What the ministers will say today

I’ve mentioned before that parliamentary select committees tend to be pretty good. Slightly less of the absurd archaic jargon and formality and front-bench pantomime of the House of Commons and slightly more incisive discussion and in-depth inquiry. At their best, they will ask all the right questions and won’t accept evasive non-answers. This morning, the House of Commons Transport Committee will be putting their questions on cycling to junior ministers — Mike Penning, Roads Minister, and Norman Baker, Under-Secretary for The Bits Of Transport The Government Doesn’t Really Care About. I don’t know whether it is a good or a bad sign that they are [choosing to / have run out of ideas and been forced to] turn to twitter for inspiration on what to ask. I’ll choose to interpret it as an acknowledgement of the extent to which online discussion has moved the cycling argument and campaigning forward over the past couple of years.

Lots of great questions have been tweeted. A few of them are spot on. A few of them are completely bonkers. Most of them are nice, but completely wrong for this forum. “How do we make this an 8-80 cycling country?” Right question, wrong situation. This should be a proper forceful cross examination. Given their record, the ministers should feel like they’re on trial.

The exact questions that come up are not the most important things about the session. Whatever opening questions are thrown at them, we know that the ministers will bring out their stock evasive statements. We know that they will say these things because it’s what the ministers always say when questioned about cycling, and because it’s what so many of their predecessors have said for thirty years or more. The only thing that could stop the ministers from saying these things is if a member on the committee has been so taken in by the evasive statements that they say it themselves before the ministers have a chance to. I have already judged the ministers for the fact that will be saying these things. I will judge the committee by whether they let the ministers get away with it.

The ministers will say:

1. “Cycling is booming.” Mike Penning said it just last week in questions in the house: “Cycling is very popular in this country, and becoming even more so.” As we’ve seen, at a national level, there is little more cycling now than there was when cycling hit rock bottom in the early 1970s. Cycling has seen small fluctuations and localised booms and busts, largely unrelated to cycling-specific policy, for three decades. If government policies and actions are responsible for the current levels of cycling, then that does not reflect well on the government. Even if it were true that “cycling is booming” now — as politicians have claimed so many times before — the ministers should have to explain how they are going to capture and build upon the boom this time around and avoid, as in previous “booms”, the bubble bursting.

2. “We’re funding Bikeability.” Despite pantomime bad guy John Griffin’s recent claims that cycling proficiency is “not on the agenda any more”, cycle training is one of the few things that the current government has a relatively good record on — as it never passes up on an opportunity to remind us. There are several interesting problems with cycle training (which I’ll probably get around to discussing on the blog one day), but on balance, it’s probably a good thing that the government are funding it. Governments have been boasting about “promoting” cycle training and “encouraging local authorities” to fund it for at least as long as they’ve been talking about the “boom” in cycling, but it wasn’t until 2006 that central government (through Cycling England) finally gave up prodding reluctant local authorities and started paying for it themselves (Scotland, as usual, beat England to it by a few years; London still hasn’t caught up with England: the mayor continues to rely on the patchy coverage of the boroughs). It’s a good thing that this government decided to save the Bikeability training programme from the ruins of Cycling England, but it’s time they stopped using this fact to distract from the still gaping policy, strategy, expertise and funding gap left in Cycling England’s place. Bikeability on its own does nothing to deliver a cycling policy. The government promised very early on to fund Bikeability for the duration at a rate of £11 million per year, and they confirmed this in the local transport policy paper in January last year. That’s it. Job done for the term of this government. It’s time they stopped putting out new press releases “announcing” the funding every few months, and stopped citing it as evidence that they are working hard and making progress.

3. “Local authorities can bid for LSTF funds: it is right that local authorities decide what to do in their area, we can only encourage them.”  The we’ll-scrap-everything-and-call-it-localism thing. We’ve tried this approach to delivering on cycling policy before. For quarter of a century, in fact. In 1982 the Thatcher government had a policy for growing cycling. They “encouraged” local authorities to include cycling projects in amongst all the big road projects that they submitted for central funding. In 1995 the Major government went much further and created the National Cycling Strategy, which set a target of quadrupling the cycling rates by 2012, and they “encouraged” local authorities to implement it. These policies came and went, failing to make the slightest difference to the national cycling rates because they relied entirely on reluctant local authorities to implement national policy. Authorities took the grants, generated plenty of work for their highways departments, but rarely managed to generate any cycling. The same thing can be seen now with grants for sustainable transport, a large part of which seem to be cleverly diverted into road schemes disguised as things like “bus rapid transit routes” or “town centre pedestrianisation (with diversionary routes)”. Few local authorities have the vision or the expertise to do really great things for cycling with the grants on offer. That is itself a problem, but especially so when local authorities are expected to deliver national policy on cycling. It is, after all, why the ministers don’t rely on “localism” in the delivery of cycle training.

The Blair government, after eight years of continuing this course while repeatedly revising down the targets of the National Cycling Strategy as the deadlines flew past without a hint of any real “cycling boom”, finally acknowledged that this doesn’t work:

The Government are committed to encouraging more cycling in England, given the benefits in terms of transport, public health and the environment. Today the Department for Transport is publishing a review of the 1996 National Cycling Strategy… The key findings of the review are that:

1. whilst investment in cycling has increased substantially in recent years, there has been no commensurate increase in cycling levels;
2. The Government need to get a better return on their collective investment in cycling—for transport, sport, leisure and tourism;
3. cycling is not sufficient a priority for local authorities that we can rely on them as exclusively as we have to date to deliver an increase in cycling.

And so Cycling England was set up — not to ride roughshod over local councils and local people, but to lend to them expertise and oversight to ensure that what little money the government did give to cycling would be spent efficiently and effectively. It was the first sign of progress after 25 years of trying the same things over and over without any growth in cycling, and during its tragically short lifetime it managed to do more with the little resources it was given than the sum of local authority achievement from the previous quarter of a century of “encouragement”.

As Earl Howe, Conservative minister at the Department of Health, described the very much not “booming” cycling rates in 2008 when still in opposition:

How the Government have allowed that dismal situation to come about is not particularly difficult to diagnose; they took their eye off the ball. They did not manage to hold local authorities properly to account for delivering on the targets. The ball was picked up again in 2005, when Cycling England was created…

The present coalition government burned Cycling England on the bonfire of the quangos. It was one single sentence buried in a gesture to briefly placate right-wing newspaper editors. They didn’t just drop the ball, they kicked it into the long grass. And so we are back in the same position as 1982, 1995, 2005, and every year in-between: a national policy ostensibly to enable and encourage cycling, but which relies on usually underfunded, often unwilling, not infrequently incompetent, and always misadvised local authorities for implementation. When the ministers admit that, yes, their government abolished Cycling England, they will point to the LSTF and claim that the money is still there. But the point is not that the funding was taken away. It is that the ministers have deliberately opted for, in the words of the 2005 report, a worse return on their investment. If, that is, local authorities consider it a priority to put in bids for cycling projects at all.

If the ministers don’t say these things, or use any of the other tired stock distractions and excuses of thirty years of failing to deliver, I can at least be consoled in my embarrassment of being wrong in public by the pleasant surprise that the stuck record has been changed. But I think they will say these things. They always say these things, and these things have always been said, since the policy to “encourage” cycling was set more than three decades ago. I hope that the select committee don’t let them get away with it. The ministers should feel like they’re on trial for what their government has done.

The DfT’s crap cycling manual

No sooner had I posted a list of things for Norman Baker and his colleagues to be doing — to prove that they were doing things that will actually make a difference, rather than just passing the buck to under-resourced and poorly supported local authorities — than they acted. Baker and road safety minister Mike “Petrolhead” Penning have written a letter to local authorities, encouraging them to, er, look at their junctions and invite businesses to sponsor cycle lanes.

I don’t think many people have fallen for this charade. There is little point in simply suggesting that local authorities rebuild junctions. If they did — and they’re not going to on any significant scale unless and until they find the money from somewhere (and that’s unlikely to be from sponsorship), but suppose they did… — they would go through the normal design process and, er, the instructions would tell them to build the same cycling hostile crap as before.

There are reasons why we have atrocious junctions and crap cycle facilities. Our engineers and lowest-bidder contractors have been trained to build these things. They are also told explicitly not to build the sort of high quality infrastructure that we need. If we are ever going to make any significant advance, the government — central government — needs to do something to help our engineers into the 21st century. The first and most obvious step is to revise the guidance — the manual — that makes local authorities build crap.

The Department for Transport have, over the years, produced a number of guidance documents that tell council officers and consultants how to build roads and streets. Things like the “Design Manual for Roads and Bridges”, which tells you how to build a motorway… or city streets, if you like your streets to look and be used like a motorway. Better streets are built according to the principles of the more modern and civilised “Manual for Streets 2”.

“Cycle Infrastructure Design” (PDF) — commonly known by its serial number, “Local Transport Note (LTN) 2/08” — is the document which sets out the principles for building for cycling, and all the technical details of the government’s recommended facilities. The devolved administrations in Scotland and London have produced their own manuals which vary slightly from LTN 2/08.

Some cycle campaigners are fans of LTN 2/08 and think that if only it were strictly followed things would be better. In their briefing to The Times last week (PDF), for example, cyclenation say:

DfT publication LTN 2/08 (Local transport note no. 2, 2008) is generally good at setting out guidance for cycling provisions, but frequently goes unheeded.

I understand where cyclenation are coming from, and I think no ill of them for writing this. Because most British main roads and cycle facilities are even worse for cycling than LTN 2/08 recommends. Following the manual would be an improvement. But not much of an improvement. Saying that LTN 2/08 is good shows just how abysmally low our expectations have sunk.

The manual largely consists of guidelines rather than strict rules, and the guidelines are frequently broken. Certainly there are, as the cyclenation briefing says, cases where the guidance has gone unheeded and we have ended up with crap cycle facilities. But there are also cases where the guidance has gone unheeded and we have ended up with something far better than would have be provided had it been followed: some of the best (and yes, in this country “best” is hardly “great”) examples of on-street infrastructure — the tracks on Camden’s Royal College Street, for example — break all of the rules of LTN 2/08. And all too often — through a combination of poor training in how to use the guidance, competing political demands like “smoothing traffic flow”, and the many fundamental failings of the guidelines themselves — the guidance is heeded, and the result is still a crap cycle facility.

Because LTN 2/08 isn’t good. It frequently endorses the wrong things. It recommends against international best practice infrastructure and omits almost every detail of it. And it fails right from its first fundamental principles, which is why anybody can “heed” the guidance and still build whatever crap they like. I think that LTN 2/08 is a greater hindrance than help for cycling and that replacing it is a necessary step.

The introductory section of LTN 2/08 is the most widely endorsed. It contains a series of underlying principles for designing for cycling. Some of it is very good — the need for “convenient, accessible, safe, comfortable and attractive” space for cycling, for example, and the need to think at the level of the network, not just streets and routes. There is something of a disconnect between these principles and the rest of the guidance, and the good principles rarely shine through in the built designs. But it is also far from the case that the underlying principles are all good.

The first problem that leaps out while reading the introduction is the Hierarchy of Provision. I’ve written before about why the Hierarchy is the wrong approach to the problem, so I won’t here, except to reiterate that the Hierarchy is not fit for the role that it has been given — that of central formula for deciding which solution is appropriate — which is one reason why so many inappropriate solutions have been implemented.

The second fundamental problem is that LTN 2/08 endorses “dual networks”. It correctly identifies that different cyclists have different needs and abilities, but from this fact it draws some very wrong and damaging conclusions. “Some cyclists are more able and willing to mix with motor traffic than others. In order to accommodate the sometimes conflicting needs of various user types and functions, it may be necessary to create dual networks offering different levels of provision, with one network offering greater segregation from motor traffic at the expense of directness and/or priority.” That is, new, nervous and child cyclists will be grateful for a crap facility that gives way to every side road, or a winding backstreet route, while confident cyclists will want to be in their natural place — on the road, with the traffic, riding in the vehicular style. Indeed, the former category are expected to eventually cast off their training wheels and graduate into the latter  category.

I would have hoped that “dual networks” could have been the one thing that might be able to unite cyclists in opposition. As cyclenation say in their briefing to The Times, crap cycle facilities can do more harm than good when other road users get indignant at your refusing to use them. But I know there is one cycling campaigner and consultant who is proud of his dual network, and just in the past few weeks LCC’s Go Dutch campaign has also taken a turn down the dual network path. I think this is the wrong path: when you stop designing infrastructure that’s good enough for everybody, you tend to end up with stuff that’s good for nobody.

The effect of the “dual networks” principle in LTN 2/08 is that neither “network” is satisfactorily designed. The low-traffic “network” can be designed down: it can concede priority, take circuitous routes, share busy pedestrian spaces, and even advise dismounting — yes, LTN 2/08 says elsewhere that those solutions are undesirable, but, hey, this is just the training network, they’ll soon graduate onto the road so what does it matter? And when it then comes to fixing the main roads and busy junctions, engineers will “take into account the type(s) of cyclist expected to use it”, conclude that the inexperienced and nervous cyclists will be usingthe other “network”, and design the roads and junctions accordingly. You can see the wretched result of the dual networks principle all over our cities — famously on the Euston Road, where the cycle route leads you along “a sort of fiddly thing”, while Real Men like Boris Johnson prefer to “scoot down the underpass“.

Theoretically the dual networks don’t have to be substandard, of course. But if you design infrastructure that isn’t substandard, there’s just no need to think in dual networks. The Dutch also recognise the variety of cyclists. Their engineering manual recommends designs of sufficient quality to accommodate that variety. Their designs work. The idea that cyclists will want to graduate on to vehicular cycling — that it is aspiration rather than a survival strategy — is perhaps one of the reasons why LTN 2/08 entirely omits quality separated infrastructure… except where it gives spurious reasons not to consider it.

The authors of LTN 2/08 have obviously not looked at Dutch solutions or the Dutch manual. There are a total of three references to the Netherlands and three further references to the continent in the document. Three of those references are about cycle parking. One is in an aside about roundabout geometry. A Dutch study measuring overtaking distances — probably irrelevant to current British conditions — is mentioned. Finally, the authors have this to say about modern European cycle track design:

“As a result of concerns over the safety of parallel cycle tracks crossing side roads, it is becoming common European pratice to reintroduce cyclists to the main road in advance of a junction. Cyclists pass the junction on the carriageway and then rejoin the cycle track.”

It’s just bonkers.

The final fundamental conceptual problem with LTN 2/08 is not explicitly stated, but is written right through the guidance. Despite being the cycling-for-transport infrastructure guidance, despite being introduced with a reminder of why cycling should be supported, the document just doesn’t treat cycling as a serious form of transport. That’s not a problem specific to LTN 2/08, obviously, and it will take more than just revisions to a document to change the entrenched culture of the nation’s highways departments. But it’s especially dissapointing to find the document so riddled with it. It is clear that the authors are stuck in the car-centric paradigm and lack imagination for how things could be.

“Advisory cycle lanes,” for example, “are not recommended where they are likely to be blocked by parked vehicles.” Not, “car parking should be restricted in cycle lanes.” We’re told that we like cycling in bus lanes: “They are preferred over off-road facilities as a result of the advantage of remaining in the carriageway and therefore having priority at side roads” [my emphasis]. This is the guidance for providing for bicycles and it can not even imagine a world in which bicycles might have priority over turning vehicles. This is especially bizarre given that, technically, pedestrians have priority over turning vehicles — though pedestrians bold and brave enough to take it are ever rarer. To me it seems so blindingly obvious that the natural arrangement would be that anybody continuing straight would have priority over those turning, regardless of the means of travel of either party. The authors of LTN 2/08 can’t imagine that world — can’t imagine that there could be any alternative to our might makes right of way world.

What of that top-of-the-hierarchy solution, “reducing traffic volume”, if highways authorities can’t even imagine a cyclist having priority over car parking or motorists leaving their driveways? This is a problem that obviously goes far wider and deeper than this one document — Karl’s experience of the LTN 2/08 in practice illustrates the cultural problem we face. But replacing this document has to be one of the first steps to changing that culture. This is the document that Norman Baker says “provides comprehensive good practice advice on a range of practical infrastructure measures to help cyclists,” when he tries to shrug off the Cities Fit For Cycling campaign. It doesn’t. It’s part of the problem, and it’s his problem.

These are just the problems with the fundamental underlying principles. Just wait ’till I get around to listing the ridiculous details — the crap facilities it recommends and the almost complete absence of of best practice solutions from this “comprehensive good practice” guide…

After Westminster Hall, where next?

I have been neglecting this blog, both pulled away by other projects and watching with awe the unfolding of The Times‘ Cities Fit For Cycling campaign. I will assume that all of the readers of this blog have managed to keep up with those events through other sources, and have signed up and lobbied their representatives.

On Thursday afternoon, of course, the Cities Fit For Cycling campaign reached Parliament, with an excellent turnout of MPs enthusiastic for cycling and an astonishing degree of cross-party agreement about the things that make cycling unsafe and unattractive, and the sort of solutions that should be pursued. Unlike Boris “keep your wits about you” Johnson, the assembled MPs recognised that fast and busy roads are the main barrier to people making journeys by bicycle, and they recognised that Britain’s roads are not a natural and immutable phenomenon but things that we can alter to make less dangerous and more attractive for cycling.

There is, of course, only so much that backbench MPs can do, and the picture of Dutch-style cycling in Britain that one-by-one the MPs painted has so far been ignored by those who actually have the power to make a difference.  It is up to ministers to turn the debate into action, and the minister Norman Baker’s response to it all was, of course, embarrassing. Early Day Motions and backbench debates don’t, by themselves, change anything, and as Robert Davis and Cycalogical both point out, we should not be naive and think that the mere fact that this one debate has occurred means that we have received any of the things that were asked for.

But nor should we be too cynical and pessimistic: exciting things are happening. For as long as I’ve been writing about transport, cycling campaigners have tried to tell me that there is no point in asking for high quality cycling infrastructure because there isn’t the political will for it: there aren’t the numbers or the demand. Well the events this past year, and these past few weeks especially — the growing and multiplying flashrides and protests, the rise of cycling as an important London election issue, the Times campaign, and now the remarkably large show of MPs who really get it — have suggested to me that there are the numbers and there is the demand for change. Yes, promises have been made and broken before. But we know much more now — not least, of the alternatives that are possible. Now is the time to learn from those past failures, but not to learn that failure is inevitable. We must make sure that the issue remains at the top of our MPs’ agendas, and we must now set out exactly what ministers need to do, so that they can not fob us off with insufficient funds spent on inadequate things. This could be our “Stop The Child Murder” moment, but only if our efforts are sustained and focussed.

Norman Baker and David Cameron have already claimed their support with many words and few actions. It is, of course, obvious when poor Norman Baker is fobbing us off with a few pennies, barely enough for tiny isolated local incremental improvements; or when our MPs are trying to pass the buck to under-resourced local authorities. It needs to be equally obvious what real activity would look like.

The Times have set out the things that they think should be done in their manifesto. It’s a nice try, and identifying specific tasks for government — so that we can see clearly when they are or are not getting on with it — is exactly what we need to be doing. But The Times‘s list is not quite right. Chester Cycling has set out a better set of objectives for infrastructure, alongside an excellent set of principles for guiding policy discussions and keeping us on track.

My own list of tasks for ministers would place infrastructure at the top — because it’s the biggest, most expensive, and highest impact task — and look something like this:

Norman Baker’s department must get to work revising or replacing the engineering manual for cycling infrastructure — one of the most important promoters of crap cycle facilities and an active impediment to the import of international best practice — and changing the way that highways departments think about building for the bicycle (with the help of The Times‘s suggested “cycling commissioners”, perhaps). The Times are correct to identify junctions as the top priority for rebuilding, but unless we change the engineering manuals and culture, the rebuilt junctions won’t look any different from before. I will go into this in great detail in forthcoming posts.

The Times are absolutely right that funding needs to be redirected to cycling — more, even, than they specify (and taken from out dated relief road schemes). But of course large sums should not be handed out just to be wasted on substandard stuff that will need fixing later. In the first year, while a better engineering manual is being prepared, spending should be focussed on ensuring that we have the right expertise — the sort of expertise that Cycling England was just beginning to build up when it was cut — and that local authorities are ready to spend the money on something that actually sounds sensible and worthwhile when it does become available. Meanwhile, since almost everything that the DfT does is dependent on the Treasury thinking it’s a good idea, I imagine it would be sensible for Baker, Greening and The Times to be specifically working on those who hold the purse strings — making the case for serious and sustained investment.

The Times are right that 20mph should be the default urban speed limit, cycle lanes or not. 20mph is increasingly the urban speed limit, and most authorities would like it to be far more widespread, but 20mph zones are held back by the expense and bureaucracy of implementing it street-by-street. Given that this government is a fan of all that “libertarian paternalism” stuff — the latest being to make workplace pensions opt-out rather than opt-in — they should make 20 the default urban limit. Authorities would then have to go to the expense of opting out, consulting and erecting signs on the few roads where the appropriate limit is 30mph, rather than on the very many where it is 20.

The Times rightly identify big trucks as a problem. They suggest some sensible enough technological solutions to the danger they pose — alarms, sensors, safety bars, and the like — but bizarrely suggest that they only need to be present on trucks “entering city centres”. Vehicle design standards are generally handled by the EU these days, and my guess is that the EP is probably the best place to pursue this. However, there are steps that this government should be taking: standing up to the haulage industry’s relentless demands for bigger and heavier trucks, and pushing those big trucks back out of the city centres and narrow streets that should never have been expected to accommodate them.

There is one thing conspicuously absent from The Times‘s manifesto, given their focus on road danger and the many tragic stories that have been raised both in the newspaper and repeatedly by MPs who had lost constituents. They say nothing about getting dangerous drivers off the road. It is abundantly clear that in recent years we have developed a massive problem with the investigation of dangerous driving. Between us we could compile vast lists of hit and run incidents and near death experiences that have all ended in the police giving up because of lost files, untraceable number plates and the vehicle owner claiming not to have been the driver. Meanwhile, when cases of dangerous driving do make it to court, the sanctions are woefully inadequate. If the government were serious about tackling road danger, ministers from the DfT, Home Office and Justice department would be working on reforms to the policing and sentencing of dangerous driving.

Those are the areas where I think we should be expecting to see action from ministers, and I’ll go into more detail about each in later posts. The other items in The Times’s manifesto? Can’t argue with gathering more reliable stats on cycling: the “audits” that we’ve had in the past have usually been far from robust. Little to say about training: the funding for it is already adequate and protected, as ministers like to regularly re-announce (though I’m not sure why, given that vehicular cycling training has only been developed as a way to cope with their failed roads policies). And sponsored cycleways? A policy championed by Boris Johnson is the last thing cycling needs.

Norman Baker defends evidence-defying policy

Norman Baker, our ever embarrassing Lib Dem Minister for The Bits Of Transport That The Government Doesn’t Care About and part-time conspiracy theorist, pops up in the HoL Sci & Tech Committee report on evidence-based behavioural change policy, defending the coalition’s approach:

Even where ministers are aware of relevant evidence, other factors may lead them to disregard it. This appears to have been the case with current alcohol pricing policy (see Box 3, page 21). Norman Baker MP, a Minister at the DfT, explained: “evidence is best used to inform policy … but not to drive it in an unreconstituted way”; the Government “have to make choices based not just on the evidence-base … but also on the political objectives of the Government at a particular time, and to ensure fairness across the country”. Other considerations might include immediate reaction to events, judgements about ethical acceptability, cost and cost-effectiveness. These considerations might justifiably affect the extent to which a policy is based on the available evidence.

What does “political objectives of the Government” even mean? It sounds awfully like “ideology”. What does “immediate reaction to events” mean? Sounds to me a bit like outlawing a recreational drug because a couple of people who coincidentally used it recently died, or locking a lot of people up for petty crimes because they happened in the context of a recent big news story.

Of course, cost, cost-effectiveness, ethical acceptability, and indeed general public acceptability must be taken into account. But those things are pieces of evidence like anything else. This stuff is all part of the evidence that evidence-based behavioural change policy needs to be based on.

As the report itself goes on to discuss, behavioural change policies will fail if the public does not understand the problem — or the magnitude of the problem — that the policy is trying to solve. The solution must be seen to be proportionate to the problem. Sometimes you need to prepare the public and make your case: a few years of “clunk-click” paved the way for seatbelt legislation. If an intervention is a really good one, it only needs to be on the border-line of public acceptability to work and to very quickly become accepted: opposition to the ban on smoking in public places quickly disappeared, and it takes effort to find people opposed to the congestion charge these days.

Equally relevant is the fact that the public acceptability of interventions depends on their success. Design an intervention that doesn’t actually work — perhaps by ignoring the evidence — and you invite a backlash. The report cites the example of high alcohol prices in Scandinavia. This could perhaps help to explain the media’s obsession with The War On The Motorist: policies to tackle the problems of mass motoring might be unpopular if the number of vehicles on the road carries on growing regardless (even if the situation would have been even worse without those policies).

I don’t know. The formula might be complicated, but I can’t think of any part of it that should not be based on real world values. Can anybody see a favourable interpretation of Baker’s words?