The Government has published its draft National Policy Statement (NPS) for major roads and railways. With a return to predict and provide and a 'climate gag' clause, we're calling it a national disaster.
A lot is wrong with this policy – the belief that building roads will solve congestion, a complete disregard for the effects on local roads, a failure to recognise road-building on this scale would trash air pollution laws, and much more.
It's hard to know where to begin but, amongst all these problems, we think we have identified the worst three:
1. National need is defined as more roads and more car dependency
There are many, many problems with the Department for Transport's traffic forecasts, as we have highlighted for many years. National statistics show traffic is now lower than it was ten years ago and that forecasts since the 1980s have over-estimated growth. There is now a consensus among academics that building our way our of congestion won't work, that traffic trends in the coming decades will not follow the same patterns as the 20th century, and that traffic growth and population are decoupling in developed countries like the UK.
Unfortunately, the DfT's forecasts are being used to define what constitutes 'national need' in the draft NPS, making this policy effectively a plan to build enough new road space for more than 40% extra traffic by 2040.
This is hugely dangerous as it risks public money being spent on new infrastructure that is not necessary, and hugely damaging to the environment. Pressing ahead with a roads policy like this would stimulate needless new traffic in a bid to make the forecasts come true, with all the problems of noise, air pollution, safety, inactivity, car dependency and higher transport costs this would bring.
The policy also dismisses reducing demand with policies such as smarter choices, and does nothing to promote travel by public transport, walking and cycling within the planning system. Any kind of hierarchy putting demand reduction and lower impact modes of transport ahead of new road-building is completely missing, setting transport policies back 20 years to the days of 'Roads for Prosperity' and predict and provide.
2. Protection is weakened for biodiversity, wildlife sites, habitats, ancient woods and landscapes
Where the NPS is not governed by legal and international obligations, the draft policy threatens a range of ecological and landscape assets by protecting them only as far as they don't conflict with a 'national need' for roads (this 'need' being defined by the faulty forecasts).
The most threatening sections deal with:
- biodiversity - section 5.18 presumes road projects will go ahead and offers offsetting 'as a last resort' even though any last resort should actually always be the rejection of a scheme
- regional and local wildlife sites - section 5.24 says "Given the need for new infrastructure, these designations should not be used in themselves to refuse development consent."
- ancient woodland - section 5.25 says new developments that destroy ancient woods should be prevented, "unless the need for and benefits of the development, in that location, clearly outweigh the loss of the habitat"
- local landscapes outside national designations - section 5.141 says: "local landscape designations should not be used in themselves as reasons to refuse consent, as this may unduly restrict acceptable development"
For the most precious national assets, including National Parks and Areas of Outstanding Natural Beauty, it's hard to see how the protection offered by the draft NPS is any better.
Section 5.137 outlines the importance of nationally designated areas, but then says: "Nevertheless, the Secretary of State may grant development consent in these areas in exceptional circumstances. The development should be demonstrated to be in the public interest and consideration of applications should include an assessment of: the need for the development, including in terms of any national considerations, and the impact of consenting, or not consenting it, upon the local economy."
3. Climate change concerns are being gagged
Most outrageous is section 3.4, which takes the consideration of climate change out of the planning process for roads and railways altogether.
This would prevent local communities and campaigners concerned with the climate change impact of a scheme from citing this as a problem during planning applications, and would prevent examiners even from considering large amounts of new CO2 emissions as a negative impact of a scheme.
The clause says: "While, considered in isolation, individual schemes may result in an increase in CO2 emissions, the Government’s overarching plan for reducing carbon emissions will ensure that any such increases do not compromise its overall CO2 reduction commitments. Increases in carbon emissions from a development should not therefore need to be considered by the Examining Authority and the Secretary of State."
The justification given is that other Government policies will 'offset' the increase in carbon from new roads. But this is not supported by either the Government's own Carbon Plan from 2011 or the long term assumptions of the Committee on Climate Change (CCC). In fact, the CCC expects a 5% reduction in traffic compared with forecasts by 2027, which it assumes will be brought about by demand management measures. These have been explicitly rejected for main roads by this draft policy.
The consultation is open and a range of experts, local authorities, transport and environmental groups are preparing detailed responses, and many of these will be rejecting even the premise - let alone the details - of the NPS. But an overwhelming public rejection of this policy would be a real blow to the plans and would force the Government to take stock.
The Hazardous Waste NPS consultation in 2011 only received a total of 28 responses but, since putting our online action live late last week (and despite our website having an unexpected 12-hour outage), we've already beaten that number more 20 times.
There are still 22 days of the consultation period left. If we can spread this news far and wide and get these numbers up even higher, the Government will have to think very carefully about the problems in this draft policy before it puts a final NPS before Parliament later this year.
Our simple action lets you send a response directly to the consultation email address. We've provided a very short template, but adding more about views on what planning for 40% more traffic would mean for you, and why you think climate change needs to be considered in planning aplications, would make the response more effective still.
Find out more and respond directly to the draft National Policy Statement on National Networks here: https://www.gov.uk/government/consultations/national-road-and-rail-networks-draft-national-policy-statement