Representation by Climate Emergency Planning and Policy (Climate Emergency Planning and Policy )
- Date submitted
- 13 March 2023
- Submitted by
- Non-statutory organisations
Dr Andrew Boswell, Climate Emergency Planning and Policy I am an independent environmental consultant. I object to the M3 Junction 9: (1) The most important question is “to what extent does the project contribute, or undermine, securing the Net Zero Strategy (“NZS”) and the net zero target?”. It requires contextualisation within a robust risk assessment of the related policy delivery, and a robust assessment methodology of the significance of the greenhouse gas emissions (“GHGs”). Neither exist in the environmental statement (“ES”). (2) Recent Progress Reports from the Climate Change Committee (“CCC”) show that the success of the NZS and the related Transport Decarbonisation Plan (“TDP”) are by no means secured. No weight can be given to the proposition that they are. The same delivery risk was highlighted by the High Court in 2022 Net Zero Strategy case (A). Further, initial analysis of calculations underpinning the TDP (B) show that the TDP is far from being secured in any meaningful sense. (3) Chapter 14 is based upon an article of faith: the “inevitable success” of the TDP and policies within the TDP eg: at ES 14.7.14. The so-called “TDP Sensitivity Test” used in chapter 14 (eg: 14.10.17), and based on the same article of faith, is not a genuine scientific sensitivity test. No risk or error bounds assessment is given for it. Even the “upper bound” figures are far from secured. The method is not based on any standard, documented or official guidance. (4) Significance of GHGs in Chapter 14 is assessed solely on “scheme-only” (DS-DM) estimates [percentage figures in Table 14.7]. This does not comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 which require that the applicant must provide the cumulative impacts of the project and other existing and/or approved projects. The section “Cumulative assessment approach” (ES 15.3.11 and 15.3.12) does not address this issue because other locally committed developments are expressed in both the DS and DM forecasts, and are subtracted out before the assessment based upon DS-DM (at Table 14.7). (5) The Institute of Environmental Management & Assessment (IEMA) “Assessing greenhouse gas emissions and evaluating their significance” guidance (February 2022) states that best EIA practice for GHGs is to use sectoral, regional and local carbon budgets to contextualise the project’s GHG emissions. The IEMA guidance says comparison against national budgets is only of “limited value”. Chapter 14 does not follow this guidance, and instead makes a sole assessment of significance against the entire UK economy carbon budget. (6) We are in a climate emergency, and it is a crisis of ever-increasing dimensions. Construction emissions of 37,070 tCO2 and non-cumulative operation emissions at 67,670 tCO2 [Table 14.7] from the traffic model area before 2037 demonstrate policy failure. And these emissions have a very real material impact on meeting UK carbon budgets and targets and cannot be justified within the planning balance. (A) R (Friends of the Earth) v Secretary of State for Business Energy and Industrial Strategy [2022] EWHC 1841 (Admin) (B) DfT Information release “Traffic Level and Electric Vehicle Assumptions used in Decarbonising Transport: A Better, Greener Britain”, Jan 12th 2023 https://www.whatdotheyknow.com/request/841974/response/2205457/attach/4/Response to EIR E0020915.xlsm