Representation by Rosie Pearson
- Date submitted
- 14 October 2022
- Submitted by
- Members of the public/businesses
I register an interest in the A12 widening scheme. The Option selected, Option 2, results in six additional lanes (Jn 22/23 and along the 5km stretch between Jn24/25, where the current four lanes seem ear-marked for continuing use). Result: ten lanes between Marks Tey & Kelvedon. Therefore, despite government’s carbon reduction targets, not only does the scheme as a whole generate 34,000,000 million tCO2e operationally and 430,000 tCO2e during construction but much of this is not even necessary. National Highways has never explained why, if one additional lane of capacity each way is required three each way are proposed. Note too that as per my consultation response previously, which has not been addressed in the consultation responses appendix, decision-making for this scheme and earlier responses to proposals were based upon a now defunct local plan. That local plan at the time of initial consultation proposed 24,000 homes at Marks Tey and it looked likely to succeed. It is therefore hardly surprising that responses at the time favoured Option 2. Now, however, the planning landscape has very much changed and there is no need whatsoever for six extra lanes. Highways England must be asked to produce costs and CO2 emissions per lane per km so that stakeholders can see what the impact of the four additional lanes is on the financial and carbon budget of the project. I am also concerned that, as per my consultation submission, which has not been addressed, the requirement to present alternatives under WebTAG rules has not been followed. There must be a clear rationale for any proposal and it must be based on a clear presentation of problems and challenges that establish the ‘need’ for a project. There must be consideration of genuine, discrete options, and not an assessment of a previously selected option against some clearly inferior alternatives. A range of solutions should be considered across networks and modes. This has not been done. These alternatives should have included options such as: • Creating an additional lane for public transport only & investing in buses; • One-lane each way on the offline route where six lanes are proposed for local traffic; current A12 for long distance traffic, smaller junctions closed; • Re-visit the online route and ask the question again in the current No West Tey scenario; • No scheme, for comparison Nor has Treasury Green book requirement to assess Natural Capital been followed. Induced demand means that the more lanes one builds, the greater the traffic induced. This project is culpable of generating significant additional traffic due to the unnecessary four lanes proposed. It is extraordinary that the scheme, which only has a BCR of 0.8 vs 4.6 for RIS overall has progressed this far and it must be the case that the unnecessary lanes are affecting the scheme’s viability – which means that tax-payers are exposed to unnecessary cost as well as wholly unnecessary carbon emissions.