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
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
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
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
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.