TAPAS.network | 23 May 2023 | Editorial Opinion | Peter Stonham
ANOTHER WEEK, another set of weighty-seeming transport strategy documents, that may or may not form part of a cohesive, consistent and logical overall framework. But which can certainly be seen as constituting part of a labyrinthine sequence of seemingly overlapping, intense material that is hugely time consuming to even read, let alone respond to, and appears to fail to really address a number of fundamental underlying issues.
It all suggests that the Government and its agencies are heroically ploughing on in seeking to set down detailed futures in a world of unstable and unpredictable change. More importantly, can anyone really keep up with all those words, tables and charts – even inside Government, let alone outside, and amongst people and bodies needing to press on with their own immediate priorities, but materially concerned by what all this documentation may mean.
This week, it’s been time for the latest conversation about the National Strategic Road programme, and planning for the next Road Investment Strategy, RIS3. This has brought a set of four publications from National Highways (or it would be two dozen, if each of the Route Strategies is counted separately), plus two from the Department for Transport responding to these. And all seeking feedback.
For the record, NH itself has published its Strategic Road Network Initial Report for 2025-2030, its long-term strategic plan, Connecting the Country, and its Environmental Sustainability Strategy, plus the 20 separate Route Strategies. DfT has simultaneously published Shaping the Future of England’s Strategic Roads, its consultation on the NH strategic document (there is also a video you can watch on this, if you’ve got time between now and the closing of consultation on the 13th July). In addition, there is the Analysis to Inform RIS3, produced by the DfT’s Chief Analyst on which consultation feedback is also invited.
All these documents cannot be seen in isolation, however. They follow the important related, and already published draft revised National Networks National Policy Statement, arguably even more significant, as it defines the framework that will be used to assess all future strategic road (and rail) schemes. Consultation on that closes on the 6th June. Not overlooking, of course, the Appraisal of Sustainability published alongside it, and the Habitats Regulation Assessment likewise. Which should not be confused, of course, with the Understanding Biodiversity Net Gain Guidance, issued by DEFRA in February to advise project developers – including National Highways and Network Rail – and local planning authorities on this new dimension to planning principles.
Meanwhile, there also is the recently tabled and equally relevant Nationally Significant Infrastructure Projects (NSIP) Reforms Action Plan, published by the Department for Levelling-up Housing and Communities on the 23rd February, on which the Government has also been consulting. This cross-Government intervention is intended to deliver reforms to streamline planning for Nationally Significant Infrastructure Projects (NSIPs) by making the system ‘better, faster, greener, fairer and more resilient’. The action plan sets out how the reforms will be delivered across government (including the Planning Inspectorate) to meet these objectives.
Alongside this, another Government agency with a finger in the same pie, the National Infrastructure Commission, has also been busy producing an Interurban Transport Advice Note on Roads Policy. This recommends that yet another document is needed to guide the way the strategic network is developed, as NIC believes the government actually needs an interurban transport strategy. That would be “built around a single vision to drive economic opportunity and narrow disparities between regions, and protect and enhance the environment”. This would “do what is necessary to decarbonise the transport network”, and “bring coherence to the national road programme and enable projects to progress.”
But hold those horses. “Developing an integrated interurban transport strategy is a large and complex task” says NIC. Its advice is that such a strategy should develop tools to help analyse the issues from a strategic perspective. “From our analysis we have developed maps that highlight the most potentially highly demanded parts of the road network, and where performance is relatively poor”, says NIC. And there are more voices to be heard, it believes, as NIC “recognise the value of the input of other bodies that the government has been instrumental in establishing, notably Subnational Transport Bodies and Mayoral Combined Authorities, and the approach should be complemented with their input on local opportunities that would not appear in NIC’s analysis, and perhaps by association, not in those of National Highways, or in the frameworks set down by the DfT and other Government departments for the NNNPSs and other framework guidance.
As the NIC mentions, all these strategic horizons for transport infrastructure investment must surely need to be set against the climate change and decarbonisation requirements that are now core to national well-being.
In that regard, there was a huge batch of context-setting documents produced only last month, on the UK’s so-called ‘green day’, which saw an avalanche of climate, energy and carbon-related announcements. This package dwarfed the DfT’s recent output by including, at a rough count, no less than 44 documents from the Department of Energy Security and Net Zero running to 2,840 pages, looking at both energy supply and decarbonising actions across the economy, including in transport. Amongst these documents were the full Energy Security Plan – Powering Up Britain and the Net Zero Growth Plan, the government response to the Net Zero Review by Chris Skidmore MP, ten National Policy Statements relating to energy, the Green Finance Strategy, Community Benefits Consultation, Sir Patrick Vallance’s Pro-Innovation Regulation of Technologies Review, the 2030 Strategic Framework for International Climate and Nature Action, and a range of papers specifically covering development of hydrogen power and other energy sources.
Plus technical annexes, and the Government’s response to the Committee on Climate Change 2022 progress report.
Perhaps from transport’s point of view, however, the most significant document in this compendium was the new Carbon Budget Delivery Plan, replacing the earlier Net Zero Strategy from 2021, which the courts had found wanting. It is this document that has set a new, more loosely defined, trajectory forward for the transport sector, significantly less demanding than that set out before in the Transport Decarbonisation Plan, just two years ago.
The full consequences of this change may as yet still not have been fully recognised, as explored in an article in this issue by Professor Greg Marsden based on his analysis of the comparative data and its implications that shows a major step back from previous Net Zero commitments.
Quite a sea change seems indeed to have been happening in terms of how the Net Zero objective should be approached. The Skidmore review of Net Zero – commissioned by ministers themselves – found the government was “not matching world-leading ambition with world-leading delivery”, and the Carbon Budget Delivery Plan seems effectively to confirm that the UK is not on a secure course to deliver on its international climate pledge for 2030 under the Paris Agreement, or its legally-binding sixth carbon budget. But, rather than addressing those shortcomings, sceptics see the new Carbon Budget document, which formally responds to the 2022 High Court ruling finding the UK’s net-zero strategy unlawful, as principally designed to fend off the risk of immediate new legal challenge.
from transport’s point of view, however, the most significant document in this compendium was the new Carbon Budget Delivery Plan, replacing the earlier Net Zero Strategy from 2021, which the courts had found wanting. It is this document that has set a new, more loosely defined, trajectory forward for the transport sector, significantly less demanding than that set out before in the Transport Decarbonisation Plan, just two years ago.
For the Department for Transport itself, the focus is now strongly on a fuel switch, by which the sector will potentially clean up its act, with the Zero Emission Vehicle (ZEV) Mandate being published on the same day as the big green wave, along with the CO2 emissions regulation for new cars and vans in the UK, plus an accompanying ZEV Efficiency Requirements Consultation-stage Cost Benefit Analysis. Responses on these documents are ending this week on 24th May.
The newly prioritised approach to decarbonisation for transport, highly dependent on a successful switch to electric vehicles with no collateral downsides in terms of wider transport carbon consequences, is explored elsewhere in this issue, by both Professor Marsden and Professor David Metz. Metz believes, in the matter of the change to electrics, as with an increasing number of government transport policy areas, the documents and supporting technical papers reveal the true nature of uncertain forecasts and speculative outcomes concerning economic development, climate change and future travel patterns. Too much faith is being placed in the models that underpin these outputs, Metz believes, with too few challenges provided for decision-making frameworks on which everything else relies.
It is not just observers like Professors Marsden and Metz who are willing to acknowledge the sense of ‘false certainty’ that all these apparently heavyweight documents are seeming to engender. The Carbon Budget Delivery Plan itself comments, alongside one of its core sector carbon forecast charts, that “These are only projections and should not be interpreted as hard sectoral policy targets. Within our overall carbon budgets it is vital to retain a degree of flexibility to adjust our plans as circumstances change given the complexity of the net zero system and the inherent uncertainty in any projections. Modelling cannot always take into account systemic feedback effects, which are hard to quantify. Other factors such as consumer behaviour, technological innovation and the speed and structure of future economic growth further contribute to Carbon Budget Delivery Plan intrinsic uncertainties of long-term sectoral emissions.” That is quite a disclaimer.
Nor is there an evident plan to deal with other forms of externality, including non-fuel related emissions and noise pollution, and the scopes two and three of greenhouse gas emissions from beyond direct transport vehicle use and embracing the generation of original energy and all the other indirect emissions that occur within the broader transport and travel-dependent economy in the upstream and downstream activities of individuals and organisations relating to it.
Against this background, the unconvincing and significantly criticised NNNPS Appraisal of Sustainability is just one of the examples leading to a lack of faith that the DfT has given proper thought to assessing the potential impact of the roads programme on climate change and the need to cut carbon emissions. Whilst a general wish is invariably expressed to do more on sustainability, all major road construction schemes for the foreseeable future will continue to be net negative in carbon terms, even if much of the traffic travelling on them is moving closer to being clean, with the switch to electrics – although progress on that trajectory itself is far from secure. Nor is there an evident plan to deal with other forms of externality, including non-fuel related emissions and noise pollution, and the scopes two and three of greenhouse gas emissions from beyond direct transport vehicle use and embracing the generation of original energy and all the other indirect emissions that occur within the broader transport and travel-dependent economy in the upstream and downstream activities of individuals and organisations relating to it.
Alongside this, the need to get to grips with maintenance and renewal, and adapting to climate change to improve resilience and reliability to calamitous weather effects is arguably a much greater priority than has yet been acknowledged.
These bigger and more fundamental issues seem to be beyond the purview of most of the transport policy outputs mentioned at the beginning of this piece.
In this context, Professor Metz wonders how the DfT can justify its concentration on great detail like the cost-benefit analysis the DfT has published in support of options to implement the Zero Emissions Vehicle Mandate – the legislative framework to fulfil the government’s objective to phase out the sale of internal combustion engine cars and vans by 2030. This is essentially a supporting document to the consultation intended to finalise details of the phase out, so why has the DfT has bothered to generate a 130-page report of a cost-benefit analysis, since no decisions seem to hinge on it, asks Metz. “Perhaps the Treasury wanted assurance that the cost-effectiveness would be acceptable in comparison with other decarbonisation measures. Or perhaps the DfT economists wanted to parade their competences when recent cost- benefit analysis had failed to be supportive of decisions on a number of major road and rail investments,” he suggests.
Meanwhile, the Department’s technical leads seem still to be earnestly beavering away at what they obviously believe to be helpful tweaks and extensions to its analysis and assessment tools embodied in TAG, and the newly added multi-scenario approach, and uncertainty toolkit. Indeed, in the newly published Analysis to inform the consultation on RIS3, prepared by the DfT Chief Analyst, Amanda Rowlatt, she states that her Department has been “developing our analytical approach, methods, and tools in a number of areas building on the sound approach developed for RIS2”, implying no major change is in prospect.
Is this really enough to cut through all the contradictory noise and confusion of the welter of work affecting transport decisions mentioned earlier? And to reach an appropriate new level of clarity about the core principles on which all transport decision making should consistently be based, and that is understood and accepted by a suitably broad range of interested parties? To do that surely requires a conversation that allows more people and more perspectives than simply extending what the existing Black Box of trailing input and output wires can accommodate.
Something more fundamental now seems essential. As Professor Metz comments, this is not the first time we have been in a situation in which there have been real doubts about the approaches to transport analysis being followed by the DfT. More than a Quarter of a Century ago it was accepted there should be an independent opportunity provided for some external critical review. This was undertaken by SACTRA – the Standing Advisory Committee on Trunk Road Assessment. SACTRA was set up as a free-standing body to advise the DfT, and subsequently issued two carefully argued and influential reports in the 1990s. One confirmed the importance of induced traffic arising from new road construction – a view that had been resisted by the DfT since such traffic added to network congestion and reduced travel time savings. The other recognised the wider economic impacts of investment, beyond the conventional time saving, vehicle operating costs and those externalities to which monetary values could be attached. Estimation of such wider impacts, such as agglomeration effects, now forms part of the standard approach to investment appraisal.
Given the confusing and fragmented decision-making landscape that exists now, and the absence of a suitable underpinning framework for carbon and climate-conscious decision-making, there again seems an urgent need now, to reconstitute SACTRA, or some similar group of independent experts, to look at the suitability of the current body of official guidance on transport economic analysis and modelling. And hopefully, alongside this, to likewise rationalise and synthesise the plethora of policy documents and guidance we are now witnessing emerge almost weekly, to match an era when decarbonisation is a national policy priority, and there should be consistency of thinking running through all related decision-making.
Confidence in the overall sense of direction being fit for purpose seems to have been draining away, and much as the institutions of government would like to armour-plate existing top down policies against legal and political challenge, it seems most unlikely that a period of resultant stability and consensus is about to break out.
All this high intensive activity may be designed to give the impression of well-directed and carefully considered effort – but there must be great doubt whether the current incremental way of doing things to an established pattern is really fit for purpose.
Peter Stonham is the Editorial Director of TAPAS Network
This article was first published in LTT magazine, LTT869, 23 May 2023.