In response to your request for comments on the working of the Active Travel Act:


Please find attached a copy of my submission to the public inquiry on the A487 Bontnewydd bypass in which I detail the reasons given by the project managers for not adhering to the requirement of the Active Travel Act (Wales) 2013 and my responses thereto. As is clear from the reasons given by the project managers you can see that they are simply ignoring the requirements of the act and devising excuses for their action.





Re: Fishguard to Bangor Trunk Road Scheme


I do wish my objection to stand and to be considered by the public inquiry.


As you state, under the Active Travel Act (Wales) 2013, “The presumption is that enhancements for active travel would be made in new schemes or during maintenance when it is practicable to do so.”


My objection is based on expecting this statutory “presumption” to be followed.


As you also state, “The Act outlines a number of exceptional circumstances where Highway Authorities may determine that is would be unreasonable or impracticable to enhance provision for walkers and cyclists in highway construction, improvement or maintenance.”


My objection is based on your having failed to provide any reasons for disregarding the statutory presumption on anything that could be regarded as “exceptional” grounds.


Reading your response to me, it appears that the grounds you have given for disregarding the statutory presumption are as follows:


1.   “An NMU Audit for the scheme concluded [that] there is no evidence that a parallel/integrated Active Travel Route would provide significant utility as the communities potentially standing to benefit are few, small and far between.”

2.    “The Scheme would be a trunk road and is not designed specifically for NMUs who will instead benefit from reduced traffic/speeds on the detrunked existing A487 that connects these communities with Caernarfon Town Centre.”

3.   “The Scheme alignment broadly follows a section of the existing Lon Eifion National Cycle Network (NCN8) route between Llanwnda and Plas Menai. The Lon Eifion (NCN8) route is a high quality, generally traffic free and attractive recreational route used by both local communities and tourists, predominantly for walking and cycling.”

4.   “The existing Lon Eifion (NCN8) route passes through the centre and waterfront of Caernarfon, whilst the scheme is peripheral from the town. Any parallel provision for Active Travel users associated with the scheme would provide limited benefits at relatively high cost due to the significant engineering requirements; especially given the distance and gradients involved in connecting communities alongside.“

5.   “Providing a cycle track alongside the Scheme would cost an estimated further £4m.”


I fail to find any of these grounds offer reasons for not complying with the Act and there is nothing “exceptional” about them.


I shall comment on them in order.


No. 1:


1.1: This demonstrates an inadequate understanding of network effects whereby it is well established that the creation of safe walking and cycling routes attracts users who would previously not have considered walking or cycling along a particular route. This is neatly summed up by the phrase “build it and they will come”. There is a solid and substantial body of evidence behind this fact which appears to have been disregarded by the reductionist approach outlined in “Reason” No. 1.


1.2 The fact that the Scheme, as you state, was conceived of as a trunk road that was (somehow or other) designed to ignore the needs of pedestrians and cyclists is irrelevant to the assumption in the Act that new schemes etc shall be taken as an opportunity to make up for past failings such as ignoring active travel users in Scheme designs. It is not exceptional for old-fashioned road design ideas to ignore active travel users, it is and has long been the UK standard and the Act is intended to provide the means and method to correct this egregious past policy, not to prolong it. New schemes such as this provide the opportunity to change past practices. There is nothing here which can be reasonably called “exceptional”.


1.3 It is not only the communities on or near the route who will use it and benefit from it.


No. 2:


2.1 There being a nearby route does constitute “exceptional” grounds for disregarding the statutory “presumption” and not taking the opportunity to create high-quality active travel routes.


No. 3:


3.1 Unlike motor travel where a diversion of some miles to access a trunk route, an effective active travel network needs to provide short distance links to comparable active routes. A nearby active travel route does not make a nearby route unnecessary as access potential and distances need to be taken into account.


No. 4:


4.1 As explained in 3.1, it is irrelevant that there is a nearby active travel route and the “build it and they will come” evidence indicates that benefits would not be “limited”.


No. 5:


5.1 It is patently not “exceptional” that an active travel route costs money and to cite this as an “exceptional” reason is absurd. To accept this assertion would reduce the Active Travel Act (Wales) 2013 to a bad joke with the implication that only Schemes that are costless can be implemented.


Clearly the grounds cited as “exceptional” are not exceptional in any reasonable sense of the word but replicate the sort of excuses regularly used by motor-dominated thinking of the road engineering professions and Highway Authorities and which have dumped this country in the unenviable position of having an undesirably large level of poor health in the population and which it is the purpose of having to have an Act to provide statutory footing to prompting change within the engineering professions and Highway Authorities.


In conclusion, if the Highway Authority is allowed to proceed with evading its statutory obligations in this scheme, it would mean that the Active Travel Act (Wales) 2013 would become a dead letter.


Finally, I suggest you have a look at this link showing the new cycle lane on the Morpeth Northern Bypass, to see how the Highways Authority in England is doing what the Active Travel Act (Wales) 2013 is asking for, but without the prompting of an Act. It would be a national shame if Welsh Highways Authorities allow Wales to fall further behind England and other European countries in provision of active travel facilities. Having seen, as this video shows, that it is now becoming the presumption that new trunk roads in England will be accompanied by new safe cycle lanes there are clearly no excuses for not doing the same in Wales.