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 Post subject: Stephen Sauvain Q.C's document submitted to enquiry
PostPosted: Mon Feb 02, 2009 11:54 am 
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http://inquiry.knowsley.gov.uk/Proof%20 ... -INQ-7.pdf

A. Introduction
It is unfortunate that it has taken Mr Ellis over three weeks to understand what was wrong with his original Tables and to produce an explanation to the inquiry. N.B. Although the revised table may appear on first sight to be, and has been presented as being, a clarification of the methodology used by Mr Ellis in his Appendix 14 it does in fact contain a different methodology. The critical column in the calculation is, and was, Column 9 – i.e. the proportion of population shopping at Kirkby under the proposed scheme which is used to calculate the future travel distances to Kirkby if the market share in each zone turned out to be what Mr Williams suggest it might be. There is, in any event, a fallacy in comparing this with the existing market share drawn to other centres (from the first Table) – which were addressed in cross examination and are repeated below – but it is important to understand how Mr Ellis has changed the nature of the information in this column. B. The nature of the change to column 9 In his Note to the Inquiry Mr Ellis does not suggest that he has made any change to the methodology. He indicates that the revised document is a “clarification” which he has updated to take account of the uplift in market share from Mr Williams Table A. However, the original figures in the Table were not uplift figures but were the total market share figures anticipated in each of the Zones from the original retail assessment Table 16 (which are appended to this Note). This clearly was a total nonsense because it failed to take account of the existing market share attracted to Kirkby, it failed to take into account changes to the application and retail floorspace, and also had the absurd result that the larger the market share attracted from Zone 1 the larger the figure for the travel distance to Kirkby post scheme and the lower the amount of travel saving. By now taking an uplift figure Mr Ellis has addressed one of the criticisms (i.e. that his original table did not take into account of the existing market share of Kirby) but he has not addressed the other fundamental criticisms which demonstrate that the exercise is still nonsensical.

It is noted that Mr Ellis has still not explained how he has derived some of the unexplained the figures in his original table. Inexplicably he is still using a different population base from that adopted by the retail consultants. It is noted that Mr Ellis repeats several times that caution has to be exercised in interpreting the results. Just how much caution should be exercised in placing any reliance on this absurd methodology can be demonstrated by looking at Zone 1. However, most of the points made below will apply to the figures relating to the other Zones as well. C. Comments on the Non Food Mileage Assessment in relation to Zone 1 I deal with these, column by column, using Mr Ellis’ numbering and the headings from the Table itself..
1. Zone.
These are of course Mr Williams’ zones which have been criticised by all the other retail consultants.
2. Zone Population
Mr Ellis uses the 2001 population figure. The survey results which he later relies upon date from November 2006 and the future market share predictions are of course based on 2013. The population Mr Ellis uses is 38,849. The Retail Statement of Common Ground gives the population figure in Zone 1 as 38,008 in 2008 and 38,457 in 2013. This may not have a huge effect on the overall results (although in view of the very small mileage saving claimed these differences could be significant) but it indicates the sloppy use of data by Mr Ellis.
3. Zone of Existing Shopping Destination
Mr Ellis has only taken account of the centre which attracts the largest market share in this zone – in this case Liverpool City Centre. 70% of the expenditure in Zone 1 goes elsewhere.
4. Distance to existing Shopping Destination
This is purely a geographical figure. We know that over 70% of those residents from Zone 1 who visit the City Centre do so by public transport. Any purported saving on distance will not necessarily mean a saving in car trips and could equally involve an increase in car trips.
5. Average percentage of population at Main Shopping destination
Mr Ellis claims to averaged the survey results for the different categories of comparison shopping from the Household Survey to arrive at a figure of 30.25% of population spend going to Liverpool (in Zone 5). He doesn’t explain precisely how this has been averaged and we have been unable to duplicate his result. Different people may have responded to the questions dealing with different types of goods and their visits to the City Centre may be more or less frequent depending on the types of goods involved.
6. Population shopping at Main Shopping destination
Mr Ellis now recognises that the figure he has used relates to population and not to households. He has applied the percentage figure from the previous column to the inaccurate population figure from Column 2 which gives a figure for the proportion of the population who shop in Liverpool City Centre. However, this cannot be equated with trips - which will probably be undertaken on a household basis. The population figures, of course, include children. The percentages of population derived from surveys is a perfectly valid tool for estimating how expenditure patterns will be affected by development because the figures for expenditure per person take into account demographic factors. Simply because 30% of population expenditure goes to centre X this cannot be equated to a number of trips to centre X unless one knows how frequently visits are made to the centre by respondents to the survey. It cannot be used to compare the number of trips, and therefore, distance travelled to another centre.
7. Total two way existing distance
This is a mathematical result of multiplying the proportion of population who shop in Liverpool with the geographical distance between Liverpool and the centroid of that Zone and multiplying it by 2 to give a two way distance. This gives a notional figure based on the assumption that 30.5% of the 2001 population make a trip to Liverpool for comparison shopping. However, the figure provided does not make any assumption as to how frequently they might make that trip nor again does it make any assumption as to by what means of transport they make the trip. Without that information it is a meaningless figure which simply tells you that Liverpool is further away from the centre of Zone 1 than is Kirkby.
8. Distance to KTC from origin Zone
This is again simply the geographical distance from the centroid of Zone 1 to Kirkby town centre.
9. Proposed % of population shopping at Kirkby
This is now said to relate to the uplift in market share as shown in TEV/SUPP/2. The previous version of this Table had used the anticipated total market share in each Zone from Table 16 of the original retail assessment. This is the material and critical change in the methodology used.
10. Population uplift shopping at Kirkby
Mr Ellis is still misquoting and misunderstanding his own table. Column 10 is headed as I have set it out above. However, Mr Ellis says “Households Shopping at Kirkby – for households read population. The value is calculated by multiplying (column 2) by (column 9).” In fact he is calculating the extra proportion (the uplift) of the population which Mr Williams estimates will go shopping in Kirkby if this scheme is permitted.
11. Total proposed two way distance to Kirkby
This is now expressed as the two way distance travelled by the increase in the proportion of the population who will spend money at the new development and in Kirkby if the scheme it is permitted.. This is a slightly more valid calculation than the one which was done in the original table although it is not clear whether Mr Ellis understands what the figure represents – and it still suffers from the flaws in that we don’t know how frequently people will make this trip, whether it will replace a trip to another centre or be in addition to such trips, nor whether these trips will be made it by car or by public transport. As the distance to the new centre is shorter it is probable that people may make more frequent trips. As parking in the proposed scheme will be free (and generous) then it is probable that those who have cars will use them and the likelihood that people will use taxis will increase.
12. Total Two way distance still travelled to existing retail
This is where Mr Ellis descends into a bizarre and incoherent attempt to justify his original table.
“the value is calculated by subtracting (column 10) from (column 6), multiplying that sum by (column 4) (or the average of column 4 where there is more than one zone of existing main shop) and multiplying that sum by two . . .” i.e. 11,185 (number of people shopping in Liverpool) -14,857 (extra number of people who will be shopping in Kirkby) multiplied by 11.6 (the distance to Liverpool) multiplied by 2. This would result in a negative figure of -3672 people whose journey was being saved by 23.2 miles. To include this phantom band of travellers would obviously make his table a nonsense – as was Mr Ellis’s original table which was not calculated on an uplift basis! So he has entered zero in this column – which of course still assumes that everyone who used to travel to Liverpool will now travel to Kirkby. This is patently wrong. Mr Hollis estimates that between 21 and 22% of the population expenditure from Mr Williams’ Zone 1 will still go to Liverpool if this development were to be permitted. This figure will include expenditure from people who continue to use both centres e.g. those who used do the majority of their shopping in Liverpool in a single trip but who now make two trips – one to Kirkby and then one to Liverpool. In other zones where more than one existing centre has been used the inaccuracies will be exacerbated by the attempt to average the distance travelled to these centres by different proportions of the population.
13. Total Future Two Way Distance
This figure would only be remotely helpful if all trips to LCC did transfer to Kirkby, if we had similar information relating to other centres currently drawing trade from Zone 1, if we knew that a single trip to these centres was replaced by a single trip to Kirkby, and if we knew that the same proportion of trips currently undertaken by public transport to LCC would be taken by public transport to Kirkby. As Mr Ellis has not looked at the 50% of existing trips which neither go to Liverpool or to Kirkby, as it will be the case that a significant percentage of trips will continue to made to Liverpool, as it is the case 70% of existing trips are made by public transport and as we don’t know whether having a huge centre at Kirkby within a shorter distance from the centre of this Zone will increase or decrease the overall number of trips made, the figures are meaningless.

D. General By obtaining and using appropriate survey data it would have been possible to have estimated (albeit necessarily in broad brush figures) what the existing total mileage to all centres amounted to. By asking the right questions in the survey it would have been possible to know much more about the frequency of trips to these centres and the mode of transport. The Applicants could, therefore, have presented evidence on this topic which had some statistical validity. They have chosen not to do so and have, therefore, presumably deliberately, failed or declined to answer one of the questions that the Secretary of State expressly wished to be informed about.


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