Representation by Transport Action Network (Transport Action Network )
- Date submitted
- 13 March 2023
- Submitted by
- Non-statutory organisations
Transport Action Network objects to the DCO application as the Applicant acknowledges the scheme would lead to increases in traffic and carbon emissions. This will make it more difficult fir tge UK to meet its commitments under the Climate Change Act and our Nationally Determined Contribution (NDC) under the Paris Agreement. We disagree with the Applicant's assessment of significance of carbon emissions. We do not believe the Transport Decarbonisation Plan (TDP) which the Applicant's relies on demonstrates a credible pathway to reduce emissions from road transport fast enough. We also believe that comparing a scheme's emissions against the entire UK's carbon budget for every sector is not a credible or robust comparison. The Applicant's should use the 2022 IEMA guidance and compare the scheme against local and regional transport carbon budgets, to have a meaningful assessment of significance.