the Worthing proposal before the public consultation nor to the withdrawal of the TPG guidance that prompted its inclusion. Conversely, and worryingly, it does still use the indicative medium value judgement that it derived from the withdrawn TPG guidance and it does still quote, in support of that, the incorrect, pre-abandonment, benefit cost ratio.

Given its failure to communicate, I am left to conclude that the Arundel team is well aware of its problem with its preferred route but will continue to avoid legitimate questions. My recourse is to add this issue to my outstanding Independent Complaints Assessor material and perhaps the National Audit Office. However, given how its inaction / actions continue to undermine the probity and reputation of HE, perhaps you might encourage the relevant project manager to follow your own commendable example.

Yours sincerely,
Ed Cuss