Action for Public Transport (N.S.W.) Inc.
|ATAP Steering Committee||P O Box K606|
|Department of Infrastructure and Regional Development||Haymarket NSW 1240|
|Canberra||8 August 2017|
Action for Public Transport (NSW) ("APTNSW") is a transport advocacy group active in Sydney since 1974. We promote the interests of beneficiaries of public transport; both passengers, and the wider community.
APTNSW has long been concerned about the systematic bias against public transport investment embedded in standard analysis and appraisal techniques. Current methods of appraisal fail to account properly for the benefits of public transport, including the positive effect of increased use of public transport on urban amenity and liveability.
Correcting this inbuilt bias is essential to getting better transport selection and funding decisions. Litman (2009, p.102) observes that some transport impacts, such as vehicle operation costs and travel time values, have been widely studied, and estimates of their magnitude are easily available. Other impacts, such as changes in walking conditions and greenhouse gas emissions, are more difficult to quantify, and so are often dismissed by decision-makers as intangibles, with the implication that they are less important.
The result is decision-making biased in favour of easy-to-measure impacts at the expense of more difficult-to-measure impacts.
APTNSW is therefore pleased to see that the Transport and Infrastructure Council is moving to bring some critical but neglected considerations into the highly influential ATAP guidelines. Urban amenity and liveability (among other things) have been effectively ignored in transport assessment practice, because they do not fit easily into the models used to assess the wisdom or otherwise of undertaking (and funding) proposed transport initiatives.
The single ratio that is the product of cost-benefit analysis is highly influential, but blind to any factor that is not assigned a dollar figure. And yet those factors can be very important.
The existing bias towards roads and against public transport and what is termed "active transport" (walking and cycling) has serious real-world consequences. This is not a technical issue of interest only to those undertaking transport assessments.
Urban motorways produce an urban environment that is hostile to walking, cycling and public transport, which depends on (and fosters) good pedestrian connectivity. They consequently damage urban amenity and liveability.
Former New York City traffic commissioner Samuel Schwartz (2015) records the history of the largest and most expensive public works project in the country's history, the US Interstate Highway System (IHS), and concludes (p.17):
The IHS is a marvel for transporting people and goods between cities, but wherever it is routed 'through cities' it is almost always a disaster.
Public transport promotes urban amenity and liveability, because it minimises the amount of land devoted to roads (as opposed to streets) and car parking. It has this effect because it uses valuable urban space so efficiently.
Litman (2009, p.1-14) notes that increased urban roadway capacity is likely to stimulate low-density, urban-fringe, car dependent development patterns. Its effect is to reduce urban densities. Other types of transport improvements usually result in more infill and clustered land use. Roads also compete directly for urban space with other potential uses, including housing. The amount of urban land devoted to concrete is in our view a more pressing concern than the amount devoted to backyards.
Busy roads also pose health risks to anyone living near them, as has been reported in a fairly recent address by Dr. Stephen Corbett Director, Population Health, Western Sydney Local Health District, which we are providing as background to this submission. This is clearly relevant to any assessment of the liveability of the urban areas afflicted by them.
Source: M5 EIS Vol 1A Figure 5-10
The draft guidelines recognise that “accounting for urban amenity and liveability effects, (both positive and negative) contributes to good decision-making in both transport planning and the appraisal of transport initiatives”. It suggests that measuring and valuing urban amenity/liveability is crucial for creating an informative Appraisal Summary Table (AST) which can provide helpful information to the decision-maker. In turn, this can lead to delivering a sustainable transport network and a basis for measuring the impact of transport on social welfare and wellbeing (Mendelsohn & Olmstead 2009, Mulley et al. 2016, Nahmias-Biran & Shiftan 2016, UK DfT 2014). It proposes to move towards doing so, within the ATAP assessment model of Cost-Benefit Analysis (CBA) and use of the Appraisal Summary Table (AST).
The draft guidelines note that a number of global scales measuring liveability exist (The Economist Intelligence Unit, Mercer Quality of Living Survey and Monocle Lifestyle Magazine). A tone of marked resistance to such indicators suffuses the discussion in the draft report, which says that “Measures of the extent to which urban amenity and liveability are achieved is also open to interpretation by decision-makers and the community”; and that interpretation of what constitutes a "liveable city" can therefore be complex for appraisal.
These observations may be correct, but the notion that important factors are better left out than considered by decision-makers and the community is more than a little problematic in a democracy. There are value judgements to be made in transport planning, disturbing the comfortable illusion of a "values-neutral" technical activity.
Assigning a nil value to factors known to be important, because they are complex to assess, is a sure way to arrive at a poor result. Litman (2013) has observed a problematic tendency to prefer "precisely wrong" to "roughly right" analysis:
People involved in economic evaluation should understand the difference between accuracy and precision. Accuracy refers to correctness of information. Precision refers to the level of detail in measurements…. Non-market cost estimates are often criticized because they lack precision. For example, estimates of air pollution costs may vary by an order of magnitude, depending on the methodology that is used. However, if such impacts are likely to be significant in magnitude, it would be more accurate to incorporate them imprecisely than to omit them in ways that bias results.
APTNSW suggests that the indicators already identified in the draft guidelines could usefully be considered, along with: "walk scores" (see https://www.walkscore.com and https://www.walkscore.com/methodology.shtml, retail turnover, vacancy rates, foot traffic, speed of vehicles in kerbside lanes, waiting times for pedestrians at traffic lights, and perhaps tree cover. The draft guidelines rightly note that a pavement associated with parking facilities can be connected with increases in ambient temperatures, and so a measure of the amount of surface land devoted to car parking would also add to the assessment of urban amenity and liveability.
The draft guidelines suggest that the ATAP approach of recognising non-monetised effects alongside monetised benefits and costs in the Appraisal Summary Table (AST) overcomes criticisms of decision-making based on monetised impacts alone, which is problematic where major impacts cannot be monetised. The AST provides the mechanism for presenting all the appraisal results, both monetised and non- monetised, in the one place.
We agree that a balanced AST, with monetised and non-monetised effects presented side-by-side, should allow for more balanced and nuanced decision making. Unfortunately, that message is not getting through in some quarters. Time and again, the BCR alone is cited as evidence that a project is "a waste of money" or "a good investment".
The draft guidelines note that, but note that a number of studies have been undertaken in Australia over the last 10-15 years on the monetisation of environmental externalities. This includes barrier effects, an aspect of urban amenity and liveability.
They note that current guidance points to a range of non-market approaches that can be implemented to infer values for amenity and liveability: stated preference techniques; regression approaches; contingent valuation; cost-based approaches; revealed preference approaches; and hedonic pricing and modelling.
It is clear that little of the research undertaken to date has moved beyond the field of economic modelling, with the aim of "inferring values" by one method or another. One approach is to keep trying to monetise everything that is relevant to reaching a properly informed decision. This is much better than ignoring important factors outright, but we suggest it is time for a paradigm shift.
Not everything that can be counted counts, and not everything that counts can be counted. (Albert Einstein, cited by Litman 2009)
It is recognised in the draft guidelines that assessing non-monetised aspects of urban amenity and liveability are emerging areas and further research is required.
We urge the Council to extend research efforts beyond the field of economic modelling, to include urban planners and urban design specialists. The draft guidelines acknowledge that connectivity and accessibility are well understood in the context of urban planning. Urban designers frequently use block sizes and the density of streets (not roads) as an indicator of the connectivity of urban areas, and this also should be explored as a useful indicator of amenity and liveability.
APTNSW thanks ATAP for the opportunity to comment on this document, and thank you for the extension of time for us to do so. In the further work that remains to be done, we see a role for transport users, transport specialists, land use planners and behavioural economists, as well as transport modellers and classical economists.
Action for Public Transport (NSW) 2014, Submission to Senate Committee inquiry on role of public transport in delivering productivity outcomes http://www.aptnsw.org.au/documents/role_of_P_T.html
Action for Public Transport (NSW) 2015, Submission in response to Draft Parramatta Rd Urban Renewal Strategy http://www.aptnsw.org.au/documents/parra_rd_URS.html
Action for Public Transport (NSW) 2014, Submission in response to IPART Review of External Benefits of Public Transport Issues Paper, http://www.aptnsw.org.au/documents/ipart_ext_benefits.html
Action for Public Transport (NSW) 2014 Submission in response to IPART Review of External Benefits of Public Transport Draft Report, http://www.aptnsw.org.au/documents/ipart_ext_benefits_2.html
Action for Public Transport (NSW) 2014 Submission in response to draft Leppington Precinct Plan http://www.aptnsw.org.au/documents/leppingtonDCP.html
Deloitte Access Economics, August 2011. The true value of rail https://ara.net.au/sites/default/files/u16/True_Value_of_Rail_Report_FINAL.pdf
Infrastructure Australia (2015), Australian Infrastructure Audit Report Volume 1 http://infrastructureaustralia.gov.au/policy-publications/publications/Australian- Infrastructure-Audit.aspx
Infrastructure Australia (2016) Australian Infrastructure Plan http://infrastructureaustralia.gov.au/policy-publications/publications/Australian-Infrastructure-Plan.aspx
Kahneman, Daniel (2011) Thinking, Fast and Slow, Penguin
Litman, Todd 2009. Evaluating Public Transit Benefits and Costs: Best Practices Guidebook, Victoria Transport Policy Institute (Canada) http://www.vtpi.org/tranben.pdf
Schwartz Samuel I. 2015, Street Smart published by Public Affairs
Tourism Task Force November 2014 Better Public Transport. Better Productivity. The economic return on public transport investment http://www.ttf.org.au/Content/bprreport181114.aspx
Walker, Jarrett, Human Transit 2012