Transport Committee
Oral evidence: National Networks National Policy Statement, HC 903
Wednesday 28 June 2023
Ordered by the House of Commons to be published on 28 June 2023.
Members present: Iain Stewart (Chair); Mr Ben Bradshaw; Ruth Cadbury; Karl McCartney; Gavin Newlands; Greg Smith.
Questions 1–39
Witnesses
I: Rosie Allen, Policy Adviser, Green Alliance; Professor Phil Goodwin, Emeritus Professor for Transport Policy, University College London; and Ralph Smyth, Consultant, Transport Action Network.
Written evidence from witnesses:
Witnesses: Rosie Allen, Professor Goodwin and Ralph Smyth.
Q1 Chair: Welcome to today’s session of the Transport Committee. Before we start I have a little bit of housekeeping. The subject matter in front of us does not have the most user-friendly title. For ease of reference, as probably the easiest acronym, I shall refer to the NNNPS as the triple-NPS. You may have other ways in which you want to describe it, but for our purposes that will be what we call it.
For the record, I invite you all to state your name and organisation.
Rosie Allen: I am Rosie Allen, Green Alliance.
Professor Goodwin: I am Phil Goodwin. I am not representing an organisation.
Ralph Smyth: I am Ralph Smyth of Transport Action Network.
Q2 Chair: Welcome all. Thank you all for giving us your time this morning.
The draft NNNPS is of course building on the existing one. To start with a general question to each of you, what do you see as the main differences between the current one and the draft proposed one? In what areas is it better or worse than the current one?
Rosie Allen: We would say that the draft aimed to update the NNNPS to reflect legislative changes—environmental targets like the legally binding carbon budgets and net zero that have come into play since the previous draft. However, we would suggest that this new draft does not successfully take environmental targets into account and, further, that the statement of need is fundamentally incompatible with reaching net zero by 2050 for the transport sector.
Q3 Chair: Thank you. We will dig down into some of those areas in more detail in a minute, but at the moment I am just interested in headline opinions. Professor Goodwin?
Professor Goodwin: It is very clear that quite a lot of the rhetoric is different—the explanatory material, the concept of long-term visions and decarbonisation, and so on. It seems to me that there is little change in the core of the process of how road schemes are appraised and approved. I noticed that the Climate Change Committee, whose report was issued at a minute past midnight this morning, makes the same point: that it is still very weak with respect to the absence of the idea of reducing traffic growth rather than, as it says, simply meeting the demand predicted in the core national road traffic projection scenarios. It sort of means that we have a “predict and provide” core, surrounded by decarbonisation language.
Q4 Chair: Thank you. Ralph?
Ralph Smyth: It is a very good question. I have met with the DFT and it could not give a clear answer. It would have been helpful to say, “Here are the differences.” Looking at the contents, one major change is that the section on wider Government policy has been taken out. Although there are a number of namechecks of new issues like levelling up and wider environmental targets, they are not substantively incorporated. It is as if someone has put a healthy eating chart on the wall, but it is still chip butty with a side salad of crisps. In fact, in relation to Professor Phil Goodwin’s point, compared with the 2014 version, the policy on alternatives in the statement of need on demand management has been taken out. It is not simply that it is possibly worse on environmental grounds. It is worse at tackling congestion, because it is too embarrassing for the Government to mention other policies to cut congestion that are far more effective than road building.
Q5 Chair: The draft NPS looks to balance future demand for economic growth and better connectivity alongside aligning with net-zero commitments. Is there a fundamental incompatibility between those two goals?
Ralph Smyth: If I could jump back in there, there are other NPSs that Parliament is considering, such as energy. We know that we need to deliver much more renewable power. There could be said to be a concern here with wider environmental issues. The evidence is very clear that building more roads does not help to accelerate net zero, or tackle congestion. Even the Department’s own figures referred to in the NPS show congestion as much as doubling—even with a massive roads programme. Something very odd is going on when the Department says that we need to spend more money to maintain performance, while its own figures show it is declining. I would ask you to request the Minister or the Department afterwards to provide figures for their forecasts for congestion on the strategic road network. That is not broken down in the latest projections. Really that sort of information should be in the statement of need.
Q6 Chair: I can assure you that the Minister will be in front of us in a future session. Professor Goodwin?
Professor Goodwin: Just to add a point, it seems to me that there is a close consistency between the objectives of the decarbonisation strategy and the potential for welfare and an efficient, functioning economy, but both of those depend on the undercurrent of containing and reversing traffic growth, which is another of the Climate Change Committee’s themes. The proposition that building roads assists economic growth is one of the least provided with convincing evidence. It is much more likely that the co-benefits for health, safety, security and wellbeing that you can get from a good decarbonisation approach are more effective in improving the economy.
Q7 Chair: Thank you. Rosie?
Rosie Allen: I would build on what has been said by other panellists and say that, as the CCC pointed out in its report released today, as there is underperformance in other areas of emissions reductions in transport, there is a concerted need to take action on several policy areas. Modal shift is listed as one of those—reducing traffic and car miles driven. The statement of need in this draft of the NPS is not compatible with that.
Chair: Thank you. As I expected, that has stimulated colleagues to ask some supplementaries. Karl first.
Q8 Karl McCartney: Thank you very much, Chairman. A general question to all three of you: it seems that you believe that net zero trumps economic wellbeing in this country. Is that the case?
Professor Goodwin: I would not say that. I would say—
Q9 Karl McCartney: I think you just have.
Professor Goodwin: No, no. I would say that net zero done properly can contribute to economic welfare and growth more effectively than a strategy based on expanding the capacity of the road network. In other words, it is a false dichotomy. We can have net zero and a very good, functioning, efficient economy, with high standards of welfare, but both of them are enhanced by the reduction of traffic, rather than provision for the increase in traffic.
Q10 Karl McCartney: That is your belief; it may not be that of members of the Committee. You are obviously a big fan of the climate change report that came out at one minute past midnight. Do you not see it as evangelistic, in a way? All three of you have already mentioned that you are not big fans of extending the road network. Those of us who live in the real world, with electors who elect us, know what they have to deal with daily going to school or work. In places like Lincolnshire, public transport is never going to replace people’s private cars.
Professor Goodwin: Absolutely; I think you have put your finger on it. There is a profound difference of view about the future of transport in this country and, indeed, in the world. It is a global thing. My advice would be that we have to come round to the view that confronting the question of a reduction in traffic growth is essential for the economy, for wellbeing and for net zero. There is another view that says provision of extra roads intended to provide capacity for the predicted increase in traffic is the way forward for the sake of the economy, and that there must be a way of doing it that is not too bad for the environment. Essentially, the sentence, “We do not believe in predict and provide,” which the Department for Transport continually says, is at the heart of this. Do we actually mean that we do not believe in predict and provide, or do we implement predict and provide? That is a division that is not going to be resolved simply by drafting amendments to the NNNPS code. It is quite profound about the direction of travel that we need to move in.
Ralph Smyth: If I can quickly come in there, the Department has done public research asking what the public want. I can follow up after the meeting with the reference and a quote, but effectively in 2018 it found that the public were cynical about whether building roads would tackle congestion, and did not like the idea of roadworks impeding their journey in the short term were roads to be made bigger. More broadly, constituents across the country want more choice. Do they want congestion to double? No. Imagine our daily journeys with twice the congestion. That would be really devastating for people, businesses and freight. There must be another way. It is as if the NNNPS is trying to paper over the cracks to ignore the difficult choices ahead. Without changed policy we are going to have a lot more traffic on the road, and that is going to be devastating.
Q11 Karl McCartney: Well, Mr Smyth, I will counter that with the fact that the eastern bypass in Lincoln has been transformational for the city and my constituents, and for a lot of other MPs’ constituents across Lincolnshire. It has changed many people’s lives for the better. I get the fact that in different areas there will be different issues; but I wanted to move on. All three of you mentioned decarbonisation. Do you think that is the answer to everything? There are other particulates, obviously. You are all aware of how much carbon is in the air we breathe. It is minuscule.
Professor Goodwin: I am not quite sure I caught the—
Q12 Karl McCartney: You all mentioned decarbonisation as the golden egg that everyone seems to be after, but you are aware that the amount of carbon in the air we breathe is minuscule.
Professor Goodwin: The problem is that a rather small amount of carbon has a very big effect on the potential climate. DEFRA is saying that strategies, policies and programmes ought to be assessed against the possibility that we might see a 2° or 4° increase in global average temperature. That would be devastating. It does not take very much carbon in universal terms to make the difference.
I agree, however, that it is not only carbon; there are many other pollutants that have a more immediate effect on breathing problems, health, and welfare at work and so on. One of the key things about decarbonisation is that it acts, I suppose, as a banner for doing a lot of other things about improving the quality of the environment around us. It is by doing all these that we get the potential benefit. Without decarbonisation, we would not need this discussion about road building at all, because if the climate proceeds on the present trajectory the economic geography of the country will change and all the patterns of movement, of where people work and live and want to travel to, will change as well. We would need an infrastructure policy, but it would be for different infrastructure.
Rosie Allen: If I may build on that, there is also a potential £2.5 billion-worth of health benefits if you shift just 1.7% of car journeys to active travel like walking and cycling. Cutting road miles would help to reduce the 36,000 early deaths caused by air pollution in the UK each year.
Q13 Karl McCartney: There are various stats there on which the panel and I disagree, but it is obviously interesting.
Rosie Allen: Not all the panel.
Chair: Thank you. Ben, you wanted to come in next.
Q14 Mr Bradshaw: Rosie, you mentioned today’s extremely damning report from the Government’s own statutory adviser on climate change—particularly with regard to transport. You highlighted one of the problems, which is the Government’s refusal to adopt policies aimed at reducing vehicles on the road. The report also points to the claim that pollution from plug-in hybrids is five times higher than was previously thought. Is that a figure that you think is fair, acceptable, realistic—true?
Rosie Allen: I do not have it at my fingertips right now. I am happy to write in about the figures on hybrids specifically, but taking a bigger-picture approach I can say that there was a June update to the cross-sector Green Alliance policy tracker that showed that currently, even with electric vehicle transition happening at its present pace, 26% of emissions reductions required by the transport sector are still not covered by any consultation or policy. So even with electric vehicle progress, there is still a need for modal shift to reach the emissions reductions required to meet the legally binding carbon budget.
Q15 Mr Bradshaw: Today’s report says that the Government have no chance of hitting their 2030 targets as a result of this and other failures, and that they need to bring forward the date when hybrids are banned; but the report does not suggest a date. Do any of you have a date that you think might help?
Professor Goodwin: I am not sure about a date, but the trajectory seems to be rather clear. The conversion of vehicles to electric as quickly as may be technically possible is an essential part of the transition—remembering that electric vehicles also have embodied carbon in their production and use; they are not in themselves zero carbon. The problem is a policy dilemma. If so much incentive is given to electrification that electric vehicles become much cheaper to use, the growth in the volume of traffic will be such that congestion will outpace pollution as the people’s concern when travelling. If you have a strategy based on building sufficient roads to meet demand but do not build enough roads to meet that demand, congestion gets worse and we are left with high traffic growth figures and devastating congestion, which cannot be good for either environmental or efficiency goals.
Q16 Mr Bradshaw: What are the other main transport policy failures in meeting our climate change goals?
Ralph Smyth: Just to come in quickly on the number, I think 2030 is the date the report gives. The reason is that the Department has tried to define the substantial zero-emission capability of a plug-in car. It has gone round in circles for two or three years, so maybe it is just simpler to have the same cut-off for plug-in as for other petrol and diesel cars.
In relation to your question about lack of progress, the Department’s evidence to this inquiry is that it is making good progress. There is a very good chart—we can get the reference—in this morning’s report showing very poor progress, with red and orange across the piece. It is not just the environment where there is poor progress, but other areas such as linking up transport and levelling up. I was in north Lincolnshire last year on a decarbonisation project, talking to parish councillors about what they wanted, and they were concerned about the number of lorries going through their community. Yes, the Department is now years behind on moving forward to the next stage of the trials proposed for electric trucks, but two years ago it also announced the idea of a rail growth target and that has not come forward yet. These are all things that would need to be integrated into the NPS.
Actually, it seems clear that this NPS cannot go forward to designation. It will need to go back to the DFT, as happened with the energy NPSs, and there will need to be a further round of consultation and another Committee hearing. Please do look for opportunities to make wider changes, because that seems inevitable now, based on the 2008 Act.
Q17 Mr Bradshaw: In your first answer to the Chair, you said that the Government seemed reluctant to talk about traffic reduction measures because they were too difficult to mention—your phrase; but they do have some, don’t they? They pay lip service to modal shift, and they have the active travel budget and so forth. Is it the lack of policies or the lack of their championing of the policies that concerns you?
Ralph Smyth: It is particularly for the strategic road network. That is where congestion is set to increase the most, and where industries like our freight sector, which is big in Lincolnshire as well, will be most affected. The current NPS does at least talk about other policies to influence the main roads, but this has been taken out. It would be things like road pricing, possibly having bus lanes as Scotland and indeed Northern Ireland already have on their motorway networks—it is not clear why we cannot do it in England—and encouraging car sharing and lift sharing, and measures like that.
Q18 Mr Bradshaw: Finally, can any of you cite a model in another country, comparable with the UK, that is doing much better on transport decarbonisation?
Rosie Allen: Well, perhaps not outside the UK, but I mentioned before the Green Alliance cross-sector analysis that found the 26% gap in the emission reduction required to meet the fifth carbon budget. If England matched Scotland’s modal shift ambition and aimed to reduce car miles driven by 20% by 2030, that would mean that 92% of transport emissions reductions that we need to see by the fifth carbon budget would be covered by policy. It is just a matter seeing that policy ambition, I think.
Professor Goodwin: The Climate Change Committee makes another comparison between England and Wales. It has advocated that “The Government should launch a…strategic review (similar to the Welsh Roads Review)” of current and future road building projects “to assess whether these projects are consistent with its environmental goals.” Of course, the Welsh roads review was marked by the fact that it was done by an independent committee of specialists. It was a technically highly qualified committee—not, as it were, a balance of vested interests—and was working to a policy brief, which enabled it to make what I think is a rather profound contribution.
I do not think that the Committee can ignore that recommendation. It should either support or reject it. If it supports it, it seems to me that the revision of the NNNPS becomes irrelevant. It is simply not fit for purpose because a different agency with a different brief and different terms of reference would be operating in a way that it could not on the basis of the revised policy statement. It seems to me that that is a critical practical—you might say impractical—recommendation, but it has to be confronted. I feel that the revised policy statement does not grapple with the fact that there is a choice of pathway ahead of us.
Mr Bradshaw: Thank you.
Ralph Smyth: Can I quickly respond by saying: France?
Chair: Briefly, please, because we still have a lot of ground to cover.
Ralph Smyth: France has private toll companies and spaces where you can drop a car and lift-share into the big cities. It has high-occupancy lanes. There are a lot of measures that we could have too, very quickly, that would increase choice for people, and affordability, and cut carbon and congestion.
Chair: Before I turn to Greg, a very quick supplementary, Karl, because I am conscious that we are not here to scrutinise the Climate Change Committee’s report; we are here to scrutinise the NNNPS. I appreciate that the two are linked, but we need to keep to the subject at hand.
Q19 Karl McCartney: Thank you, Chairman. I have loads of other questions I would love to ask, but in the light of your recent comments, Mr Smyth, regarding hybrids, have any of the three of you read the “Fuelling the Future” report by this Committee? If so, have you any comments?
Ralph Smyth: I do. Maybe it is best to put them in writing, subsequent to this, because I have so many bits of paper here I probably have too much in my head—if that would be okay.
Professor Goodwin: I would be happy to join in with that response as well.
Q20 Greg Smith: I think some of these themes have come out in the earlier questioning, but just for clarity, for our evidence base, do you think that the national transport model that has been used to inform future demand in the NNNPS is robust?
Professor Goodwin: I have spent quite a lot of time on this. The model has strengths and weaknesses. It is an incredibly complicated model, and one of its problems is that it is not in the public domain. You cannot, as in the case of the Treasury model, say, “Please can we have the model, and run it and test it, and change the assumptions and see what happens?” You should be able to, I think.
The problem that has arisen is that, in the forecasting scenarios that the Department for Transport has adopted, there is a range of different futures, ranging from small growth to very high growth. There is simply no future modelled to look at zero or minus growth, even though the sum total of all the policies in the decarbonisation strategy would imply that there are other, lower traffic growth futures. The reason for that is the rules of the game—that you do not put into your model forecasts those policies that are not fully funded and not committed in a legal sense. Promises by the Government do not count in the modelling.
That means that, even if we were to say that all the assumptions and calculations in a model were accurate in themselves, they do not actually address the range of futures that we may have to deal with. Nor, indeed, do they address the question of significantly worse climate conditions than we have. There is in the modelling no policy to reduce traffic, and no policy to address higher rates of climate change. The scope is quite narrow and its accuracy is not really the point. The point is whether it addresses the questions to which we want answers.
Q21 Greg Smith: Before I bring the others in—and maybe, Rosie and Ralph, you can reflect this question in your answers to the first one, as well—would it be fair to say that there is an element in any future modelling that can look only at the technology we have today? In the case of road cars and projecting future road car use, at the moment all the eggs are in the battery electric basket. As has been alluded to, while they are pretty clean when the wheels are turning, they are pretty environmentally destructive over the whole life cycle of the vehicle. Once you have got the lithium out of the ground and made batteries in a different place from where you make the car, they do not last long before they need replacing, compared to a petrol or diesel car, they are not actually very good in terms of a whole system analysis.
Karl mentioned the “Fuelling the Future” report. The model does not look at what might be more accessible in 10, 20 or 30 years: synthetic fuels, or hydrogen combustion in which the only by-product is water. Is there a failure to include technological development in the profiling?
Rosie Allen: I would argue that the flaw with the modelling is that it is based on the national road traffic projections, which are largely based on the assumption that the cost of driving is projected to fall by 30%, and that public transport use will decrease. I think that the modelling of the future should include some policy ambition towards modal shift, rather than necessarily purely technology ambition, as it is harder to model for the future, whereas modelling policy ambition is something that Green Alliance has attempted to do in a recent modal shift report. That could perhaps be reflected when we are looking at traffic reduction in future scenarios.
Q22 Greg Smith: It would be fair to say of your organisation’s perspective that you come at it from the view that there has to be fundamental change to human behaviour, as opposed to using technology R&D to enable people to do what they do today, but just in a different way.
Rosie Allen: I would not say that those things are necessarily in opposition. Based on the information available today and based on the under-delivery of emissions reductions that we have seen thus far, as shown by the CCC report out today, we need to look at ambitious modal shift if, as seems to be the case, technology is not giving us the emissions reductions that we need fast enough currently.
Q23 Greg Smith: Is there an element—where we are today, 2023—of letting the perfect be the enemy of the good? We heard freight raised earlier in the evidence. A lot of the haulage sector—road haulage, I must stress—actively wants to transfer in the short term to biofuels, biodiesel, etc., which of course still emit some of the nasties from the tailpipe but to a lesser extent than the full fossil product. Because there seems to be this obsession—I am going to call it that—with getting to the full-on zero emissions at tailpipe right here, right now, we are not giving industry the ability to use a transition fuel, a biofuel, HVO, whatever it might be, until we get to the perfect in 10 or 20 years, when hydrogen combustion is properly cracked for heavy-application uses, or whatever it might be.
Ralph Smyth: Can I just jump in there? It is a project I was doing outside TAN as part of the zero emission road freight trials, looking at those issues in detail. The evidence on hydrogen gets worse every year. Rather than electrifying, which is very efficient, hydrogen and then synthetic fuels are even worse. You are just throwing away most of the energy.
There is a real risk to Britain here. The rest of Europe is storming ahead, planning to deliver electric charging points for heavy duty vehicles on major roads by 2030. There is nothing in the NPS there because Britain is looking at starting in 2030. Many companies are looking to cut their emissions as part of this. That means British manufacturers, the British supply chain, will be falling behind competitors in other parts of Europe because we are so far behind on this. There will not be sustainable quantities of hydrogen until 2040, given the wider challenges.
If we do not do this—and there should be something in the NPS about the driver and charging facilities required—we will fall behind further with our productivity.
Q24 Greg Smith: When you talk about the efficiency loss, is that not from looking at once the energy, in its generic sense, is in the vehicle—in a battery, a hydrogen tank or a fuel tank—as opposed to the whole system analysis of it, of getting the energy from generation through a national grid to charge the vehicle, when you do not have the same whole system analysis loss of the energy, if you are putting a synthetic fuel in a tank as you would put petrol or diesel in a tank now?
Ralph Smyth: It is a really important question. One problem with the current carbon accounting is that transport is simply the tailpipe emissions rather than the whole system emissions that you are referring to.
There is an excellent report by Ricardo for the Department for Transport that breaks the different types of fuels down for each type of vehicle. I can forward it to the Committee afterwards. It should hopefully allay your concerns.
Q25 Greg Smith: Please do come in on that, but, just to add to the question, do you agree that whole system analysis needs to happen, as opposed to looking at what happens once the wheels of the vehicle are turning or, in aviation, the propellers and so forth? At the moment, we are too focused on what happens once the energy—whichever energy you choose to use, be it a liquid, hydrocarbon or electricity—is in the vehicle.
Ralph Smyth: Before Phil comes in, absolutely. That is why modal shift is so important because a car is unused for 96% of the time. Something like a bus or a train is used much more intensively. Therefore, that is a way of reducing those wider emissions.
Professor Goodwin: To add one further rather quirky problem to this: there are things of which the model does not comprise, not because they are technically too difficult, but because nobody thought of including them. One of the biggest factors in the car market in recent years has been the enormous increase in the average size and weight of vehicles. We have vehicles attempting to use city streets that previously would have been thought a bit out of scale in farm use. That means that the embedded carbon in manufacture, in materials and in the effect on congestion of the road space being used can be bigger in offsetting the fuel savings that you have from the fuel source than you had intended—not to mention, of course, the effect of that on pavement parking, which the Committee has done some extremely important work on, of expanding the road capacity by taking away the pavements. All these interactions are an interaction of the human factor and the vehicle factor that only a system-wide approach can handle. It is a very important point.
Q26 Greg Smith: You have brought in to that particularly urban environments and cities. The UK is not all cities or even towns. Most of it is rural. In rural communities, you just cannot survive on public transport—certainly not for the entirety of the journey. The vast majority of people in villages probably do not even have a school in their village. By definition, they will have to take little children, before they can get on a school bus or whatever, to school in a car. Should there be some gearing in where we look to that recognises the reality of living in a rural community as opposed to London, where there is a massive bus network and tube network, even though it turns out the air quality is worse on the tube than it is on the street?
Professor Goodwin: It is an important point. I am hearing a view from local authorities that too much attention is being given to the strategic “national” road network and not enough to the local networks, where very often it is not capacity that is the issue but maintenance. There is a whole series of recalibrating the expenditure pattern between capital and revenue, between long term and short term, between cities and the countryside that we do need to take a fresh view of, because it does not seem to correspond any longer with what the problems on the ground are.
Greg Smith: Does anyone else want to come in on that?
Rosie Allen: I agree it is about prioritising transport spending on the maintenance of the existing network and channelling this towards further public transport and active travel infrastructure.
Ralph Smyth: Hear, hear. Regarding the policy document before us, there are the consequences of what you are saying and with which I agree, having grown up in a rural area. The statement of need is, broad-brush, the same whether you are in a hamlet or a big city, and that seems wrong.
There was a big study done on the strategic road network in urban areas, which the DFT was trying to get hold of, that should give more detail for the cities. As for the rural areas, let’s not forget the need for tourists, maybe without cars, from big cities going into those areas. Also, integration is something that the NPS is really poor about—how to integrate local transport plans, which apparently are supposed to be cutting carbon, with the big roads. We need to have an integrated system rather than just a national network that does not join up with local areas and their needs.
Q27 Greg Smith: My last question is on the way the NNNPS measures and mitigates carbon from major schemes, not just in the construction but the operation once those schemes are built. Is it right that schemes are looked at on an individual basis as opposed to a broad-brush approach? Within that, particularly once you get to the operational end, the predictions seem to be entirely around the carbon put into the atmosphere by the operation of them as opposed to what could be done with that carbon.
I give an example, coming back to the point Karl made around our “Fuelling the Future” report. If you look at the synthetic fuel element of that and some of the synthetic fuels that have been developed, one company in the UK gave evidence to this Committee that their product follows the natural biological carbon cycle: the carbon that comes out when the fuel is in operation, be it in a train, an aircraft, a private vehicle, a truck or whatever it might be, is the same volume of carbon that is then recaptured to make the next lot. So it is, to that extent, net zero.
Ralph Smyth: I have seen those figures. There is a big failing. Rather than taking the carbon back into a tree or something, you are simply keeping it in the atmosphere, when we do need radically to cut emissions. Maybe I could best again follow up with a note because I can probably express it better in writing, not having been prepared for that. We need to be cutting emissions rather than capturing and then pretty much instantly reburning them.
Rosie Allen: I will take the first part of your question on assessing and mitigating the emissions of the schemes. This draft of the NPS does suggest that the decision maker should be content that all reasonable steps have been taken to reduce greenhouse gas emissions. Ultimately, there is still the admission that there will be residual emissions from the construction of infrastructure and, also, that operational greenhouse gas emissions are not a reason to prohibit consenting to national network projects. So we can maybe conclude that the obligation to consider the emissions in the construction of the operation is a bit toothless.
You also mentioned assessing individual projects rather than the piece as a whole. This was highlighted in some written evidence sent to the inquiry for a strategic road investment, another inquiry, by Professor Greg Marsden from the University of Leeds. In that, he assessed the cumulative carbon emissions from the road investment strategy using the Government’s own national road traffic projections, which the appraisal of sustainability of this NPS draft did not do. Professor Marsden’s findings were that the core scenario used in this NPS exceeded the sixth carbon budget by hundreds of megatonnes of carbon.
Professor Goodwin: To reinforce your point, it does not make sense to consider schemes on their own without a wider appreciation of how they interact with other schemes, other modes and planning issues which change the role of travel in society.
If you do not do that, there is no scope for saying, “Well, all this scheme does is move the congestion five miles down the network.” It only makes sense if you see the whole thing as an integrated whole and, therefore, assess the whole thing as an integrated whole when you are taking the decisions.
Ralph Smyth: Could I make one quick point on a change in the draft which says that decision makers should give weight to nature-based solutions? That is saying that if you plant a few trees along the side of a new road it can offset the emissions. A challenge here is how many of National Highways’ trees are dying for the A14 in Cambridgeshire? Hundreds of thousands of trees died in 2021, let alone last summer’s 40° heatwave. There is very little about resilience in this NPS. It is very weak there. That is not just about the resilience of the infrastructure but the resilience and the mitigation that we really need to be thinking about.
Q28 Greg Smith: The same could be said, if I can call it such, of the green lobby, which held HS2 as some great saviour but hundreds of thousands of trees are dying in my constituency up and down the route to build that. This is not something that is exclusive to road, is it?
Ralph Smyth: No, it is across the board, but road has much greater land take, so it is a bigger issue.
Greg Smith: Come to Buckinghamshire and see the land take from HS2; it is much bigger than a road.
Chair: As tempting as it is to switch to HS2, let us keep the focus on the NNNPS.
Q29 Ruth Cadbury: I have an overarching question that is relevant because we are dealing with the planning system here. Would removing the presumption in favour of development in the revised NNNPS help to ensure that new infrastructure is consistent with net-zero commitments and other commitments?
Professor Goodwin: That is an interesting question. One of the problems is that the role of the public examination system is absolutely crucial in giving the scope for other than the promoters of a scheme to cast judgment on it. One of the difficulties about the old and the revised NNNPS is the restrictions placed on the examining authority about what they may or may not consider. Doing what you suggest would strengthen the ability of the examining authority and the inspectors to have a much broader view of the whole thing. It would need some retraining and re-education on their part because they have been used to being told by the lawyers, “No, you’re not allowed to consider this.” If they are being told they must consider it, there is a difference between a strengthening of their role and, if it is done in the right way, a strengthening of the quality of the output as well. So I think it is a good idea.
Ralph Smyth: May I suggest a slightly different tack to that? That is having a presumption against for road building, as Wales now has and as the CCC says, but having a presumption in favour of the transport infrastructure we need for net zero, such as charging points for lorries, cycleways, and our public transport upgrades. There should be a strong presumption in favour just as there is going to be for renewable energy infrastructure.
Q30 Ruth Cadbury: If we were to shift in that way, what do we do about the construction sector’s pipeline of work and the jobs that go with it?
Ralph Smyth: That is a really good question. The system behind roads was supposed to be about stability and certainty. That is not the way it has turned out, with many schemes being paused. The construction sector itself is complaining that it is not helping.
It is very difficult to change while we keep on going on. There really needs to be a roads reset and quickly coming up with alternative projects for the construction sector, such as cycleways, electrification of road and rail. There is certainly the need there for the constructor sector, but we need to shift their work. The only way that is going to happen now is by having a reset rather than trying to tweak, tweak, tweak.
Ruth Cadbury: Thank you.
Q31 Chair: Our discussion thus far has understandably focused almost exclusively on roads and the private passenger use of roads in that. The NNNPS also covers rail schemes. Is there sufficient detail and ambition in the revised NNNPS for the rail network?
Rosie Allen: We welcome that this draft of the NPS recognises the value of rail freight and, as I have mentioned, expanding strategic rail freight interchanges. Green Alliance supports a vision for a future transport system in which modal shift is encouraged, as we have outlined, and passenger rail is increased. But in this draft the impact of the pandemic on rail is accepted, rather than there being any policy ambition to change this trend.
Also, as we have mentioned, the focus on roads is too great. As outlined in the written evidence from Campaign for Better Transport, there is not enough focus on how rail can be used to improve connectivity or on electrification of the existing rail network. There is also not enough focus on the resilience and adaptation of the existing rail network. As my plan has mentioned, the impact of weather conditions on the rail network are already being seen across the country.
Q32 Chair: Do either of you have anything to add?
Ralph Smyth: It is very weak on rail. There are a few positive words, but there is nothing on resilience. With most of the rail network being hundreds of years old, with pre-Victorian earthworks, that is a massive risk. We have seen recently the Nuneham Viaduct and the impact of that on people in Oxfordshire and maybe bits of Buckinghamshire. There is no link-up at all to the Levelling Up Bill and the mission to increase public transport connectivity across the country.
France is delivering regional metros across about 10 different cities. Something like that should be in our UK policy. I could go on. It is very, very weak. There is a massive need for it to be expanded, not just for the public sector but also to encourage the private sector—whether it is a rail freight interchange or so on—to invest and have that certainty that there is a good future for rail.
Professor Goodwin: It is not really a transport problem—or not directly. The role of the construction industry, or of civil engineering generally, is going to be enormously important as we confront climate change. There is going to be a huge amount of investment. For an industry technically qualified and able to do a job that we are going to need doing, it seems to me that job creation schemes involving not very good road projects should be at the bottom of the list. There are a lot more important things to do with the infrastructure of this country.
Q33 Chair: Thank you. To what extent will the draft NNNPS look at connectivity holistically? You might have a road scheme which in itself may not be compatible with net-zero obligations but, as part of a wider package alongside a rail project, for example, could be. Does the revised NNNPS have that objective in mind?
Ralph Smyth: East West Rail?
Q34 Chair: I am not thinking of any specific scheme but there will be a number. For example, if you look at the supply chain network on freight, I attended a session recently on upgrading Ely Junction—a rail project. That will feed in, potentially, to other road projects for improving the freight supply chain.
Professor Goodwin: That is a perfectly good, logical point, is it not? Clearly, there are interactions between rail and road. You are going to need access to and from railheads and all the rest of it, but, in practice that is not the key issue. The key issue is that we do not have an unlimited amount of investment available. One of the shifts that ought to be made is from road to rail. Having said that, clearly one wants to get the interaction right, but if the balance is wrong you are not going to make it right by disguising projects as being different from what they are really about.
Q35 Chair: I appreciate the general ambition to have modal shift. My question is: as it is currently drafted, does the NNNPS allow that holistic consideration of projects as a whole?
Professor Goodwin: No, it does not really.
Q36 Chair: If it does not, how could it?
Ralph Smyth: The question is very well put about freight because that is, perhaps, where there is the biggest need. While you could cycle to a station, you are probably not going to be able to get large freight deliveries back by bike. There is a comment about integrating the ambition for a national freight network, but, like everything else, it is namechecked rather than substantively incorporated in the policy. That is definitely lacking.
Q37 Chair: Thank you. In the last five minutes, I want to turn to some of the development consent and legal challenges. Ralph, you have mentioned that you think that the revised NNNPS will result in more legal challenges to schemes. Could you explain that a little further, please?
Ralph Smyth: Yes. First, by trying to have it both ways it increases uncertainty. In one respect, for example the transition proceedings, it tries to say that the new NPS will not have effect for schemes that have already entered into the process but the NPS itself is reflecting wider policy and wider legislation. That is another example of the DFT struggling with change management and making things worse. Other bodies that have submitted evidence have said the same.
Another major issue is cumulative impact. This was a big issue in the legal challenges on climate. Of course, today’s CCC report will make previous decisions by the courts no longer a precedent.
Many of the other targets, such as on air quality and nature recovery by 2030, are moving away from particular tests like, “Does this road itself in a village go over a limit?”, or, “Is this particular habitat by a town affected?”, to national targets. That is trying to assess the cumulative impact—so the different impacts of the schemes added together. There is no guidance there and that is going to be a major area for legal challenges going forward. Again, the new draft makes it worse rather than better.
Q38 Chair: As far as I am aware, none of the legal challenges to the Secretary of State’s decision to grant development consent for new road schemes on net-zero grounds has been successful. Does that not suggest that, until now, the Government’s policy approach is aligned with other policy commitments?
Ralph Smyth: First, the Government withdrew the Derby A38 scheme rather than going to court. More broadly, all the administrative court or the planning court do is check, based on the available evidence, whether the Government’s decision was irrational or not. TAN has been trying for a long time to get the data out behind the transport decarbonisation plan. That has now happened. It shows that the Government’s promises are not adding up. We would say that the reason the cases were lost is that we did not have the data to put in front of the court. Now we do, and also the CCC has come down very strongly today. In the wider targets, the NAO has said that the Government are also off track on those. I can forward a link to that following this hearing.
Chair: Thank you.
Q39 Gavin Newlands: You mentioned some of the differences between Scotland and England and the reduction in car usage reduction targets set for Scotland. I have a quick, overarching question on the overall strategic approach to how we view this entire issue. We are looking at the NNNPS at the moment. In Scotland, there is a different model in that it is more holistic. You have the overarching infrastructure and investment plan, which then feeds into the national transport strategy, which then feeds into the delivery model for the national transport strategy, which is the STPR2—the current version is STPR2. All that is looked at holistically. It is viewed through the prism of the car reduction target for a start. It also looks at every aspect of transport and how integrated it is, including active travel, which is everything up to an airport, because that is reserved and not a function of the Scottish Government.
Would a much more holistic model, looking at every aspect and how we best integrate that and decarbonise that, be a better way of looking at it than the current model that the DFT is looking at?
Rosie Allen: Yes.
Professor Goodwin: I would go for yes as well. One of the interesting things about the Scottish model is that they have a requirement that schemes are appraised not only in terms of the unfettered forecast of the state of the economy and so on but whether those schemes would be robust and useful if there were a 20% traffic reduction. That entirely changes the way you look at the problem. In many cases, if you were to have a 20% traffic reduction, the actual case for need disappears. You still have to deliver the 20% reduction. That is the key policy issue, but allowing yourself to think what would happen if there were a necessary stage before that is precluded under the whole English NPS system; it is simply never there in the calculations. Would this scheme be robust if there were a traffic reduction? It is not modelled; it is not appraised. If anybody asks the question, the lawyers say, “You’re not allowed to consider that; you’re only allowed to consider the proposal which is in front of you from the promoter.” It does change the whole atmosphere and logic of the decision process.
Ralph Smyth: Very briefly, yes, as well. Maybe having that would mean we would not have the NNNPS but something less of a mouthful like an integrated transport NPS or an overarching transport NPS, with something smaller for active travel and freight. That would be a much better system as well as an easier-to-pronounce acronym.
Chair: On that note, I thank you all for your time and evidence this morning.