M4 Public Inquiry – Debunking WG Statements -Proof of Evidence submitted by Wales Green Party

M4 Public Inquiry – Debunking WG Statements -Proof of Evidence submitted by Wales Green Party

To: The Public Inspector, Mr WSC Wadrup

Purpose of this document

To examine some of the ‘facts’ produced in the Welsh Government (WG) leaflet (appendix 6) which has been distributed to the public and deal with the FoI responses received. There is concern that the public are being persuaded, through a public misinformation campaign, to support a poor value for money solution to the alleged problems on the M4 between Magor and Castleton.

  1. Traffic Volumes


WG documentation distributed to the public states that in 2014 ‘the road’ was 95% full. This appears to be misleading as it cannot be 95% full 100% of the time.

FoI Request: Please provide documentation detailing at what times of day the road is 95% full, if any, and between which junctions this volume of traffic has been measured.

  1. Projected figures for future usage between the points above, taking into account demographic trends and the impact of the SEW Metro system on this stretch of road.

Response: Appendix 1

Observations: Based on WG FoI Response documents (Appendix 1)

The lower end of the forecasts shows the recent fall in trips continues over the next 30 years[1].

At peak times the motorway is as little as 46% full. The M4 around Newport is, on average, 76% full at peak times. On one section of the motorway, and in one direction only, the figure reaches 95%.

Traffic Volume data for the three-year period 2009-2011 is unavailable.

No account has been made for traffic scenarios arising from the completion of the Heads of the Valleys Road (A 465) improvements, due in 2018. It is likely that upon completion, much of the traffic coming from Birmingham and the midlands will not use the M4.

Demographic changes are a key driver of the number of journeys[2]. The population of Wales has grown by only 200,000 souls since 1995, most of those being in the north. The increase in population is mainly down to age, and older drivers tend not to populate the roads at peak times. This has not been examined.



The forecasting models are based on a high degree of uncertainty and do not take account of planned public transport impacts and demographic trends. By stating the road is ‘95% full’ the WG is misleading the public.


  1. Jobs

FoI request: Your pamphlet documentation states that 6,500 new jobs will be created by the Black Route.

  1. Please let me have a breakdown of the industries and businesses projected to achieve these ‘new’ jobs, and where exactly they will be situated geographically.
  2. How many will be in Newport?

Response: Appendix 2

Observations: Based on WG FoI Response documents (Appendix 2)

The high scenario for new jobs is 6,750. Medium scenario is 2,800, low scenario is 750 new jobs[3].

There are few possibilities for industry either side of the proposed motorway around Newport. The south side is scantily populated with few opportunities for development due to SSI status and flood risk. The north side is already well developed, with much of the available land allocated for housing.

There is no breakdown of the industries likely to be created.

New jobs are indicated to be around motorway junctions, two of which have been in place for some years. The two new junctions are Glan Llyn, residential to the north, SSSI to the south, and Docks Way, which prioritizes Port traffic. Whilst some new jobs may be created at the Port in spite of the proposed low Usk bridge, it is difficult to see how the proposed M4 can compete with a Metro[4] system in terms of job creation.


Whilst the documentation does not specifically say the jobs will be created in Newport, the entire document is Newport centric and will be read as such. The possibility of 6,500 new jobs in Newport is remote, and overplays the economic benefits of the proposed motorway.



  1. Accident Rates

FOI Request:

I have received a copy of the WG Statement of Case for a new M4 Black Route. Paragraph 1.5.2 states that ‘The current accident rates on the M4 between Magor and Castleton are higher than average for UK motorways.

  1. Please advise me which figures you are using, and from which reliable sources, in order to make this statement about accident rates on the M4?

Response: Appendix 3

Observations: Based on WG FoI Response documents (Appendix 3)

The average accident rate for this stretch of motorway as a percentage of UK average was 88.6% (2002-2008), 86.8% (2002-2005), 91.1% (2006-2008) 74.9% (2006-2008,12).

The claim that Junction 25-25A, the Brynglas Tunnels and Junctions 26-27) had a higher observed accident rate than the UK average for motorways, is not substantiated.

In 2012 and 2013 there was a reduction in the number of Police Stats19 Form accidents compared with previous years.

The FoI response did not report the following:

  1. The number of recorded UK personal injury collisions decreased from 9588 in 2000, to 6850 in 2010[5]. No comparable data has been put forward for the J24 – 28 stretch of M4 motorway.


  1. The number of casualties on UK motorways has gone down by 27% in the years 2014-2015[6]


  1. Statistics for Wales[7] does not single out the M4 Brynglas Tunnels as being any worse for accidents than any other part of the M4 (appendix 6). The area it chooses to detail is J33 Cardiff.


  1. The Variable Speed Limit (VSL) is expected to reduce accident rates by around 13%[8], yet this is not taken into consideration. Edwina Hart said, “In 2012 and 2013 there was a reduction in accidents compared with previous years.” We are not told what that reduction actually was.


  1. WG states that there was a reduction in accidents in 2012 and 2014 yet uses Police Stats 19 Forms for 2006-2008 as a measure of current accident rates.


  1. VSL installation was introduced in June 2011 between Junctions 24 and 28, but not enforced until autumn 2016.




Analysis of the figures between 2002 and 2008 (the only figures available), show that the stretch of motorway between Magor and Castleton reached at most 91% of the national rate for accidents.  The WG statement on accident rates is wrong.


  1. Air Quality

FoI Request: Your pamphlet documentation states that air quality will improve by up to 15%.

  1. ‘Up to’ is misleading. It might improve 5% or not at all. What is the accurate figure?
    How do you calculate improvement in air quality when at the same time you project an increase in traffic

Response: Appendix 4

FoI Observations: Based on WG FoI Response documents (Appendix 4)

The data shows there will be an overall increase in air pollution in future years: Changes in emissions (tonnes/year) :CO2 + 1,215. NOx  -155. PM10  -21. (Table 7.23, P48)

Local NOx concentrations in the region between Castleton and Magor will go up. (7.15.8). The concentrations, not the total emissions, are the measure of air quality.

There will be significant risks to designated sites, which cannot be mitigated. (Table 7.25)

There is no modelling of emissions along the A48 Eastern Avenue, which would in all probability go from bad to worse.

Emissions reduction is not likely to be achieved due to induced traffic using the present M4.


The 15% air quality improvement figure doesn’t exist in the documentation, and should not have been used to mislead the public into thinking the proposed M4 was a good thing. If we are to meet the Paris climate change targets, the overarching aim should be to reduce CO2 as quickly as possible. The proposed M4 is increasing CO2 emissions.



  1. Environmental Impact

The plans for the M4 Black Route include re-directing some reens through culverts. Evaluation of previously culverted reens will be a measure of the environmental impact of this apparent mitigation measure.

FoI request:

  1. What monitoring and evaluation of the culverted reens adjacent to Gwent Europark have been done, and the results of this.
  2. The monitoring and evaluation of the effects of any other culverted reens across the Gwent levels.

Response: Appendix 5

Observations: Based on WG FoI Response documents (Appendix 5)

No records provided.



The documents contain NO record of monitoring or evaluation of reens at Gwent Europark or anywhere else. This unknown factor in environmental impact is a crucial omission. The absence of monitoring data affecting approximately 2568m of SSSI reen and 9136m of SSSI field ditch would indicate that culverting does not work, and the impact on flora and fauna would be unacceptably high.







Only five aspects of the documentation have been examined, and in all five, the information publicised by the Welsh Government is misleading. In some cases the figures used are exaggerated, or information is withheld. In other cases they are fiction. A sample score of 0/5 for openness, honesty and transparency is worrying.  All other claims should therefore be subjected to rigorous scrutiny.


The basis for building a 19 mile stretch of new motorway at a cost of £1.2 billion+ is discredited.

This proposal represents bad value for money for the taxpayer, and all costs and expenses to date should be referred to the Wales Audit Office for further action.





[1] https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationestimates/timeseries/wapop/pop

[2] changebehaviourhttps://www.gov.uk/government/uploads/system/uploads/attachment_data/file/411471/road-traffic-forecasts-2015.pdf

[3] Table 6.22 (p.150).


[4] See separate submission : M4 Public Inquiry – Better Value for Money from Integrated Public Transport

Proof of Evidence submitted by Pippa Bartolotti, Wales Green Party


[5] http://gov.wales/docs/det/publications/130719delplanen.pdf

[6] https://www.gov.uk/government/statistical-data-sets/ras40-reported-accidents-vehicles-and-casualties#table-ras40001

[7] http://gov.wales/docs/statistics/2016/160405-accident-cluster-sites-fatal-road-accidents-welsh-trans-european-network-2012-2014-revised-en.pdf

[8] http://www.traffic-wales.com/media/33521/m4-vsl-qa-sheet-january-2011.pdf

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