Section 10

STAG Technical Database

Section 10

Integration

3 December 2013

Version History

Changes since STAG Refresh, May 2008

Change number Section updated Date
1 Add reference to Policy Assessment Framework December 2013

Contents

10. Integration
10.1 Introduction
10.1.1 Transport Integration
10.1.2 Land-Use Transport Integration
10.1.3 Policy Integration
10.2 Transport Integration
10.2.1 Movement of People
10.2.2 Movement of Goods
10.2.3 Presentation of Information
10.3 Transport and Land-Use Integration
10.3.1 Policy Comparison
10.3.2 Consultations
10.3.3 Pro-active Analysis
10.3.4 Interdependence of Land-Use and Transport Options
10.4 Policy Integration
10.5 Participation and Consultation
10.6 Reporting

10. Integration

There are three sub-criteria to Part 2 Appraisal against the Integration Criterion:

  • Transport Integration;
  • Transport and Land-Use Integration; and
  • Policy Integration

10.1 Introduction

In Travel Choices for Scotland (1998), the following was said about integrated transport:

“We see an integrated transport policy encompassing:

  • Integration within and between different modes of transport – so that each contributes its full potential and people and goods can move easily between them;
  • Integration of transport with the environment – so that our transport choices support a better environment; 
  • Integration between transport and land-use planning – at the Scotland and local level, so that the two work together to support more sustainable travel choices and reduce the need to travel; and
  • Integration of transport and our policies for education, health and wealth creation – to make a fairer, more inclusive society.”

Of the above interpretations, Transport Integration with the environment is dealt with under the Environment Criterion, Section 7 of the STAG Appraisal guidance. This means that the following can be taken as the specific interpretations of the Integration Criterion:

  • Transport Integration – the degree to which an option fits with other transport infrastructure and services;
  • Transport Land-Use Integration – the fit between the option and established land-use plans and land-use/transport planning guidance; and
  • Policy Integration – the appropriateness of the option in light of wider policies, including those both central and local government.

Practitioners should note that for Transport Integration this does not include the physical fit with existing mode-specific infrastructure (i.e. how well a rail project integrates with the  existing rail network).  We would expect this to be captured by the TEE analysis.

These sub-criteria are different in terms of both concept and scope, and they therefore require separate treatment in the STAG study.

10.1.1 Transport Integration

An integrated transport system aids accessibility by connecting people to opportunities and goods to markets with the minimum inconvenience.  This is the source of the concept of the “seamless journey”.  However, interchange is a fact for many journeys made by bus, train or a combination of both. Interchange is also a necessary feature of any inter-modal freight movement and one which carries a cost.  Furthermore, facilities such as Park and Ride by their nature imply an interchange between the car (or other mode used to access the site) and the mode of public transport which completes the journey.

The Part 2 Appraisal requires detailed consideration of the following aspects of Transport Integration:

  • Services and ticketing; and 
  • Infrastructure and information.

In relation to services and ticketing, the Part 2 Appraisal should focus on:

  • Seamless public transport network (where the user’s experience is of a single, genuinely integrated system); and
  • Seamless ticketing (where no barriers are presented to purchasing whole-journey tickets).

A greater variety of impacts can be expected within the categories of infrastructure, interchange layout and information. Practitioners are advised to use established benchmarks where possible and to quantify impacts as much as possible.

With very few exceptions, efforts that improve the process of interchange confer a benefit on both those already making the journey and upon those who make a journey because of being attracted to the transport mode by the improved interchange. Many of the changes in the costs of interchange are covered by the cost-benefit analysis undertaken in the Transport Economic Efficiency (TEE) as part of the Economy section. This overlap therefore requires extra vigilance to avoid double counting of benefits arising from Transport Interchange developments.

The guidance in this section concentrates on the aspects of Transport Interchange that are genuinely additional to those in TEE analysis. Such differences are namely in the areas of quality, comfort and co-ordination. 

No Transport Integration impacts, over and above those covered under the Economy Criterion, are envisaged as a result of freight options.

10.1.2 Land-Use Transport Integration

In Part 2, the appraisal of land-use and transport impacts involves an active transport assessment carried out in accordance with established planning policy to gauge the likely impacts of an option in terms of existing and planned land-use developments.

The relationship between land-use and transport planning requires close attention.  Many of the decisions driving land-use are long-term, leading to an assumption that most studies should look on the land-use scenario as a fixed input.  This ignores the fact that developments in travel behaviour in recent decades have been greatly influenced by the locations and types of land-use.  It could be argued, in fact, that the land-use-transport relationship has been neglected in the past, leading to development decisions which have promoted car use and compromised the capacity of those without a car to access important destinations.

The natural conclusions of this discussion are twofold: that a positive approach to land-use and transport planning can pay significant dividends in environmental and social terms; and that it is very important to appraise this aspect of an option adequately. 

Developments in UK and Scottish Government policy in recent years have provided a clear framework for the integration of land-use and transport planning with a focus on sustainability and reducing the need to travel. It is expected that options emerging from STAG studies are consistent with existing policy.   

For the Part 2 Appraisal the relationship between the transport option and any major existing or proposed developments should be considered to determine the likely impacts of an option on existing and planned land-use developments.  Central to the appraisal completed against this sub-criterion is the process of comparison and consultation.  A general awareness of the need to promote sustainability and reduce the overall need to travel should be demonstrated by identifying key relationships between the option and relevant existing or future developments with the support of appropriate analysis.

A major aspect of the Land-Use-Transport relationship is accounted for by the effects of transport actions upon the functioning of the economy. These are dealt with separately in the Economic Activity and Location Impacts (EALI’s) under the Economy section.

10.1.3 Policy Integration

For Policy Integration, a series of checks is specified to establish the option's impact in terms of integration with Government policy outside those areas already captured under the other criteria:

  • The option's fit with the aims of transport and wider (non-transport) government policies and national transport targets should be tested in Part 1 Appraisal; and
  • Any genuinely additional benefits in the context of Scottish policy on disability, health and rural matters should be identified in Part 2 Appraisal, together with further social inclusion impacts.

Education, health and wealth creation are all well cited in Scotland’s Transport Future – The Transport White Paper (2004), as being policy areas of concern when planning transport. This reflects the simple observation that transport decisions have wide impacts upon communities.

Whilst the other aspects of the appraisal process will capture the vast majority of an option’s impacts, there is a need to consider the option against a wider policy context. The challenge is to avoid an overly cumbersome appraisal structure that strives to cover all facets of Government policy, but at the same time to identify key impacts beyond the areas captured in the body of the appraisal. The guidance below reflects a pragmatic approach; practitioners will need to assess which policy issues are relevant and therefore deserve attention.

10.2 Transport Integration

Government policy over transport has become increasingly focussed on moving passengers and freight onto railways, which is likely to involve modal transfer to/from road at the beginning or the end of the journey. Integration can then be divided into two separate categories – movement of people, and movement of freight. 

Given the degree to which TEE analysis can be expected to capture costs and benefits of transport interchanges, impacts which would be expected to be recorded under this criterion can only be done if the practitioners can answer definitely “yes” to the following two questions:

  • Is there an identifiable impact upon transport interchange resulting from this option?
  • Is it definitely the case that some aspect(s) of this impact will not be captured by the TEE or another aspect of the appraisal?

The text supporting the AST will need to include a brief description as to why the practitioners have answered yes to both. If the answer to one or the other is “no”, practitioners should write “no impacts” in the relevant box on the AST.

10.2.1 Movement of People

Assessing movement of people, the relevant aspects of transport interchange to consider can be divided into the following two broad categories:

  • Services and Ticketing; and
  • Infrastructure and Information.

10.2.1.1 Services and Ticketing

It is particularly important to avoid double counting in this area. The following impacts of an option on transport interchange should already be accounted for in the TEE analysis.

  • Time savings resulting from better co-ordination of services;
  • Reliability improvements (and, potentially losses) resulting from the establishment of procedures for holding one service for the arrival of another;
  • Monetary cost savings from the introduction of through ticketing; and
  • Savings of time and interchange penalties from the introduction of through services.

This leaves relatively little that can be identified under this category. Practitioners may argue that there are benefits in the following two areas:

  • Where public transport services have been co-ordinated to the extent that a claim can be made for “seamless” movement across a network (and if there is confidence that this level of integration will endure), it is legitimate to describe the system as a “seamless public transport network”. This reflects that the seamlessness confers benefits additional to those resulting from savings and new patronage;
  • Where ticketing across a network is made more convenient and simpler as a result of integration regardless of any discounts which may accrue to the user, a benefit entitled “seamless ticketing” can be argued for.

Neither of these claims can be made lightly. The extent of integration in each case will need to be considerable and should be supported by shared branding and whole-journey information. In both cases, practitioners should expect arrangements to be founded upon formal quality partnerships and other agreements of similar robustness.

10.2.1.2 Infrastructure and Information

These two aspects relate to what is provided at an interchange point independently of what transport visits the site.

It is expected that most impacts that are genuinely additional to those captured elsewhere in the appraisal will fall into this category. In the case of Park & Ride schemes and other options that facilitate interchange between private and public transport, it is likely that all additional impacts will fall into this category.

Practitioners should first ask whether there is an established benchmark against which to assess the value of the option. These could then be used as a best practice guide for railway interchange improvements. Citing the achievement of established performance thresholds will make it easier for Ministers to arrive at a balanced judgement of the option’s value.

Consideration of infrastructure and information relates to what is provided at an interchange point independent of actual public transport services. Practitioners should then embark on attempting to classify the impacts. The following is a list of typical areas of impact:

  • Quality of infrastructure: waiting areas, amenities on site (such as toilets, refreshment areas and shops), quantity and quality of seating;
  • Layout: distances between boarding points, changes of level, widths of corridors, physical accessibility/barrier-free design, weather protection; and
  • Information: provision of accessible information, provision of whole-journey information, accuracy of information (e.g. real-time), signing between points.

Security is not considered here since it should have been adequately covered under the Safety Criterion.

It is sometimes the case that detailed research will have been carried out to assess the willingness of individuals to pay for qualitative improvements such as those listed above. Practitioners should make full use of such data to derive a quantitative measure of impact if possible, unless the data has been included in generalised cost measures for journeys and the impact is therefore implicit in the TEE. Equally, where attitudinal information is available concerning the value placed by actual and potential users on qualitative improvements, this should be to the fore in the presentation of the findings. 

The preference should be for quantitative information over qualitative, if the quantities adequately capture the types of benefit. Moreover, where it is possible to make reasonable estimates of the value of such benefits, this should be done.

10.2.2 Movement of Goods

It is unlikely that any interchange impact in terms of freight movement will be truly additional to those captured by other aspects of the appraisal, for the simple reason that freight movement is governed by commercial decision-making, reflecting time, cost, security, and reliability. A better freight interchange will show its value in the business it attracts and the time savings it produces. 

Where practitioners are confident that a freight scheme has interchange impacts that are genuinely additional, they can identify them in this section of the AST, ensuring that accompanying text clearly sets out the rationale for the claim.

10.2.3 Presentation of Information

The qualitative nature and diversity of the impacts described, defies a uniform style of presentation. Practitioners should, however, attempt to quantify the number of passenger journeys in a given period (probably a year) affected by impacts on the movement of people. As stated above, survey information should be cited where available, as should performance against any established benchmarks. In particular, where interchange facilities have been made fully accessible, it is desirable to identify this explicitly. Other than this, practitioners should identify the categories from the list cited above (10.2.1.2) under which impacts have been identified, saying in each case whether the impact is positive or negative.

The two categories “seamless public transport network” and “seamless ticketing” constitute special cases and should be identified separately from any individual category of impact.

10.3 Transport and Land-Use Integration

Most of the guidance that follows is directed at the identification and, where appropriate, amelioration of any conflicts between the option and the planning policy. However, practitioners should not ignore consideration of whether the option might bring benefits in terms of facilitating the achievement of land-use aspirations.

A preliminary appraisal of the option’s fit with established land-use policy and environmental designations at a local and, where appropriate, national level should be carried out in Part 1 Appraisal. This will allow any serious conflicts to be identified early and so avoid any wasted effort in working up an option that is not viable. In its most specific sense, this is a test of whether any land required for the option is preserved for uses that are entirely incompatible with transport. There is a second, more general question of whether the option fits with the policies of local authorities and the Scottish Government concerning transport and land-use. If, however, objectives for the study have been derived in accordance with the advice in Section 3 Objective Setting, problems should be unlikely to arise.

Whilst the Part 1 Appraisal largely determines the option’s performance under this sub-criterion, there is scope for additional analysis to be carried out in the Part 2 Appraisal. It may be appropriate to do this, for example, where an option has not been precisely located until the later part of the study; here it would be necessary to revisit planning policy once a final location or alignment was proposed to check that no conflicts arose.

For the Part 2 Appraisal, the relationship between an option and any major existing or proposed developments should be considered to determine the likely impacts of an option in terms of existing and planned land-use developments. 

The main aspect of appraisal under this sub-criterion consists of comparison and consultation. Nevertheless, practitioners should show a more general awareness of the need to promote sustainability and reduce the need to travel, by identifying key relationships between the option and relevant existing or future developments and analysing them in sufficient detail.

10.3.1 Policy Comparison

In any transport planning exercise, there will exist statutory documents concerning planning which should be checked as a matter of course to establish any spatial conflicts. In the exercises to which this guidance relates, development plans comprising the following are likely to feature:

  • Structure plans; and
  • Local plans.

Any Environmental Report produced for SEAs of plans or programmes should be referred to for commitments and objectives.

Practitioners should take care to establish with confidence the nature and gravity of any spatial conflicts between the options under consideration and established planning policy at either level. However, because this will ordinarily form part of the Part 1 Appraisal, it is not appropriate to grade the compatibility. Rather, it will be necessary to record the conflict and to take a view as to whether it would be likely to jeopardise the feasibility of the option. This question can be more readily answered following the consultation described below.

Practitioners should give most credence to statutory documents (remembering that the approved structure plan and adopted local plan represents an authority’s legal position). However, they should take proper account of the age of a given policy for example, a local plan that is more than five years old may well be near obsolete and they should therefore take proper account of the policies being developed to replace it.

In addition to these documents, there exist a number of Scottish Planning Policy statements (SPPs), replacing the series of National Planning Policy Guidelines (NPPGs) which should also be examined to ensure compatibility. The key documents, which should be used in all planning exercises, are SPP17: Planning for Transport (2005) and PAN 75: Transport and Planning (2005).

In addition, it may be desirable to consider:

  • SPP2: Economic Development;
  • SPP3: Planning for housing (review in progress);
  • West Edinburgh Planning Framework (aimed at developing the area’s long-term co-ordinated plans to meet economic, transport and environmental needs);
  • SPP8: Town Centres and Retailing;
  • NPPG14: Natural Heritage;
  • SPP15: Planning for Rural Development;
  • PAN59: Improving Town Centres; and
  • PAN66: Best Practice in Handling Planning Applications Affecting Trunk Roads.

A full list can be viewed at http://www.scotland.gov.uk/planning under the policy and advice menus. Practitioners may wish to consult with the Scottish Government as to whether additional policy documents should also be consulted. They may also wish to follow the guidance on this topic set out in DMRB Volume 11.

10.3.2 Consultations

It is typical for studies to involve consultation with a number of stakeholders. In terms of Transport and Land-Use Planning Integration, it is appropriate to target individuals involved in planning decisions at the local and, if the scope of the option demands it, regional level. Whilst there is no blueprint for this type of discussion, practitioners should aim to establish the following:

  • Whether the option constitutes “the best fit possible” with planning objectives;

and

  • Whether any key stakeholder would have cause to oppose the option as presented.

It should be noted that there are specific consultation requirements for those options requiring SEA or EIA. These requirements are set out in, respectively: The Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004 and The Environmental Impact Assessment (Scotland) Regulations 1999.

Where some material objection may exist, practitioners should go on to explore whether alterations to the option could resolve any conflict whilst still achieving the key objectives of the option within the context of local policies.

For further details see section 10.5

10.3.3 Pro-active Analysis

For the Part 2 Appraisal, practitioners should carry out a proper analysis of the relationship between the transport option and any major existing or proposed developments likely to be affected. With an eye to the principles of sustainability and reducing the need to travel, they should investigate whether the option would be likely to increase or reduce the need to travel. Where the chances are that more trips will be made or that existing trips are likely to lengthen, practitioners should investigate any mitigation measures that could be incorporated into the option in order to reduce this negative impact.

This process is well established and is continuing to evolve. In effect, it is equivalent to the task of carrying out a transport assessment as described in SPP17 and PAN57, though starting with a transport option rather than one focussed on land development. Transport Assessment & Implementation: a Guide contains useful methodology, and consequently is not repeated here. However, the emphasis on identifying accessibility impacts in NPPG17 and PAN57 should be noted from two perspectives:

  • The analysis undertaken for assessing accessibility and social inclusion impacts (Section 11) may assist;
  • Double counting with the Accessibility and Social Inclusion Criteria findings should be avoided.

Evidently, practitioners will need to gauge the degree of detail required in undertaking such analysis and it is important that detailed research is not carried out unnecessarily. Again, this is a point on which SPP17 and PAN57 provide useful advice.

It will be necessary for practitioners to provide a commentary in the Part 2 Appraisal text. This should detail the process undergone, the sites thought likely to generate or attract more or longer car trips and the range of measures considered for mitigation. It should further relate the conclusions reached and the expected results of the mitigation measures decided upon. 

10.3.4 Interdependence of Land-Use and Transport Options

It is sometimes the case that land-use and transport options are worked up in tandem and that, in appraisal, a circular argument seems to arise whereby:

  • The viability of the land-use option depends upon the implementation of the transport option; and
  • The viability of the transport option depends on the trips that would be generated by the land-use development.

Such a situation is bound to make it difficult to establish the true merits of either option. However, Scottish Government research entitled Key Sites Appraisal Methodology for Development Planning (2001), produced findings that are incorporated in SPP17. One of the key objectives of the guidance is to locate major travel generating uses so that they can support more sustainable travel patterns. The original research document includes a useful glossary of terminologies for “key sites” relevant to the work being undertaken. Other research work results incorporated into SPP17 include An Integrated Approach to the Transport and Land-Use Planning Aspects of Development Applications, which is a helpful background example on transport assessment or travel plans. The following is proposed as a rule of thumb to help disentangle the respective impacts of the options:

  • The total costs and benefits of the combined options should be appraised against the established Land-Use objectives (probably set out in the local/structure plan) with the accompanying question: “could the land-use objectives be better achieved by some other means (perhaps involving other transport options)?” Here, the better achievement of land-use objectives should reflect a measure of value for money which will be a matter of judgement for the relevant land-use planners;
  • The total costs and benefits of the combined options should also be appraised against the established Transport Planning Objectives with the equivalent question: “could the Transport Planning Objectives be better achieved by some other means?”

Where the answer to both questions is “yes” this would appear to present a mandate to reconsider the wisdom of both options, subject to the following further test. Two answers of “yes” imply that there exist preferable alternatives in each case. The combined costs and benefits of these alternatives should be looked at against those of the original combination. If the costs and benefits of the alternatives appear preferable to those of the original, this would strengthen the case for review. If not, there may be an argument for the original combination on the grounds of “net” savings. This would not be conclusive but the very exercise is likely to have prompted a sufficiently thorough analysis of the options to ensure that the precise relationship between component options is much better understood.

By the same token, if the answer to both is “no” there would seem good cause to proceed with both. In a mixed case, it would make sense to see the combined options as serving the aims for which they appear optimal (e.g. if a better way of meeting land-use objectives cannot be found then the package of land-use and transport options should be seen as serving land-use objectives first and foremost). This should help to clarify the appropriate planning and funding paths.

The totalling of costs and benefits is likely to be only nominally possible – it will probably be a process of juxtaposition rather than aggregation.

10.4 Policy Integration

The need to keep this aspect of the appraisal tractable results in a straightforward process of checks to establish the fit of the option with wide government policy.

In the Part 1 Appraisal stage all that is required is a simple check as to whether the option fits with the wider aims, targets, and policies (non-transport) of the government. Practitioners should also indicate whether the option would have an effect on these wider objectives, indicating the polarity of effect.

The Policy Assessment Framework (PAF) (available in Section 17) should have been used as part of the Initial Appraisal, to assess and demonstrate the contribution of each option to meeting current Scottish Government transport policy objectives. 

The Part 2 Appraisal requires more detailed checks to identify complementary or conflicting impacts with the wider Scottish policy context, including, but not limited to, the Government’s Purpose. Additional benefits in the context of Scottish policy on disability, health and rural matters together with further social inclusion impacts should also be outlined. It should be noted that these checks should not be confused with the Accessibility and Social Inclusion impacts as discussed in Section 11. The purpose here is to check for compliance with legislation and policy in addition to specific accessibility issues, including but not limited to:

  • Disability - though the requirements of the Disability Discrimination Act 2005 will have been largely covered elsewhere in the appraisal, practitioners should briefly state whether the option has noteworthy impacts in terms of overcoming barriers for people with disabilities. Examples are that accessible vehicles are to be introduced in advance of the deadlines set in the Act or that station infrastructure will be enhanced beyond the requirements of the Act; 
  • Health - the health impacts of a transport option may be quite great, particularly if they lead to increased exercise on the part of a significant number of people. Practitioners should note instances of this, citing relevant legislation or policy as appropriate;
  • Rural Affairs - recent policy sets out a vision for rural Scotland in which rural communities strengthen or remain strong through retention of population and access to essential services. The consideration of EALIs as set out in the Economy Criterion (Section 9) will cover any impacts of a transport option as far as regeneration is concerned but where an expected impact is simply that a community or communities will not decline, this should be noted here. 
  • Social Inclusion: although the bulk of the social inclusion impacts will have been considered under the Accessibility and Social Inclusion Criterion (Section 11) there may be additional issues worth considering such as the opportunities for a training scheme to be offered through the transport option. 

The Part 2 Appraisal also requires a more detailed assessment of the consistency of options with national transport targets, for example for road traffic reduction.

Practitioners should not feel limited by the range of policy areas listed above. It is perfectly legitimate to identify additional policy implications associated with a transport option.

The PAF assessment which was undertaken at the detailed appraisal stage should be revisited at the Detailed Appraisal stage for all options that were taken through from the Initial Appraisal.  At this stage, the PAF assessment should draw on quantitative data that is available.  The professional judgement used to score options on the seven point scale should now be informed by quantitative data.  The outputs of the PAF should be used in conjunction with Option Summary Tables.

10.5 Participation and Consultation

Consultation should be integral when considering the impact of an option on Integration.  For example, in terms of Transport and Land-Use Integration it may be appropriate to target individuals involved in planning decisions at the local and regional level.  Furthermore, the movement of people is a key aspect of Transport Integration and users should be consulted to ensure account is taken of real and perceived integration issues.

10.6 Reporting

Reporting on Integration in the STAG Report should cover to some degree the three sub-criteria of Transport Integration, Transport  and Land-Use Integration and Policy Integration.

It should be noted that there is possible overlap and the potential for double counting between Transport Integration and the Transport Economic Efficiency (TEE) appraisal.  It is therefore important for practitioners to provide an explanation in support of the Part 2 AST in the form of answers to the following two questions:

  • Is there an identifiable impact upon transport interchange resulting from the option? and
  • Is it definitely the case that some aspect(s) of this impact will not be captured by the TEE or another aspect of the appraisal?

Under the Transport and Land-Use sub-criterion any conflicts and potential synergies with existing statutory documents concerning planning should be reported.  In addition it is necessary to demonstrate that a proper analysis has been undertaken of the relationship between the option and any major existing or proposed developments, taking into account the principles of sustainability and reduction in the need to travel.

The Policy Integration sub-criterion requires checks to establish the fit of the option with wider Government policies, e.g. on Disability, Health and Rural Affairs, and national transport targets. The links between the option and these wider policies should be documented. References

  • Travel choices for Scotland, The Scottish integrated transport white paper, The Stationery Office (1998);
  • The Scottish Executive (2005) SPP17: Planning for Transport;
  • The Scottish Executive (2005) PAN 75: Transport and Planning;
  • The Scottish Executive (2002), Scottish Planning Policy 2 - Economic Development;
  • The Scottish Executive (2003), Scottish Planning Policy 3 - Planning for Housing;
  • The Scottish Executive, The City of Edinburgh Council & Scottish Enterprise Edinburgh and Lothian (2003), West Edinburgh Planning Framework;
  • The Scottish Executive (2006) SPP8: Town Centres and Retailing;
  • The Scottish Office (1999), National Planning Policy Guidance Note NPPG14 - Natural Heritage;
  • The Scottish Executive (2005) SPP15:Planning for Rural Development;
  • The Scottish Executive (1999), Planning Advice Note 59 - Improving Town Centres; and
  • The Scottish Executive (2003), Planning Advice Note 66 - Best Practice in Handling Planning Applications Affecting Trunk Roads (including Annexes A and B).