TAPAS.network | 11 July 2022 | Editorial Opinion | Peter Stonham

What’s it for? Is it worth it? Did it work?

Peter Stonham

SEVERAL ITEMS in this issue of LTT explore the justification, implications and outcomes - both forecast and measured - of transport ideas, policies and projects. And that is not unusual at all at this time, as such awkward questions are being raised more and more frequently in the context of scarce financial and other resources to deploy, and the changing social, economic and environmental objectives and priorities that must be the fundamental reason for transport interventions. 

Too often, it seems, the underpinning assumptions of why we are doing things are not sufficiently open to question - or are baked into processes and formula that ought to be regularly looked at afresh. And alongside this, secondary and unintended consequences may be overlooked, and overriding wider objectives frustrated.

Not for the first time the Welsh Government is showing imagination and resolve in re-thinking key transport matters in this context. Its move to reduce the general speed limit in urban areas has prompted some careful examination of both political positions and professional practice so that things can be done differently - and hopefully better.

In this situation, the idea of Regulatory Impact Assessment for government policies is a logical and revealing one. Providing a template for public officials to use when completing such an examination of a policy proposal allows for the awkward and difficult assessment of things that can only ultimately be decided by policy makers, but need to potentially override the ‘black box’ tools of experts, and the established beliefs of both advocates and objectors.

Governments and their Departmental administrators (especially those holding the purse strings) generally like formulas and appraisals that make proposals ‘pass tests’. But sometimes the tests themselves need a hard look.

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Governments and their Departmental administrators (especially those holding the purse strings) generally like formulas and appraisals that ‘pass tests’. But sometimes the tests themselves need a hard look.

The Welsh speed limit RIA highlights, for example, the recently introduced new description of ‘Value for money’ in the Glossary of the much feared, and seldom challenged, Treasury ‘Green Book” on appraisal and evaluation.

This new interpretation attests that Value for Money – (VfM) is “a balanced judgement based on the Benefit Cost Ratio which brings together social costs and benefits including public sector costs over the entire life of a proposal, together with decisively significant unquantified deliverables, and unmonetised risks and uncertainties, to deliver a proposals SMART objectives. The judgement is made in the context of the proposal’s role, in supporting government policies and strategies of which it is a part, and its fit with wider public policies.”

Those are my italics, to highlight an apparent acknowledgment that such assessment and judgement have to be made against underlying policy objectives - which obviously are subject to change and democratic determination, and not to be ‘ruled out’ by a pre-existing paradigm that has a life of its own.

Policy changes ought, of course, to be subject to proper debate and analysis themselves, and a key role in this should be played by professional advice - hopefully guided by both expertise and experience.

On this topic the Department for Transport’s latest new evaluation strategy and programme is encouraging too.

Prompted by the Treasury and Cabinet Office, the DfT has been looking afresh at how it conducts its programme of evaluation since it published its first evaluation strategy in 2013.

The update seeks to meet the requirement of the Cabinet Office and Treasury’s Evaluation Task Force to publish an evaluation strategy outlining their Department approach to identifying and prioritising areas for evaluation activity.

The record to date in this area has not been great - in either undertaking the relevant and timely data collection and analysis, publishing the outcomes, and applying the results to future appraisal. DfT now says, rather guardedly, “We are committed to embedding evaluation in our programmes to derive proportionate learning about their effectiveness”, but more encouragingly, “we are seeking to prioritise this so we can provide the optimal feedback to improve delivery, provide better appraisals and inform decisions about future policies”, in the words of Amanda Rowlatt, DfT Chief Analyst.

Can we perhaps look to Rowlatt and her team to be as open to change as have been Transport

for Wales, whose new version of WelTAG, to be released later this year, is expected to require the journey time elements of scheme analysis to be presented separately for the first time. It is also likely to remove the specific requirement for BCRs for many projects in favour of “an integrated well-being appraisal that puts greater emphasis on well-being and the environment”, says the Regulatory Impact Assessment (RIA) for the Welsh Government of the 20mph default limit.

“Reflecting the heretofore dominant role of time savings in transport appraisal, where a BCR is required, WelTAG is expected to require the calculation of a BCR with and without the value of time monetised,” it explains.

The RIA was commissioned while the government was revising WelTAG. “One of the reasons for the revision is a recognition that the present appraisal processes may elevate certain appraisal variables that would result in potential negative outcomes when viewed against the policy objectives of the Welsh Government,” it notes. 

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We are committed to embedding evaluation in our programmes to derive proportionate learning about their effectiveness...we are seeking to prioritise this so we can provide the optimal feedback to improve delivery, provide better appraisals and inform decisions about future policies

Amanda Rowlatt, Chief Analyst, DfT

The RIA says an example of this would be the BCR trumping health benefits in the appraisal process. “The UK Treasury Green Book has recently been revised for similar reasons, and Welsh Government’s Chief Economist subsequently issued an advisory note ‘Aligning the Green Book with Welsh Government Values: Transport’, which states that: ‘A project can only be shown to deliver value for money if it is consistent with the Welsh Government’s strategic objectives and values’.”

The RIA comments: “The last sentence is indicating that if a proposal does not support a Government objective, it cannot be value for money. In the context of this RIA about speed limit policy, one of the primary causes of professional concern about potential outcomes from the present approach to appraisal is how journey time should be valued and used to calculate BCRs.

“This concern has been driven by the relationship of journey time importance relative to wider policies that seek to address climate change, health, clean air and the environment. It is evident that valuation of traveller time savings holds potential to either support or undermine high-level government priorities, depending on who the time savings accrue to.

“For these reasons, the draft revised WelTAG guidance specifies that the element of the value- for-money assessment based on journey time increments or decrements should be calculated and presented separately to enable decision-makers to take a view as to the relevance and validity of the journey-time element.”

It is not just the issues of journey times and reducing accidents and personal fears for non- motorised travellers of using local roads that need to be traded off in approval and evaluation. Other fundamental policy issues that must now surely be addressed in their own right are Climate Change and the achievement of Net Zero.

Interestingly, back in 2013 a sustainable development impact test was published by the Department for Environment, Food and Rural Affairs with Guidance for policy officials in government to identify and assess the sustainable development impacts of their policy options. The preamble was that as The UK government is committed to sustainable development, so that the current generation satisfies its basic needs and enjoys an improving quality of life without compromising the position of future generations, this central principle should underpin all policy development. 

Peter Stonham is the Editorial Director of TAPAS Network

This article was first published in LTT magazine, LTT849, 11 July 2022.

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