Source · Select Committees · Transport Committee

Recommendation 5

5 Not Addressed Paragraph: 31

Undefined "residual" greenhouse gas emissions in NNNPS leave infrastructure schemes vulnerable to legal challenge.

Conclusion
The draft NNNPS permits “residual” greenhouse gas emissions from NSIPs, but does not define what “residual” means, nor does it set out a threshold or limits for a level of emissions that would be deemed “residual”. Accordingly, schemes which are likely to cause an increase in carbon emissions may remain vulnerable to legal challenge.
Government Response Summary
The government discusses the robustness and transparency of decision-making processes and the National Transport Model, but does not address the committee's concern about defining 'residual' greenhouse gas emissions or setting specific thresholds for them.
Paragraph Reference: 31
Government Response Not Addressed
HM Government Not Addressed
The Department for Transport believes that the decision-making process for schemes is robust and transparent. The process provides many opportunities for stakeholders and the public to influence options, and the DCO process is conducted in public in order to be transparent. However, it is right that democratically elected ministers take the ultimate decisions on preferred options for major schemes, taking into account all the relevant considerations. National Transport Model The model that is used to produce the National Road Traffic Projections 22 (NRTP22) is the National Transport Model (NTM). The purpose of the National Road Traffic Projections is to inform and shape strategic policy development, to provide a common and consistent basis against which policy options can be compared, and to further our understanding of the drivers of travel demand and how they impact on traffic levels, congestion and emissions in different plausible scenarios. The future is inherently uncertain so the NRTP22 has utilised the core scenario and seven Common Analytical Scenarios which have been deliberately designed to consider a range of futures based on the biggest drivers of uncertainty. The Common Analytical Scenarios explore uncertainties in demography, economic growth, regional redistribution, behavioural change, emerging technologies, and decarbonisation. This is based on careful engagement about which uncertainties should be considered and prioritised. The Department for Transport considers this to be a proportionate and representative approach to modelling future scenarios. Full details and explanations of the Common Analytical Scenarios are published in the Uncertainty Toolkit2, as part of the Transport Analysis Guidance. Due to the considerable level of complexity, the digital infrastructure used and some of the sensitive inputs, it is not appropriate to make the model fully available to the public. However, there are various reports published on the NRTP22, including inputs, assumptions, outputs and validation of the results. The outputs of the modelling are published in summary tables3, and in a format that allows others to manipulate the data into the format most useful to them. There are also multiple reports available on the NTM4, including details of the modelling structure, peer reviews and quality reports. The Department for Transport is committed to upholding the highest analytical standards and practices and regularly reviews modelling with external experts. This includes ongoing collaborative discussions with the Joint Analysis Development Panel (JADP). JADP was established in 2015 and brings together academic and professional experts with senior departmental analysts. The panel provides expert advice to the Department for Transport on its modelling and appraisal methods and strategies. There are annual reports of the panel’s activities published online. Regarding the committee’s recommendation to model a wider range of scenarios where traffic levels on the SRN are reduced or maintained at current levels, our current analysis shows that it is likely that demand management policies would be necessary for this to be realised. Otherwise, projected changes in the three main drivers of traffic growth (GDP, population and motoring costs) lead to a projected increase in road demand (although the low economy scenario projects reducing trips for the last 15 years of the series, and if the trend continued would lead to reduced traffic levels). The government’s policy is not to stop people travelling but to enable people to do the same things differently and more sustainably while still realising transport’s social and economic benefits. For this reason, the Department for Transport does not model scenarios which incorporate policies designed to reduce demand. Congestion forecasts The NRTP22 includes datasets on Lost Time (in seconds) by road type which is used to generate projected motorway congestion figures in the NRTP22 report. The outputs have been published in summary tables5 alongside data that can be easily manipulated for the user’s purposes. Additionally, the Department for Transport produces statistics which show historic road congestion and travel times on the SRN6. 2 GOV.UK Guidance. ‘TAG uncertainty toolkit’ 3 Department for Transport. ‘National Road Traffic Projections 2022’ 4 Department for Transport. ‘Transport and appraisal modelling tools’ 5 Department for Transport. ‘National Road Traffic Projections 2022’, accessible data, worksheet 3. 6 Department for Transport. ‘Road congestion and travel times’ Project control framework Alternatives and options are considered at various stages of the decision-making process for road schemes and are often shaped by engagement with stakeholders or public consultation. The Department for Transport’s Transport Appraisal Guidance (TAG) requires scheme developers to consider alternative options for schemes from the start of scheme development, including considerat