2 March response sent to: Dear Sir/Madam, Response to: Welsh Transport Appraisal Guidance (WelTAG) 2017

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1 Royal Town Planning Institute Cymru (RTPI Cymru) PO Box 2465 Cardiff CF23 0DS Tel +44 (0) Website: response sent to: 2 March 2017 Dear Sir/Madam, Response to: Welsh Transport Appraisal Guidance (WelTAG) 2017 The Royal Town Planning Institute (RTPI) is the largest professional institute for planners in Europe, representing some 23,000 spatial planners. RTPI Cymru represents the RTPI in Wales, with 1,100 members. The Institute seeks to advance the science and art of spatial planning for the benefit of the public. As well as promoting spatial planning, the RTPI develops and shapes policy affecting the built environment, works to raise professional standards and supports members through continuous education, training and development. The response has been formed drawing on the expertise of the RTPI Cymru Policy and Research Forum which includes a cross section of planning practitioners from the private and public sectors and academia from across Wales. Our comments on the consultation questions are set out below. If you require further assistance, have any queries or require clarification of any points made, please contact RTPI Cymru on or Roisin Willmott at walespolicy@rtpi.org.uk Yours sincerely, Dr Roisin Willmott FRTPI Director RTPI Cymru

2 Question 1: Do you think WelTAG 2017 is an improved process for developing, appraising, and evaluating transport related projects? Yes If no, please explain the reason for your answer: Yes. The document clearly explains the principles of the new Weltag Appraisal methodology and the structure and stages of the appraisal process. The integration of the Weltag Appraisal Stages with the Welsh Government and UK Treasury s Five Case Model for Public Sector Business Cases is welcomed. Question 2: WelTAG 2017 has been written to encompass the goals, objectives, and ways of working set out in the Well-being of Future Generations (Wales) Act Are there specific areas where the document needs to be improved or strengthened? Yes If yes, Please explain the reason for your answer: Weltag Stage 1, the Strategic Outline Business Case requires objectives to be set for the required solution. The guidance requires that these objectives reflect the general national objectives included in the Well Being of Future Generations (Wales) Act 2015 (FGW Act) which we support in principle. The FGW Act sets five high level goals which the Act requires public bodies to translate into well-being objectives within the Well Being Plans for their areas. In our view it would be more appropriate for the project objectives as part of the Strategic Outline Case to reflect the objectives in the Well Being Plan of the public bod(ies) undertaking the Weltag Appraisal or who will be using it to inform decision-making. The objectives (and Weltag Appraisal) should also reflect how the project/solution contributes to/demonstrates the five ways of working set out in the FGW Act, namely: Long Term Prevention Integration Collaboration Involvement This should be made more explicit in the guidance. The guidance requires that project objectives also reflect the objectives in the Wales Transport Strategy (WTS). The WTS document is now 9 years old. RTPI Cymru s view is that the WTS needs to be fully reviewed and updated in light of more recent developments in policy, most notably the FGW Act. This would ensure that projects are appraised against up to date policies and that the Weltag process

3 is effective. In the meantime, it would helpful if the guidance were to map the WTS outcomes and FGW Goals to highlight areas of compatibility. Project objectives should also reflect the requirement to support the delivery of the Active Travel (Wales) Act 2013 and to increase travel by active modes. The provision of further guidance on objective setting within the document or via the Weltag website would be helpful. The appraisal process does not appear to require any assessment of how a project stands in relation to the Local Development Plan and the Local Transport Plan for the area in question. Given the consultation arrangements which are involved in the preparation of these documents and their statutory status, this appears to be a key omission. As the preparation of the National Development Framework and Strategic Development Plans progress, these documents should also feature in appraisals where relevant to them. A key concern, in terms of the outcome of transport appraisals, is that the transport sector is still routinely failing to achieve the reductions in carbon emissions that legislation now binds our governments to achieve. Indeed, it is evident that transport schemes which will profoundly increase carbon emissions are still finding their way into approved transport programmes. Carbon emissions appear in the documentation as just one of a very large number of variables. RTPI s view is that carbon reduction needs to be given greater primacy and weighting as a consideration in the appraisal process. Guidance on how this should be addressed within the appraisal process should be provided as we recommend in our response to Question 3 below. This underlines the need for weightings to be assigned to impact appraisal criteria, as we have recommended in our response to Question 5. Question 3: It is our intention to provide Advisory Notes to accompany WelTAG What advisory notes would you find helpful? Please respond in the box below: Advisory notes may be helpful for the following matters: Advice on objective setting Advice on appropriate detail/quality of evidence required at each Weltag stage for projects of different sizes how to apply the principle of proportionality. Advice on carrying out Weltag assessment for different project types e.g. rail road etc (whilst avoiding any implied predetermination of a modal solution where there is more than one modal option e.g. Bus Rapid Transit vs Light Rapid Transit). Advice on the composition and role of the Review Group Advice on scope and contents of WelTAG Stage Report and Impacts Assessment Report.

4 Advice on weighting of appraisal criteria including weighting of criteria relating to carbon reduction Question 4: Are there any areas where you would find additional training and support helpful? If yes, please make your suggestions below: Yes. Training and support to help different types of users consultancies, local authority transport planners, Welsh Government officials would be very helpful. The Weltag website could provide an invaluable information and training resource. The inclusion of worked examples of appraisals and Stage Reports or case studies for different projects would be very helpful. Welsh Government should help to facilitate groups and workshop sessions to enable practitioners to share experience and work through issues with each other and Welsh Government officials. The input of professional institutions through these channels and links to professional learning pathways should be actively encouraged. Question 5: Do you have any other comments on the guidance? Please respond in the box below: The guidance very clearly sets out the five stages of the Weltag Appraisal. The integration of the Welsh Government/UK Treasury Five Cases Model within the Weltag Stages is to be welcomed. The alignment with the FGW Act needs to be more clearly defined. The checklists provided for each of the five cases provide a helpful list of the contents headings for each case. Although this is helpful in defining the scope of the appraisal in broad terms, the guidance lacks specifics on the level of detail required for each element. While that lack of prescription in the document regarding technical methodology and evidencing helps the user to take a proportional approach to scheme appraisal, there is a danger that too much is left open to interpretation and that this may invite light touch appraisals for schemes where a more rigorous or in-depth technical appraisal would have been appropriate (or vice versa). The WelTAG 2017 document should reference statutory requirements e.g. Environmental Impact Assessment and relevant Welsh Government requirements on equality, health impact etc. The guidance advises against assigning weightings to impacts (Page 31). It seems to imply that this element of appraisal be supplanted by the vagaries of political decision-making and the trade-offs and subjective judgements this may entail. We would argue that weightings should be assigned to impact appraisal and that their effect upon the appraisal scoring (within different scenarios featuring alternative weightings if necessary) be presented transparently and clearly to

5 decision-makers who can then make a decision based on a fully informed appraisal of impacts.. There will always be a risk that decision makers may choose to overlook evidence or professional advice, but this should not be a reason for not presenting a weighted appraisal for consideration. Further advice on the expected composition and role of the Review Group would be helpful. It would also be beneficial for the document to advise on the technical and professional competencies that group members should have. It is likely that the requirement to have a Review Group for small projects could be regarded as onerous for small projects. Guidance on how to tailor and streamline Review Group involvement to the scale of the project would help to dispel concerns about this. For example, there may be a case for grouping a number of related small projects together under a single Review Group. There should also be further guidance regarding the selection/role of the independent reviewer of Stage Reports and Assessments. We raise the question whether this should be a person within an organisation or outside it e.g a consultant?