3. Our reasoning against the WG position
1. Traffic forecasts
6,800
7,000
7,200
7,400
7,600
7,800
8,000
8,200
8,400
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Traffic (south-east Wales)
Forecast
Actual
4. Our reasoning against the WG position
1. Traffic forecasts
2. Congestion
“The Welsh Government has no congestion statistics or indeed means of measuring congestion.
A statistician at the Department for Transport confirmed to Friends of the Earth Cymru that the
Welsh Government has no congestion statistics, nor has it made contact with the Department for
Transport’s department that is piloting a scheme for measuring congestion.
The apparent priority of the Welsh Government – tackling congestion – has no basis in evidence”.
Friends of the Earth Cymru, 2013
5. Our reasoning against the WG position
1. Traffic forecasts
2. Congestion
3. Reasoning out of date
“A current understanding of the transport problems on the M4 corridor is then considered, originating
with the problems established in a WelTAG planning Stage workshop held in October 2007”.
“The environmental report… shall include the information that may reasonably be required taking into
account current knowledge and methods of assessment”
Welsh Government, 2013
European Commission, 2001
6. Our reasoning against the WG position
1. Traffic forecasts
2. Congestion
3. Reasoning out of date
4. Environmental objectives
“The Welsh Government, with your input, has identified 15 goals for the M4 Corridor around Newport”.
“The 15 goals… were adopted as a result of consultation with a limited number and range of
stakeholders in 2007 (not 2012), and were never subject to public consultation”.
“the question for the Court is did the Secretary of State ask himself the right question and take
reasonable steps to acquaint himself with the relevant information to enable him to answer it
correctly?” Tameside adjudication, 1977
Friends of the Earth Cymru, 2014
Welsh Government, 2014
7. Our reasoning against the WG position
1. Traffic forecasts
2. Congestion
3. Reasoning out of date
4. Environmental objectives
5. Reasonable alternatives
• Including the Blue Route; public transport plus junction closure(s) plus active
travel