Representation by Sheffield Climate Alliance (Sheffield Climate Alliance)
- Date submitted
- 9 September 2021
- Submitted by
- Members of the public/businesses
Introduction We are commenting on this proposed scheme because it would increase greenhouse gas emissions during a climate emergency. Since the scheme was proposed in 2018, stronger local and national climate targets have been set, which the scheme could not reasonably align with. How transport projects are assessed against climate targets The National Networks NPS states it is unlikely that a road project will, in isolation, affect our ability to meet national carbon targets. Using this guideline alone is extremely inappropriate since it is clearly the cumulative impact of all road capacity that can endanger carbon targets. The fact that surface transport emissions have barely reduced in 25 years shows a more rigorous approach is long overdue. Meanwhile, TfN is currently carrying out analytical work for all northern transport. This has already shown that its current investment programme will not fit with newly tightened national climate targets. This should prompt all schemes to be examined more critically. Emissions associated with the scheme We compare these to the most appropriate notional transport carbon budget for the area. Tameside’s is the best comparator as it covers most (though not all) of the area of the scheme. Note that Tameside Council declared a Climate Emergency in February 2020 and committed to align with Greater Manchester ambitions to become net zero by 2038. Projected emissions are stated in paragraph 14.13.1 of Highways England’s Environmental Statement. The total construction and operational emissions are 84 484 tCO2e from 2023 until 2032. Here, we will consider the period from the roads’ opening in 2025 to the end of the fifth carbon budget, at the end of 2032. For simplicity, we will account for all the construction emissions within that period. Whilst technically inaccurate, this gives a less complex comparison than if the construction emissions are accounted for before the roads become operational. The evidence base behind Tameside’s climate targets is at [redacted]. From this, we derive a carbon budget of 4.57 MtCO2e for Tameside for the period 2025-2032. The national average of 27%, 1.23 MtCO2e, is allowed for transport. This means the link roads represent 7% of Tameside’s entire notional transport carbon budget. For just two link roads that feed traffic to and from more major roads, that is clearly a disproportionate share of the total emissions target for an entire Local Authority area. (In practice, the emissions would be spread across three Local Authorities area but this does not alter this principle). National carbon budgets are set at a more generous level than Tameside’s but again, our proportionality principle still holds. It should also be noted that the CCC has advised the Government that the most cost effective path towards meeting its net zero target involves out-performing the fourth and fifth carbon budgets. Conclusions We believe that in view of the climate emergency, all investment decisions need to fit with climate objectives. We urge that this link roads scheme proposal be rejected and consultations carried out on more sustainable transport solutions.