Everything needs to change to support sustainable growth. Except, it seems, the National Policy Statement about it….

IN THIS ARTICLE I offer my review of the Draft National Policy Statement for National Networks (road and rail) that has just been published by the Department for Transport (LTT 865). In doing so, I should point out that, continuing on from other roads-related matters under consideration of late, my focus is on roads, rather than also considering rail. Because my analysis comprises quite a lot of detail, and to reflect several stages of my take on things, I’ve arranged it in four parts:

Part 1: Making sense of what the NPS and the new version are all about
Part 2: Weighing up alternatives
Part 3: Appraisal of Sustainability
Part 4: Ten areas of concern that I have identified

Part 1: Making sense of what the NPS and the new version are all about

If you are an NPS guru and deep inside the worlds of major scheme appraisals and Development Consent Order processes, then you can probably jump over this section (or point out to me what I may have misunderstood).

When reviewing a significant new policy and planning document it’s reasonable to want to know what it is and what it is for. In this case, one has to start with knowing what it should be properly called!

The December 2014 version (designated – i.e. published – in 2015), and currently in force, is called National Policy Statement for National Networks, on the cover. In the first sentence of the Introduction to this document it is called the National Networks National Policy Statement – abbreviated to NN NPS we are told, and then to NPS. For good measure, the announcement in July 2021 of the review of this version refers to it as the National Policy Statement (NPS) on National Networks. Meanwhile the issuing of the draft revised version for consultation on 14 March 2023 uses the abbreviation NNNPS, though the draft itself then uses the abbreviation NPS.

Maybe it’s the academic in me being hung up on getting the name and abbreviation right. Anyway, from now on in this review of mine, I’m going to simply refer to it as the NPS, as seems common to do so.

Whatever we call it, however, I reckon it is of real importance in setting the context for a more sustainable transport policy.

It helps, I think, to appreciate that this document is one of a series of twelve National Policy Statements NPSs – as described by the Planning Inspectorate. This particular NPS is for National Networks (national road and rail networks). NPSs exist because of the Planning Act 2008, passed by the last Labour Government. This Act was intended to speed up the process for approving major new infrastructure projects known as Nationally Significant Infrastructure Projects – NSIPs. The means of being able to achieve this speeding up is through the NPSs, which are intended to set out the need for development and other policy deliberations, and thus make the outcome more certain by following specified guidelines, assisting applicants who will have invested in significant resources in order to obtain development consent.

As the then Secretary of State for Transport, Grant Shapps, said in announcing the review of the NPS for National Networks: the NPS provides “a proper basis on which the Planning Inspectorate can examine, and the Secretary of State for Transport can make decisions on, applications for development consent.”

Just as an aside, when reference is made to ‘speeding up’, and to resources invested in preparations, you may wish to note that for the biggest proposed investment in the second Road Investment Strategy (RIS2), the £10bn Lower Thames Crossing, the submission of evidence for the DCO examination runs, I understand, to over 60,000 pages.

With regard to what constitutes a Nationally Significant Infrastructure Project (NSIP), the draft NPS points us to Part 3 of the Planning Act 2008. We’re told in Clause 14 that “In this Act ‘nationally significant infrastructure project’ means a project which consists of any of the following….”, with a list that includes, as of principal concern to this article, “highway-related development”. Under this sub-clause heading are further details of what is in and out of scope for roads, and for further understanding of this I can best refer to a document in the House of Commons Library called “Planning for Nationally Significant Infrastructure Projects”. In answer to the question ‘what are NSIPs’ this says that they are “large scale developments (relating to energy, transport, water, or waste) which require a type of planning permission known as “development consent”. In the case of roads, this means that if National Highways has a major new road scheme, it must put forward an application to the Planning Inspectorate for a Development Consent Order. According to this DCO factsheet, “A Development Consent Order (“DCO”) application for consent to undertake a NSIP is made to the Planning Inspectorate who will consider the application and make a recommendation to the Secretary of State, who will decide on whether development consent should be granted for the proposed scheme.”

The National Infrastructure Planning web page from the Planning Inspectorate allows you in turn to go to a section which lists all the current NSIPs – enabling you to search for those for transport according to which stage they are at in the process. There is quite a substantial number, with some 50 listed amongst about 220 NSIPs of all types.

So, to summarise, in England, when National Highways wants to take forward a major new road scheme, it needs to apply for and get a Development Consent Order (DCO) to be able to do so. This ultimately has to come from the Secretary of State for Transport (SoS) who is advised on their decision by the Planning Inspectorate (PINS), which will have considered the application and all related evidence thoroughly. National Highways, PINS and the SoS are expected to be guided by what is said in the National Policy Statement (NPS) for National Networks. If this NPS has been followed, then the outcome should be more certain, thereby making the effort involved in making the application worthwhile and – in theory – the process quicker. Amongst the matters that must be satisfactorily addressed are the sustainability of the policy [NPS] to ensure compliance with environmental sustainability standards, i.e. a DCO application should not fall foul on environmental grounds.

Here’s my attempt at an even pithier summary:

The UK Government gives many billions of pounds to National Highways every five years – according to a Road Investment Strategy – to spend on our trunk roads and motorways, including new schemes to change the road network. These first require specific individual permission from the Government to go ahead. An important document called a National Policy Statement helps determine whether that permission should be granted. Therefore, what is in that document can be considered fundamental to shaping our future road network and its use.

I now want to set out a few more considerations that seem important in setting the scene for my review of this important draft new NPS.

● It is Not a National Transport Strategy

The NPS only covers England. The Scottish Government and Welsh Government have national transport strategies, rather than NPSs. There is not a national transport strategy for England. The NPS may be seen as a kind of policy statement, but it only concerns itself with large scale transport investments on road (and rail) and thus is not an overall national transport strategy. It’s worth bearing that in mind if you read the NPS or when you read about it.

● The existing NPS is out of date

The current NPS was written nearly a decade ago. A lot has changed since then. In July 2021 an announcement was made for the NPS to be reviewed and revised, though the decision for the review to take place was not readily forthcoming. You can read here (https://transportactionnetwork.org.uk/nps-legal-case-2/) about the High Court proceedings that were taken to challenge the initial refusal of the Secretary of State to review the NPS. The delay which was occasioned means the Government and National Highways are currently in the process of preparing the next (third) Road Investment Strategy, for the period 2025-2030, whilst schemes that have been or are currently part of the second Road Investment Strategy (2020-2025) have been considered against the old 2015 NPS. They are still now being measured against that NPS, in spite of how much has changed since 2015.

● Much has changed since 2015

As the Government itself acknowledges in tabling the revised NPS “The current National policy statement (NPS) on national networks, the government’s statement of strategic planning policy for major road and rail schemes, was written in 2014 – before the government’s legal commitment to net zero, the 10 point plan for a green industrial revolution, the new sixth carbon budget and most directly the new, more ambitious policies outlined in the transport decarbonisation plan.”(my emphasis added)

It seems there is therefore general agreement that there is an urgent need for an updated NPS to be published and to be guiding major road (and rail) scheme investments. There is also an imperative to get this revised version right.

● Can you spot the difference?

Given the significance of the review and revision in process, I might have expected to see a document up front that explains the key changes that are proposed in the new revised draft, compared to the 2015 NPS, as well as the key features that remain from it. No such luck, I’m afraid. It was only after I had been through the draft NPS (and the Appraisal of Sustainability document – more later) that I then found a section on the consultation page labelled ‘Draft NNNPS summary’ which claimed to “outline the changes made to NNNPS chapters as part of the review process and the rationale for making them”. Whilst not an untrue claim, blink and you’ll miss it, it’s so short. Since I don’t have time to compare and contrast the old and the draft new revised NPS in detail myself, my review is just based on an examination of what is in the new NPS itself.

Part 2: Weighing up alternatives

In this part of my review – which in some ways is an extension of the first part – I will consider the fact that the NPS itself is not really concerned with consideration of any alternative options when it comes to major infrastructure schemes. I’ll then go on to examine how it seems we can treat the NPS itself as the place where there should in fact have been such consideration of alternative options.

It’s easy to keep falling into the trap when reading the NPS of thinking ‘but what about the consideration of alternatives when it comes to arguing for new infrastructure investment?”. As is made clear in the document early on “The NPS provides policy and guidance on matters such as good scheme design, transport decarbonisation, avoidance and mitigation of environmental effects and environmental enhancement.” Conspicuous by its absence is the idea of ‘consideration of alternatives’. The document goes on to explain that “both the National Planning Policy Framework and the NPS seek to achieve sustainable development, by ensuring the right infrastructure is delivered in the right place and at the right time to support sustainable growth”. So the emphasis is very firmly on the provision of infrastructure.

‘Supporting sustainable growth through infrastructure investment’ might, in fact, have been the sub-title of the NPS as it has been written. Since it is not a national transport strategy, the NPS is not about guidance for the bigger picture that might include other ways of supporting sustainable growth. And the concept of growth – sustainable or otherwise – is not really explored in the document, but taken as a given. It is rather remarkable that in a service-based economy such as the UK, nothing is said about the growing role of digital connectivity and accessibility in working and social lives as alternative and/or complementary to road networks in supporting growth. The only mention of digital is as it pertains to the operation of the road network, and its use.

Only at page 40 in the 105 page document do we get to a heading ‘Alternatives’. However, we are merely advised here that “The Examining Authority and the Secretary of State should satisfy themselves that the options appraisal process has been undertaken”, and that “Where an options appraisal process has been undertaken, it should not be necessary to consider alternatives”. This, I recall, is in line with the 2015 NPS. In other words, attention is focussed mainly on whether the preferred road scheme as presented is acceptable or not.

The NPS states that “improved connectivity and accessibility, both locally and inter-regionally, facilitates deeper labour markets, giving individuals better access to jobs and education, and businesses better access to skills”. But in this context, it clearly means ‘improved connectivity and accessibility through road (and rail) schemes’ because improvement could not instead come from spatial proximity and digital connectivity as these are not the subject of the NPS. In short, improving connectivity must come from physical motorised mobility on the appropriately provided infrastructure.

Reference is made in the draft NPS to alternatives having been considered. But alternatives to what? I was scratching my head over this to start with, but then realised that to make sense of this you have to step away from the NPS and read the Appraisal of Sustainability document, an accompanying 26-page document.

This contains the statement that: “DfT consider that there are three reasonable approaches to development of the NNNPS” and that “these reasonable approaches are:

• An approach which delivers balanced national priorities (as selected by the DfT as the basis of the draft NNNPS); (my emphasis)

• An approach which prioritises environmental sustainability benefits (Alternative 1); and

• An approach which prioritises wider economic and levelling up benefits (Alternative 2).”
  This Appraisal of Sustainability document then goes on to say, “In the light of updated travel demand forecasts and the policy framework provided by the Transport Decarbonisation Plan, it was not considered reasonable to include a ‘do nothing scenario’ as an alternative.”
  

Take care here, by the way, to not be confused by the use of the term ‘scenario’. In this context, (as far as I can gather), it refers to the option of not making any changes to the existing NPS, i.e. a ‘do nothing scenario’. This suggests that ‘options’ for the NPS itself are also being called ‘scenarios’, as are the DfT’s recently postulated seven possible futures against which the new National Road Traffic Projections have been developed – not with the intention to confuse of course, though this overlapping use of the same word might surely have been better avoided.

So, to summarise again, it would appear that part of the process of getting to the revised NPS is to have considered three substantive alternatives to not materially changing it at all. With little insight (other than brief consideration in the six-page Appendix 1 of the Appraisal of Sustainability), two alternative courses the NPS could have taken would have been to prioritise environment over economy, or economy over environment (with levelling up also put into the mix). Instead, we have an NPS which is referred to as ‘delivering balanced national priorities’ which in turn has been translated into the concept of ‘supporting sustainable growth’ and is acknowledged to have been, as mentioned earlier, “selected by the DfT as the basis of the draft NNNPS”. However, since the NPS only concerns major road (and rail) schemes, balancing national priorities of economy and environment can only be achieved in NPS terms through authorising new infrastructure. This in turn suggests that for the most part the reason for delivering new infrastructure must be for economic reasons, but (perhaps) with a hope that this is not to the detriment of environmental sustainability.

So let’s move onto that next.

Part 3: Appraisal of Sustainability

As alluded to earlier on, an Appraisal of Sustainability has been conducted on the draft new NPS (as it was for the 2015 NPS). Indeed as the current Appraisal of Sustainability document explains “The Planning Act 2008 requires that an AoS is carried out before an NPS can be designated”.

The headline conclusion of this exercise (for both the current NPS draft, and as it was for the 2015 designated NPS) is that “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS.” As I understand it, this ‘clean bill of health’ assertion firmly implies that if a scheme promoter follows the NPS they can be confident that their major infrastructure scheme will be able not only to deliver growth, but to do so sustainably. Of course, the devil will be in the detail within a Development Consent Order process, but for the NPS itself, this is presumably intended to give confidence that with the right practices in place in terms of scheme design (as set out in the NPS), major road schemes need not be environmentally problematic.

So, this Appraisal of Sustainability (AoS) endorsement seems quite important to the revision to the NPS. Foundational one might say, since the announcement of the need for the review emphasised the changes in relation to the climate change and decarbonisation agendas that had made the old one well past its sell by date.

We are told of the new AoS: “The assessment has been carried out and reported using an expert, judgement-led qualitative assessment”, adding “A ‘precautionary approach’ is taken, especially with qualitative judgements and judgements are documented in the assessment tables.”

This must surely mean a great deal rests on those experts and their judgement. That, to me, immediately begs the question “so who were the experts involved?” And indeed was it a diverse group of experts from a broad range of disciplinary perspectives and backgrounds, as it surely ought to be? Of this we are not told, unless this detail is tucked away in the appendices somewhere and I didn’t spot it. Details of ‘the Jury’ would seem essential – perhaps those assembled by consultants Ramboll and WSP upon whose work it is acknowledged that the AoS is based? It certainly didn’t seem important enough to include in the main document (all 26 pages of it). Stage D of the process followed involved ‘consultation’, it is noted, which I assume is something different. This involved four Statutory Environmental Bodies, and four ‘other consultee’ responses; it also involved several stakeholder workshops, but again no names are provided.

So what of the ‘precautionary approach’ referred to in the AoS? Well, first of all the qualitative assessment culminates in a score ranging from ‘significant positive’ (++) to ‘significant negative’ (--) passing through ‘neutral’ (0) and ‘uncertain’ (?).

Notably, it is stated that “uncertain effects will be treated as significant negative effects and mitigation and monitoring recommended”. The main body of the AoS has, however, very little in the way of results from the assessment, but when these do appear, they highlight the following.: Greenhouse Gas and Air Emissions potential effects of the NPS are judged to be ‘uncertain’. Meanwhile Economic Impacts, User Experience and Safety are all judged to have significant positive potential effects. It is judged that there is an “uncertain effect on greenhouse gas emissions from road users due to investment in road infrastructure (Operation)”. Mitigation recommended is that “All new SRN [schemes]…could be required to ensure they can be delivered without impacting on ability to meet net zero GHG emissions at a network/investment programme level”.

So, again if I understand correctly, the NPS should deliver balanced national priorities in support of sustainable growth for which “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS”. This is even though there is uncertainty over greenhouse gas emissions, which ‘could’ (not ‘must’), require NSIPs be delivered without impacting on ability to meet net zero at a network/investment programme level. Forgive me if I have misdirected myself, but either I have not followed the nuances and details of the commentary, or this sounds distinctly unconvincing as a ‘precautionary’ approach.

Seeking more detail regarding the assessment on particular matters requires the reader to go into the appendices to the AoS. In terms of greenhouse gas emissions from road network users, for example, this is tucked away in Appendix 3, page 2. It is nonetheless perhaps worth drawing this text from the document out in full here (my emphasis added):

This information from the Appraisal of Sustainability is brought forwards into the NPS itself. I assume ‘user emissions’ are being treated as part of ‘operational emissions’ as opposed to being a separate category. So let me get this straight: Significant improvements and enhancements to the road network could result in substantial increases in greenhouse gas emissions due to increased use of the network, and facilitation of further growth, and yet “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS”, and “The Secretary of State does not, therefore need to assess individual applications for planning consent against operational carbon emissions”. In the NPS it also notes that “in the case of road projects while the developer can estimate the likely emissions from road traffic, it is not solely responsible for controlling them”.

I’m sure I’d make better sense of the meaning of all of this if I was a lawyer. However, the overriding impression I get is ‘There is no imperative to do anything differently. Do what you can, but there is nothing to see here in the new NPS that will upset pressing on as we are folks”.

Part 4: Ten areas of significant concern

The final part of my review I’ve characterised as detailing ten (further) matters of concern. As I read through the NPS, certain moments of (minor) outrage or incredulity arose for me along the way, as you will have no doubt noticed in this article. Some are (probably) not fundamental. But some seem to be quite serious.
Here they are:

1 - A Freudian slip?

The DfT’s ‘second cycling and walking investment strategy’ (updated 10 March 2023) reiterates an earlier stated political ambition that “50% of all journeys in towns and cities should be walked or cycled by 2030”. However, in the NPS it states that “It is a government commitment for more than half of personal journeys in our towns and cities to be made by active travel by 2030s.” Spot the difference? A careless little ‘s’ at the end not picked up in proof reading, or a carefully placed ‘s’ to subtly soften the target and buy another decade of time?

2 - Publication of the new guidance for LTPs is imminent

I understand it is still the official line that the long-awaited new guidance for Local Transport Plans from the DfT is imminent. Yet in the draft NPS it makes reference to ‘Updates to Local Transport Plan Guidance’ as if already available to see. Maybe I’ll let this one slip given the draft status IF indeed the publication of the (draft) new guidance is indeed imminent….

3 - We’ve almost done transport decarbonisation

The NPS states “Government’s Transport Decarbonisation Plan demonstrates how we will deliver transport’s contribution to emissions reductions in line with net zero, much of which has already been delivered or is in progress.” I’ll give you a similar phrase I just made up which is also true “I have a plan to colonise Mars which is in progress”. The TDP may demonstrate how we could deliver, it doesn’t definitively demonstrate how we will deliver. Saying ‘much of which is already in progress’ is largely meaningless unless we know how such progress is measured, how much has been made, and to what effect.

4 - Tailpipe emissions are projected to fall significantly

We’re told in the draft NPS that the “The National Road Traffic Projections 2022 provide a strong analytical basis for understanding the potential evolution of traffic growth, congestion, and emissions under a wide range of plausible future scenarios. In all scenarios carbon dioxide tailpipe emissions are projected to fall significantly due to the anticipated uptake of EVs.” Let’s put aside questions over whether we all agree on the first ‘strong analytical basis’ point (particularly on whether the set of scenarios is entirely appropriate). Yes, it’s true that tailpipe emissions go down in all scenarios. However, in five of the eight scenarios (including the ‘core’ scenario), CO2 emissions from road transport remain well above a whopping 40 Megatons per year by 2050. Hardly grounds for celebration. But no need to worry it seems.

5 - Increase in demand on the SRN is inevitable

We are also told in the draft NPS that “There has been a steady growth in the population of Great Britain over the last 20 years, and the population is projected to increase further by 4% between 2025 and 2060. Continuing growth in the economy and the population will increase the demands placed upon the SRN. Without investment and infrastructure interventions, increasing demand will lead to decreasing network performance for users, for example, poorer journey time reliability, which comes with economic and social costs.” Note the definitive ‘will’. No room for ‘could potentially’ or ‘unless other measures are put in place, will likely’. Simply ‘will’. A bald statement that if economic prosperity is needed, you have to invest in infrastructure. Never mind the fact that for the devolved nations there are now targets in place for absolute reduction in road traffic levels which suggests these are possible alternative futures. So – we can’t say ‘will’ to increasing demand in Scotland and Wales, but we can for England? Yet even for England the NPS lists “a range of measures that can be employed to make the best use of all road capacity (not just the SRN) which may impact upon demand for the SRN”. These don’t expressly include reducing the need to travel (on the SRN) or, heaven forbid, using the charging mechanism to discourage traffic, but do suggest increase in demand is not a foregone conclusion.

6 - No need to worry about induced road traffic demand?

The NPS states that: “Evidence that development on the network leads to induced demand is limited” and points to a WSP/RAND report on this topic from 2018, intended as an update to the 1994 SACTRA report. The report, a review of 25 papers, says “There is little evidence that extreme levels of induced demand would therefore occur on the Strategic Road Network”. It also points to a “wide range of elasticities” and a “wide range of percentage changes in traffic flows”. The report noted that “The evidence reviewed in this study supports the findings of the SACTRA (1994) report that induced traffic does exist, though its size and significance is likely to vary in different circumstances”. My minor outrage here is that this statement in the NPS comes immediately after being told demand on the SRN will increase because of population and economic growth. It seems as if the message is ‘demand will increase, we need more capacity unless we want to stifle growth, and we needn’t be concerned too much about induced demand from more capacity’. This is surely an area on which professional opinion is far from unanimous.

7 - No need to get your ‘facts’ about uncertainty correct

The latest National Road Traffic Projections report states “From 2025, traffic is projected to grow between 8% and 54% by 2060”. This only came out in December 2022. However, in the NPS it states “all scenarios have projected a growth of traffic between 2025 and 2060 for England and Wales, with forecasts ranging from 12% to 54%”. The next sentence, however, almost invites us to not worry too much about the incorrect range anyway because “The Core scenario, which represents a world in which deviation from historic trends in the key drivers of demand and current Government policies is minimal, projects a 22% increase in traffic between 2025 and 2060”. Even though DfT has an uncertainty toolkit and even though DfT emphasises how uncertain future road traffic demand is, we can’t resist being drawn again to the ‘core’ projection in the NRTP for a source of comfort it seems.

8 - Either we’re uncertain or we’re not

Still fixating over the core NRTP scenario (the most likely source of truth for some it seems), the NPS delves into the world of ‘false precision’ in an apparent attempt to give a sense of authority and confidence when wanting to make a point about user experience. So, thus it is stated: “Increases in the number of seconds of time lost due to congestion on motorways also varies under the Core scenario; from 81.8% in one region to 215.5% in another”. Reporting an increase in seconds of lost time to four significant figures of precision, when looking at projections out over a 35-year period into the future to 2060. Not only that, but taking a range of what I would refer to as ‘between roughly 80 and 220%’, and still being unable to resist the false precision at either end of the range. I find this quite remarkable. And to add insult to injury, the very next paragraph starts with “These projections are not definitive predictions of what will happen in the future and are not a predictor of the level of expansion required on the national road network”. Not definitive predictions, but applied as falsely precise as you’d like!!

9 - Long live predict and provide?

The NPS recognises that the Transport Decarbonisation Plan has committed to moving away from ‘Predict and Provide’ towards ‘Decide and Provide’ as a transport planning perspective. However, it is at pains, it seems, to point out that “various challenges will be presented at certain sites” such that a vision-led decide and provide approach “will not always offset the need to increase capacity”. It goes on to point out that “In some cases, to meet the need set out in this NPS, it will not be sufficient to simply expand capacity on the existing network [with new and improved junctions and slip roads, dualling of single carriageways, and additional lanes on existing dual carriageways]. In those circumstances new road alignments and corresponding links, including alignments which cross a river or estuary, may be needed to support increased capacity and connectivity”. More boldly, the NPS elsewhere states that (my emphasis added) “They [the national road traffic projections] do, however, demonstrate that continued absolute traffic growth is likely under all scenarios, and therefore enhancements on the national road network will be necessary in order to ensure the national road network operates effectively in the face of growing demand.” There you have it – long live predict and provide. In England at least.

10 - Mention biodiversity net gain but not too much

I was pleased to reach a section in the NPS (on page 41) titled ‘Biodiversity Net Gain’. Ah, I thought, perhaps COP15 has worked its magic, and we are finally moving past ‘minimising biodiversity loss’. No mention of COP15 here, but in the half page, four paragraph length of this section the following statement is included. “Biodiversity net gain is an approach to development that delivers measurable improvements for biodiversity by creating or enhancing habitats in association with developments. Applicants should therefore not just look to mitigate direct harms, but also identify and deliver appropriate opportunities for nature recovery and wider environmental opportunities for enhancements by providing net gains for biodiversity.” Biodiversity is also returned to later in the NPS on page 59. More good news perhaps? My concern, however, is that there is no room, it would appear, to entertain a Nationally Significant Infrastructure Project that is positively focussed on an investment in achieving biodiversity net gain, as opposed to it being (still?) an (aspirational?) by-product of new infrastructure schemes. Mention is made of a ‘Biodiversity Gain Statement’ in the NPS three times, but without it being further explained. My understanding from reading elsewhere is that the Environment Act 2021 makes Biodiversity Net Gain mandatory in England, and “To achieve biodiversity net gain, a development must show evidence that a development will increase the biodiversity value of a site by at least 10%” (LTT 864). Let’s hope National Highways is not just banking on planting more trees for this purpose in the light of the recently reported experience where National Highways is said to have planted 850,000 saplings as part of the A14 upgrade, but an internal review seen by Sky News revealed that three-quarters of them have died.

Conclusion

Having got to this point in my Review, you will probably not be surprised to hear that I’m not convinced of either the approach, or the internal consistency, of this revised National Policy Statement. And am concerned that it will just slip into being a box ticked for the appropriateness of roads policy without proper discussion and examination as to its suitability. And worse, be seen as just some technical manual beyond policy debate. In contrast I see multiple areas for challenge, and strong signals of the ‘old school’ philosophy of ‘predict and provide’ as a basis for building new roads living on in its language and reasoning. I’m particularly unclear – and alarmed – how a conclusion could be reached that “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS”.

It has taken the best part of two years for this NPS review to result in the draft now available for consultation, a draft which for me at least is inadequate. I imagine countless person months of effort have gone into it by those working within, or for, the Department for Transport. And I’ve found multiple causes for concern after only spending a couple of days trying to dig into it. I’ve not been commissioned to do that – and who else will have the time or the inclination to look any harder than that? Perhaps they are out there.
Major scheme promoters with deep pockets are able to produce much material in support of their proposed schemes that requires a skilled eye to make sense of and unpick, only for those wishing to scrutinise having to do so on a shoestring. Similarly, I feel as though the invitation for people and organisations to respond to the consultation on this draft NPS has the consultees for the most part at a clear disadvantage in terms of time and resource at their disposal. Hopefully the lawyers out there can dig deeper, and help ensure this revised NPS does indeed set in place appropriate expectations and tests against which scheme promoters must in future set out their case in the interests of nationally significant infrastructure that delivers stewardship of the future in economic, social and environmental terms.

References and Links:

• Consultation on an updated National Networks National Policy Statement (NNNPS)
  

• Appraisal of Sustainability (AoS) report for the National Networks National Policy Statement
  

• The Transport Decarbonisation Plan
  

• Nationally Significant Infrastructure Projects Reforms Action Plan
  

• The National Infrastructure Planning web page from the Planning Inspectorate