This is an annotation of the text of a briefing Transport for the North’s Carbon Shame? sent to TfN board members prior to their meeting on Thursday 13th September, to allow them to factcheck the sources of the information it contains.
● Environmental Transport Organisations – the briefing has been prepared by individual Northern regional members of organisations including northern Campaign for Better Transport, Campaign to Protect Rural England, Friends of the Earth, Railfuture, Zero Carbon Yorkshire.
● Please note the ? after the words ‘carbon shame’. We hope it’s possible for TfN to avoid this serious charge by taking corrective action now.
● With transport emissions now more than 40% of the UK total (DfT) See Department for Transport Future of Aviation 2018 figure 10 page 61
● … and rising The DfT figures were for 2016, and had increased from 36% in 2015. With both surface and aviation emissions having risen again in 2017 (and probably in 2018), combined with continuing emissions reductions in the other UK sectors, then it is very probable that transport emissions will now be higher than 40%, and edging towards 50% of total UK carbon emissions.
● … and with the Committee on Climate Change recommending that instead these need to be reduced by 44% between now and 2030 See CCC 2017 Progress Report page 110. The significant point is the 2030 deadline. TfN, like other transport policymakers, is at the moment, relying on the progressive adoption of electric vehicles between 2030-50 in order to make progress with carbon reduction. But keeping keep carbon reduction within the limits of the 4-5th carbon budgets requires transport emissions to be radically reduced over the next 12 years. Please note that this number excludes aviation emissions, which are also rising rapidly.
● The STP contains no commitment to reduce carbon emissions by a quantified amount. In order to demonstrate carbon reduction consistent with the CCC recommendation the STP needs to actually quantify the amount of emissions reduction it intends to achieve by 2030.
● Not only will it not reduce these climate changing emissions, in fact its actual effect will be to increase them, and as a matter of deliberate policy. This is the most serious criticism of all. The letter to John Cridland identifies three segments of carbon emissions which the STP contains proposals to increase: as a result of –
* providing for increased future travel demand (scenarios 1/3 result in road traffic growth of 26-7%, and scenarios 2/4 growth of 52-54% STP p.26)
* consequent to the promotion of the strategic development corridors (Integrated Sustainability Appraisal p.89 “For all SDCs, GHG emissions from road movement is anticipated to grow in the short term, up to 15% in the case of SDC 1, relative to today”.)
* consequent to the promotion of airport expansion, where the STP proposals page exceed even the DfT emissions forecasts which themselves breach the Committee on Climate Change’s planning assumption for aviation carbon. (STP p.29 “Under a transformational growth scenario, it is predicted that there will be 75 million international air passengers per year by 2050, which is 12 million more than the business as usual scenario trajectory.”)
● This has not been disclosed to consultees, and maybe not to you as board members responsible for the strategy. If neither consultees or board members have been informed of the quantified carbon outcomes of the STP, because these have not been assessed and/or disclosed, how could the former have provided an informed consultation response to a strategy proposing to actually increase climate change emissions; and then how can board members judge its compliance with C&LGDA subsection b), c) and d)? See the next item
● TfN’s founding statute requires that the STP ‘must have regard to the social and environmental impacts in connection with the implementation of the proposals contained in the strategy’. See Cities & Local Government Devolution Act 2016 section 102I subsection 8, page 34. The words quoted, which are from 8b) are prefaced by ‘In preparing or revising its transport strategy an STB [subnational transport body] must … have regard to …’ The wording of 8b requires that the ‘having regard to’ of the carbon impacts by the STP must take place when the strategy is being prepared, not afterwards when individual programmes or projects are subsequently developed.
Also relevant are subsections c) and d) which state ‘have regard to … any current national policy relating to transport that has been published by or on behalf of Her Majesty’s Government’ and ‘the results of the public consultation’. Subsection 10 – ‘The constituent authorities of an STB must exercise transport functions with a view to securing the implementation of the proposals contained in the STB’s transport strategy’ – means that it carbon reduction objective identified in TfN’s STP will also be able to provide a framework for carbon reduction by city regions/district authorities as well.
● TfN has not produced an overarching report on how the STP will reduce transport’s emissions, and to a sufficient extent. Whilst TfN have commissioned many expert reports to inform the STP’s preparation, they did not do so in relation to the critical task of how to reconcile transport improvement with carbon reduction, which means that now neither consultees or decision-makers are able to refer to such an expert analysis. Nor is there any reference in the STP evidence base to the carbon reduction framework established by the Climate Change Act.
● … in advance of your board meeting on Thursday we have written to TfN chair John Cridland, setting out these concerns in detail The letter can be downloaded here.
● … risk incurring major reputational risk by failing to respond to rising transport emissions, in the current context of an increased awareness of climate change and extreme weather events. See for example this compilation of stories on Carbon Brief ; and ‘Climate change moving faster than we are, says UN‘ BBC 10th September
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