Memorandum by English Nature (RP 07)
M6 TOLL ROAD
1. INTRODUCTION
1.1 English Nature is the statutory body
that champions the conservation and enhancement of the wildlife
and natural features of England. We do this by:
— advising—Government, other
agencies, local authorities, interest groups, business communities,
individuals;
— regulating—activities affecting
the special nature conservation sites in England;
— enabling—helping others to
manage land for nature conservation through grants, projects and
information;
— enthusing—advocating nature
conservation for all and biodiversity as a key test of sustainable
development.
1.2 In fulfilling our statutory duties,
we:
— establish and manage National Nature
Reserves (NNRs);
— notify and safeguard Sites of Special
Scientific Interest (SSSIs);
— advocate to government departments
and others effective policies for nature conservation;
— disseminate guidance and advice about
nature conservation;
— promote research relevant to nature
conservation.
1.3 Through the Joint Nature Conservation
Committee, English Nature works with sister organisations in Scotland,
Wales and Northern Ireland to advise Government on UK and international
nature conservation issues.
2. GENERAL COMMENTS
ABOUT THE
M6 EXPRESSWAY PROPOSAL
2.1 English Nature welcomes this short inquiry
by the Transport Committee into the M6 Toll Road and the proposed
M6 Expressway and is pleased to have the opportunity to provide
comments and views on the issues these raise for nature conservation.
Whilst we respond to all of the questions posed in the Transport
Committee's Press Notice 36/2003-04 (issued on 19 July 2004),
we have focused our attention on questions 5 and 6 below as these
are of most relevance to our statutory role as advisers to the
government on nature conservation.
2.2 In order to provide some context we
have chosen to set out in this section our general comments and
concerns over the proposal for a new M6 Expressway Toll Road.
Based on the limited information available, English Nature's initial
view is that the proposed scheme would lead to a range of direct
and indirect impacts on wildlife through land-take, fragmentation
of existing habitats, changes to local air quality and hydrological
regimes, and threats to populations of protected species. There
are at least 16 SSSIs, five of which are internationally important
as part of the Meres and Mosses Ramsar site, together with a number
of protected species, within a 5km corridor alongside the existing
M6. The annex to this submission provides a Character Area overview
of the types of landscape the Expressway would pass through, including
the key wildlife features and species present within the corridor.
It contains a table which lists each of the SSSIs, their location
and nature conservation interest. Important species present in
the area are also highlighted together with a number of non-statutory
sites of nature conservation importance. Any plan to progress
this major project should include as an essential component measures
to maintain a sufficient extent and quality of habitat to ensure
that local populations of protected and other wide-ranging species
remain in favourable conservation status. The protection and enhancement
of biodiversity should therefore be an explicit objective of the
project if it is progressed.
2.3 One of our main concerns is that the
proposal appears to be out of step with recent government statements
about future transport policy. For example, the new White Paper,
The Future of Transport: A network for 2030 (Department for Transport,
2004) states that "to build our way out of the problems we
face. would be environmentally irresponsible". Yet this project
would require a significant amount of new infrastructure and create
a brand new transport corridor. The proposal is also potentially
in conflict with the principles of sustainable development. Any
assessment or appraisal of the M6 Expressway proposal should include
an examination of whether the existing transport network assets
are being fully utilised through the use of technology, speed
limits, congestion charging or other measures. It should also
consider alternative investments which could encourage economic
growth that contributes to sustainable development, for example
through improved resource productivity, reduced waste, enhanced
recycling of materials and so on.
2.4 Furthermore, we don't believe that there
is a rationale for the project as it did not form part of any
coherent package of measures as identified by the relevant Multi-Modal
Studies completed a couple of years ago. We also have a concern
that the proposal could lead to significant land-take and an unnecessary
over-provision of road-space which ends up being under-utilised.
Investments in local transport alternatives that take more local
traffic off the motorway and transfer it to other modes may well
be a better solution for local development and economic growth
whilst enhancing the value of the existing M6.
2.5 The proposal to charge for use of the
motorway is welcome in principle if it signals a commitment by
Government to consider charging regimes for congested routes but
not when applied in isolation to individual roads and especially
new road building. It could set an unwelcome precedent if only
new roads are charged for. In our view the benefits of charging
for road-space can only be fully realised if such measures are
applied on an area-wide basis and to existing capacity in order
to enable any benefits to be "locked in".
3. HOW EFFECTIVE
HAS THE
EXISTING TOLL
ROAD BEEN
IN TACKLING
CONGESTION ON
THE M6, ON
THE NEW
TOLL ROAD
AND ON
THE SURROUNDING
AREA?
3.1 The three main causes of congestion
are excess demand, accidents and breakdowns. We believe that it
is still far too early to fully understand the effectiveness of
the M6 Toll Road in tackling these issues and in reducing congestion.
Changes in traffic patterns and the appearance of "induced"
traffic take periods of years rather than months. It is our view
that the Government should further evaluate the effects of the
M6 Toll Road on traffic flows during 2006 and postpone any major
investment in studies on the M6 Expressway until the completion
of that evaluation. These studies should await the outcome of
the experiments in hard shoulder running and multiple occupancy
vehicles on motorways which were announced in the same month as
the government's decision to consider a new M6 Expressway.
4. WHAT IMPACT
HAS THE
M6 TOLL HAD
ON TRAFFIC
LEVELS?
According to the first three month analysis
of traffic levels by the Highways Agency traffic on the current
M6 has fallen by 10%. It is too early to reach any definitive
conclusions as to the success of the M6 Toll Road, however, and
there is a view that the M6 Toll Road is leading to significant
additional traffic in the Midlands region through the phenomenon
of "induced" traffic. This will have adverse consequences
for the natural environment and result in the generation of more
CO2, noise and NOx emissions.
5. IS A
NEW "EXPRESSWAY"
PREFERABLE TO
WIDENING THE
EXISTING ROAD?
5.1 The building of a new Expressway, unlike
the on-line widening of the existing M6 within the existing footprint,
would carve a significant new swathe through the countryside.
Construction on this scale would inevitably result in the loss
of a considerable area of rural land and have significant implications
for biodiversity. Our supplementary paper to this submission,
which we have already referred to above, provides a description
of the nature conservation importance of the area in question.
According to the Department for Transport's consultation document
a 35 to 40 metres strip of land would be required for the Expressway
as opposed to 25 to 30 metres for widening the M6. Construction
figures for the M6 Toll Road showed that interchanges and side
roads required further land in addition to that required for the
main route. This additional infrastructure required land equal
to 46% of the area of the toll road itself. The proposed M6 Expressway
would also require junctions, feeder connections and toll plazas
yet the current consultation does not make allowances for this.
5.2 Even with the best level of mitigation
this is likely to result in some degree of habitat destruction
and fragmentation, a new barrier to wildlife and extending the
area affected by air pollution. The new route is therefore likely
to have a much bigger environmental impact than widening the existing
route.
5.3 At this early stage, and before specific
options for the route have been considered, it is not possible
to compare in detail the relative merits of a new toll road as
against widening the M6 but this is a key issue that should be
addressed. On the evidence available, however, it is our view
that any new Expressway would not be preferable to widening of
the existing M6.
6. IS THIS
THE MOST
COST EFFECTIVE
AND ENVIRONMENTALLY
EFFECTIVE SOLUTION?
6.1 As we have said above any new parallel
motorway would be significantly more environmentally damaging
than a widening of the existing M6. The proposed Expressway would
provide an extensive length of new motorway cutting through the
countryside. The design of the route would be critical in ensuring
the avoidance of any impact on internationally and nationally
important nature conservation sites. However, if such a project
was pursued steps should be taken to enhance the opportunities
for protected species, such as otters and great crested newts.
A construction on this scale would need to incorporate considerable
areas for habitat creation and enhancement so as to reduce the
scale of impact. Measures such as "green" bridges and
sustainable drainage schemes could be used to deliver environmental
benefits.
6.2 In terms of finding the most environmentally
effective solution, however, we would argue that instead of enhancing
road capacity other measures should be taken. These should be
based around a package of measures including small-scale interventions,
such as bus lanes, technologies to make better use of the existing
road-space, such as variable speed limits, congestion charging
on an area-wide basis and "soft" measures, such as the
adoption of travel plans for offices, schools and tourist attractions.
7. HAVE THERE
BEEN ANY
UNFORESEEN IMPACTS
OF THE
EXISTING M6 TOLL?
7.1 We do not have any evidence but there
is a strong likelihood that the M6 Toll Road has led to traffic
diverting onto less suitable roads, particularly in rural areas.
This will have consequences for biodiversity through additional
pressure for new or upgraded roads, increased local air emissions,
potential damage to protected roadside verges and threats to Biodiversity
Action Plan and other protected species.
8. CONCLUSIONS
AND RECOMMENDATIONS
The proposed Expressway would lead to a range
of direct and indirect impacts on wildlife through land-take,
fragmentation of habitats, changes to local air quality and hydrological
regimes and threats to protected species.
We are concerned that the proposal is out of
step with current government policy on transport, potentially
in conflict with sustainable development and doesn't form part
of any coherent package of measures identified by the recent Multi-Modal
Studies.
The proposal to charge for road-space is welcome
in principle but the benefits can only be realised if such measures
are applied on an area-wide basis and to existing roads.
We recommend that the Government should further
evaluate the effects of the M6 Toll Road on traffic flows and
congestion and postpone any major investment in further studies
on the M6 Expressway until this evaluation is complete.
There are several approaches to improving congestion
and journey time reliability that are far more cost-effective
and environmentally effective than either construction of the
Expressway or widening the M6. For example, measures to make better
use of the existing motorway through the use of variable speed
limits should be implemented.
Widening of the M6 should be preferred over
the Expressway option because of the reduced loss of land area
and the significantly lower risk of unnecessary provision of road-space.
If either the Expressway is built or the M6
widened the protection and enhancement of biodiversity should
be an explicit part of the project and resources should be made
available to improve the overall sustainability of the road transport
system. We recommend that the amount should be commensurate with
the scheme cost of £2 billion and serve to significantly
enhance biodiversity and reduce the CO2, NOx, particulates, noise
and congestion caused by existing vehicles.
Environmental Impacts Team
English Nature
September 2004
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