Representation by Climate Emergency Planning and Policy (Climate Emergency Planning and Policy)
- Date submitted
- 24 August 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 A66 Northern Trans-Pennine Project: (1) The Environmental Statement (ES) does not comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (“the 2017 Regulations”). (2) Chapter 7 of the ES presents estimates of the greenhouse gas (GHG) emissions for 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 7-23, and the “net CO2” data in Table 7-24). (3) 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 the ES. (4) 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 uses multiple sources of evidence, and contextualises GHG assessment against local and regional carbon budgets. The IEMA guidance says comparison against national budgets is only of “limited value”. The ES does not follow this guidance, and instead makes a sole assessment of significance against the entire UK economy carbon budget. (5) The very large construction stage emissions of 518,562 tCO2e [Table 7-21] have been omitted from the cost side of the BCR calculations (3.8 Combined Modelling and Appraisal Report, page 148). These would amount to over £130,000,000 at the 2025 government carbon valuation increasing the cost side to at least £880m. The value of cumulative carbon emissions from the scheme has not been used in the benefit side of the BCR calculations, because no cumulative assessment has been done. (6) The existing adjusted BCR of 0.92 is an investment hard to justify. It should be recalculated for the issues above, which would reduce it further. (7) 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. The scheme increases carbon emissions, and cannot be justified even within the scope of UK climate legislation, especially when properly contextualised by EIA best practice. No scheme increasing carbon emissions on this scale, and at such a poor BCR, can be justified within the planning balance. (8) However, as a scientist in the good company of many others including Professor Sir David King , former UK Government's Chief Scientific Advisor (see his commentary on the Intergovernmental Panel on Climate Change 6th Assessment report “The final warning bell” at www.ccag.earth), I go further and call out the Government targets, policies including the out-of-date NPSNN as being wholly insufficient to the scale of the crisis. The scheme cannot be justified given the very clear moral grounds of its impacts on future beings.