Representation by Anthony Rae
- Date submitted
- 16 September 2021
- Submitted by
- Members of the public/businesses
As a transport and climate campaigner who works at the local, regional, sub-national transport body (Transport for the North) and national levels, the issues I will wish to include within a written representation to be considered by an Examination principally relate to the additional carbon emissions that will be generated as a result of this scheme, and also the additional road traffic. As a member of the DfT/TfN reference group previously considering the possibility of a trans-Pennine tunnel there may also be issues relating to the scheme’s strategic context and justification. I have reviewed the outline information prepared by CPRE concerning potential climate change impacts: ‘Over 60 years of operation the scheme would add an extra 399,867 tonnes of carbon dioxide. Over a lifetime of 100 years, one tree absorbs around 1 tonne of carbon dioxide but we cannot wait for nearly 400,000 trees to grow for a hundred years. Carbon emissions must be tested against international and national legislation and guidance including the Paris Agreement, the 2008 Climate Change Act’s legally binding target of net-zero carbon emissions by 2050, the UK Sixth Carbon Budget, science-based carbon budgets from the Tyndall Centre, and the National Planning Policy Framework which requires ‘radical reductions of greenhouse gas emissions’. The potential for an additional 400,000tonnes CO2 needs to be understood in the context of i) the appropriate local transport decarbonisation objectives and targets; ii) the targets of the TfN decarbonisation strategy; iii) the proposed emissions reduction pathway of the DfT transport decarbonisation plan (TDP); and iv) the transport emissions pathway identified by the Climate Change Committee in their 6th carbon budget report. In the context where transport emissions at both local and national levels have not reduced significantly below the 1990 baseline level for the Climate Change Act, have stayed level or even increased in the 5 year period up to 2019 (pre-covid), and are taking up an ever increasing share of local and national carbon budgets, then it’s imperative that the potential carbon generation impact of the scheme is rigourously scrutinised against local/regional/national targets for radical transport decarbonisation. Since at the present time the results of the consultation on the TfN strategy had not yet been published, and the dataset underpinning the TDP has not yet been released, it will be necessary to review the scheme’s impact in relation to those strategic frameworks at a later date. It will also be necessary to understand the outputs and validity of the traffic generation modelling, which within the Trans-Pennine tunnel working process were never adequately revealed.