Select Committee on Environmental Audit Written Evidence

Memorandum submitted by CPRE WM

  This evidence considers briefly the information feeding into the Department for Transport from the West Midlands region. We do not have evidence relating to other regions, but we are concerned that poor advice from this region (specifically in relation to the Regional Energy Strategy) could lead to a lack of proper understanding of the impact of regional investment programmes (such as Regional Funding Allocations) on Carbon Emissions. As a result we are concerned that Climate Change considerations may not play an adequate role when it comes to infrastructure projects such as the M6 Expressway in Staffordshire and Cheshire.


  In 2004 the Regional Energy Strategy was published for the West Midlands by the Regional Assembly. CPRE WM was specifically involved in the Renewable Energy Working Group. Our response to the Strategy (attached) [not printed] highlighted concern about the transport data, and also highlighted the fact that the predicted growth in aviation had not been taken into account. This would have had a negative impact on CO2 emissions.

  The transport element of the strategy was developed by a working group of transport planners for the region. They were already responsible for developing the Regional Transport Priorities and strategies for the region which were driven by the Department's congestion and economic goals and by the political views of regional and local politicians. Unlike most of the people involved in developing other elements of the strategy, carbon reduction was also not their main expertise.

  Not surprisingly the recommendations in the transport section did not challenge those priorities or strategies. However, what was of particular concern were the claims the strategy made of reductions in CO2 emissions and the lack of a clear basis for them. These are detailed in the attached response [not printed]. The strategy concluded that stabilisation of emissions would be possible by 2010 leading to a reduction in CO2 by 2020 of 0.7 mt (7%).

  The strategy claimed that this conclusion was based on the outputs of the three main multi modal studies in the region, at the time the best widescale examination of transport impacts across the region. However, all the Multi-Modal Studies assumed overall increases in CO2 emissions whether or not their strategies were implemented and only the West Midlands Multi-Modal Study assumed a reduction even in the increase of emissions as a result of their strategy. They all took account of improved vehicle technology.

  The Energy Strategy's specific assertion that the West Midlands study proposals would reduce emissions to 1996 levels is wrong and is not supported by the study itself, which predicts a 6% rise in emissions. This is based on a flaw of assuming that if congestion reduced to 1996 levels emissions would also do so. This is clearly not the case since the overall level of traffic has risen.

  Furthermore, when the strategy was produced it was already apparent that many of the non-road building options in the Multi-Modal Studies were unlikely to be delivered as compared to the road building options, and that there were uncertainties about the deliverability of charging regimes and behavioural change levels. All of which meant that in reality the parts of the Multi Modal Studies one would expect to lead to CO2 reductions were exactly the parts not being delivered.

  As a result of this it is almost impossible to see how the conclusion in the West Midlands Energy Strategy as regard transport can be supported.


  One of the specific results of this is that the conclusions of the West Midlands-North West Multi Modal Study (Midman), which recommended widening the M6 in Staffordshire and Cheshire as part of a wider package of measures, are now being used to support either widening that motorway or a new M6 Expressway toll road.

  In fact the Midman Study said "a degree of subjective judgement" was required in determining whether that option was better than the non-widening package. It also concluded that the only option which reduced the growth in CO2 emissions was the non-widening package.

  Furthermore the rest of the recommendations in Midman are in many cases not being pursued and in some cases important "base case" elements are actually being lost (such as rail services between Walsall and Stafford)

  Nor is the Department now prepared to consider the alternative non-widening option which Midman identified as delivering the required M6 reliability. Stephen Ladyman, the Minister responsible, specifically ruled out the non-widening option when he visited Stafford earlier this year and that has been confirmed by letter.


  As well as looking at surface transport, which the energy strategy did consider, CPRE WM also specifically undertook to assess the impact of including the growth of aviation in the West Midlands predicted in the White Paper on the Strategy. Our work suggested that the aviation emissions would eliminate all the gains that strategy produced. Our technical paper is attached explaining the reasoning behind this [not printed].


  More recently the process by which regional priorities for transport have been set has been the Regional Funding Allocations bids. These have now gone into Government. In our case the methodology was developed by Ecotec and Faber Maunsell for the Regional Assembly. We have criticised both the lack of openness of this process and the level to which it uncritically relied (particularly in relation to environmental impacts) on the information from local authority promoters.

  The West Midlands Regional Prioritisation Framework is largely an examination of the cost- benefit and other economic impacts of a scheme. It does examine the environmental impact, but the process appears to be subjective and is certainly opaque to outsiders. Carbon emissions are only one element among a list of nine.

  The resulting supporting information from the consultants simply lists individual schemes in terms of positive, negative or neutral environmental impact. There is no way of identifying climate change impacts of individual scheme. The submission to the Secretary of State, which resulted from this process, did not refer to Climate Change impacts and there was no discussion of them at the Regional Assembly's Transport Partnership, Planning Partnership or the Regional Assembly itself when the list of schemes was discussed.

  Nor was there any wider assessment of the overall Climate Change impacts of the set of schemes prioritised beyond whatever individual material was submitted to the consultants by promoters of individual schemes.

  In our view the list is over-dominated by road schemes, including a number of controversial bypasses, and we have recently written to the Secretary of State for Transport raising these concerns. But, in particular, we question how he can properly judge the Climate Change implications of the schemes.

  Our concern that much that was in the Multi-Modal Studies which might reduce emissions was not being pursued strongly enough, is also underlined by the schemes which have been recommended by the Regional Funding Allocations process.

  The Committee may wish to examine to what extent these deficiencies can be rectified when the list reaches the Department for Transport and to what extent Climate impacts will be critically assessed in determining allocations of Regional Funding for transport.


  In our view three is a lack of expertise on the relationship between Climate Change issues and transport within the West Midlands region.

  This means there has been a lack of critical examination of transport policies and proposals in relation to Climate Change emissions.

  This has led to a lack of firm information at all levels of decision making to judge Climate Change implications of transport decisions.

  At present we do not see any champion of the Climate Change issue who has the political authority to challenge transport decisions in the region which increase emissions. Indeed, much of the real effort in terms of reducing CO2 emissions has been directed towards other sectors other than transport, while transport policy has carried on with little regard for its Climate Change implications.

February 2006

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