Representation by Climate Emergency Planning and Policy (Climate Emergency Planning and Policy)
- Date submitted
- 15 October 2022
- Submitted by
- Members of the public/businesses
Dr Andrew Boswell, Climate Emergency Planning and Policy I am an independent environmental consultant specialising in climate science, policy, and law, and I object to the A12 Chelmsford to A120 Widening Scheme: (1) Chapter 15 of the ES presents estimates of the greenhouse gas (GHG) emissions for the assessment of significance of the scheme against the fourth, fifth and sixth carbon budgets. Only “scheme-only” estimates are given and assessed (eg the bottom line of Table 15-23), and this does not comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (“the 2017 Regulations”). One of the requirements of the 2017 Regulations is that the applicant must provide an environmental statement (“ES”) including the cumulative impacts of the project and other existing and/or approved projects on climate change. The requirement can only be discharged by providing a separate cumulative assessment in Chapter 15. (2) The so-called “TDP Sensitivity Test” given at Table 15.24 is not based on any standard, documented or official guidance. It is an “ad-hoc” method which is not even a sensitivity test in the real meaning of the term. (Fudge factor is a more precise description). (3) 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 15 does not follow this guidance, and instead makes a sole assessment of significance against the entire UK economy carbon budget. (4) The very large construction stage emissions of 428,626 tCO2e [Table 15-21] have been omitted from the cost side of the BCR. These would amount to over £100,000,000 at the 2025 government carbon valuation increasing the cost side. The value of cumulative operational carbon emissions from the scheme has not been used in the benefit side of the BCR calculations, because no cumulative assessment has been done. (5) Section 15.8.6 highlights that Essex already has much greater emissions for transport (47.8%) than the East of England or the UK. The scheme has large construction emissions (428,626 tCO2e) in the 4th carbon budget, and introduces new emissions into Essex from 2027 at levels of >140,000 tCO2e for both the 5th and 6th carbon budgets. These new emissions are so significant that they would have material impact on the ability of the Government to meet its carbon reduction targets (NNNPS 5.18 significance test). (6) We are in a climate emergency, and recent record-breaking global heating and drought in the UK, Europe and around the world demonstrate that it is a crisis of ever-increasing dimensions. No scheme increasing carbon emissions on this scale, having a material impact of meeting UK carbon budgets, can be justified within the planning balance. Further, it is not morally acceptable for such a scheme to go ahead and add to increasing climate chaos.