Fine Words, No Action
Many organisations fighting the Climate and Biodiversity Emergencies point out that the UK Government’s road-building programme should stop.
For instance, Green Alliance, ‘an independent think tank and charity focused on ambitious leadership for the environment’, said in November 2020: ‘Decisions are still being made which are locking in high carbon activity for the long term. For example, the Government plans to spend at least £14bn on new roads and expand the capacity of existing roads, which will increase traffic. This is despite evidence that achieving net zero emissions requires a reduction in car use and ownership, even with an ambitious 2030 phase-out date for petrol and diesel cars.’
The paper for Transport for Quality of Life by Sloman et al., ‘The Carbon Impact of the National Roads Programme’, July 2020, uses the carbon data reported by Highways England to make the first programme-level estimate of the likely carbon impact of RIS2 (Roads Investment Strategy 2). It says in its Introduction: ‘RIS2 will make carbon emissions from the Strategic Road Network go up, by about 20 mtCO2, during a period when we need to make them go down, by about 167 mtCO2. …We therefore believe that it [RIS2] should be cancelled.’
Government policy documents are catching up, and sometimes say the right thing, but meanwhile Highways England has 21 Development Consent Orders in progress for new roads, and there seems to be a concrete wall preventing any government document from saying ‘Put the fine words into practice, abolish Highways England and stop road building’.
1. What the latest government policy advice says
The latest government policy advice seems to echo the words of the Green Alliance. The Green Alliance summary: ‘Put net zero at the heart of all infrastructure decisions.’ Those who attempt to guide policy appear to be listening. The Government body called the Natural Capital Committee (NCC) in its ‘Green Book Review: Final Report’, November 2020, says: ‘1.10. Business cases frequently do not demonstrate necessary understanding of the proposal’s specific contribution to the delivery of the Government’s intended strategic goals (such as…Net Zero).’
The ‘Green Alliance’ paper also links net zero and environmental protection. It says: ‘As part of the current review of the Green Book, the government should ensure that all public spending decisions align with the net zero goal, by setting a ‘net zero test’ for infrastructure proposals, ahead of assessment of the business case and ensuring compatibility with a net zero pathway at the programme level. Environmental principles and Natural Capital should also be embedded into the policy appraisal process.’
Again the Natural Capital Committee appears to be listening. In its November 2020 ‘Green Book Guidance’ the NCC says ‘Overall the NCC has found limited evidence of Natural Capital being considered in policy appraisal…failure to implement Green Book guidance across all relevant decisions should be urgently addressed given the Government’s wide-ranging environmental objectives, including their commitment to avoid further degradation of our natural assets.’ Road proposals are relevant decisions.
Another Government body, the Public Accounts Committee, says progress on the environment is painfully slow. Its Chairwoman, Meg Hillier, said in February 2021: ‘If the Prime Minister is serious about protecting the environment, the issue needs to be owned by the whole of government.’ That includes the Department for Transport, and should include Highways England, supposedly under the oversight of the DfT.
Another Government report, the Dasgupta Review commissioned by the Treasury, points out that ‘Substitution of produced capital (roads, buildings, ports, machines) for natural capital (ecosystems) has not only characterised our investment systems but also shaped our conception of economic progress’ (p. 17). He says that GDP (Gross Domestic Product) or an emphasis on economic growth – an important usual reason given for wanting new roads – is ‘wholly unsuitable for appraising investment projects and identifying sustainable development’.  Yet Benefit Cost Ratios, based on supposed economic returns, are still the main tool for appraising road schemes.
2. The ‘Concrete Wall’
More examples of right thinking can be found in many other Government policy guidance documents. But there always seems to be a stark mismatch between what the Government bodies say, and what they recommend should be done. This is what I call the ‘concrete wall’.
a. The Climate Change Committee (CCC)
The Government’s Climate Change Committee recently (December 2020) produced a paper ‘Local Authorities and the 6th Carbon Budget’. It made the usual promising statements. P. 81: ‘Constraining the growth in vehicle mileage is vital to reducing [carbon] emissions.’ P. 83, in bold: ‘Weighting funding towards active travel, public transport and digital infrastructure rather than road building would help deliver the modal shift required to counteract the likely increase in car use due to the Covid 19 pandemic.’ But nowhere in the paper does the CCC say Local Authorities should stop supporting road building – which increases vehicle mileage.
In April 2020 Chris Stark, the CEO of the CCC, said: ‘The government mustn’t be investing in anything likely to increase carbon emissions. I expect that video conferencing will become the new normal, and we won’t return to travelling the way we did. I would spend the roads budget on fibre.’
The CCC produced a paper in December 2020 called ‘Policies for the Sixth Carbon Budget’. The paper made no mention of road building.
b. The Transport Committee Inquiry
A recent call for evidence about road appraisal by Parliament’s Transport Committee stated that ‘The Government … has a legal commitment to meet net-zero carbon emissions by 2050 and infrastructure is a major contributor to the UK’s Greenhouse Gas emissions.’ But the Committee also said it would consider ‘factors influencing the cost and capacity skills required to deliver the infrastructure plans’ – in other words, it envisaged infrastructure plans as going ahead all the same.
This concrete wall between fair words and suggested actions may be propped up by loyalty to the construction companies who are big donors to the Conservative party. Other, more insidious blocks to the right sort of action – the proliferation of different regulatory bodies carefully differentiated from each other, and the ridiculous crudity of some of the newest policy advice attempting to deal with the idea of ‘natural capital’ – may also be related.
3. The blizzard of initials – buck-passing
The Environment Bill – a promising-sounding initiative – says a new Office for Environmental Protection (OEP) will be set up. The OEP will have an MOU (Memorandum of Understanding) with the CCC (Climate Change Committee) about who will be in charge of what. Para 28(4): ‘A matter is within the remit of the CCC if it is a matter on which the Committee is, or may be, required to report under Part 1, Sections 34-6, or Section 48 of the Climate Change Act 2008’. What happened to ‘The issue [protecting the environment] needs to be owned by the whole of Government’? What happened to ‘The government should ensure that all public spending decisions align with the net zero goal’? By suggesting a neat division between the CCC and the OEP, the Bill suggests policy advice will be watered down, when the Climate and Biodiversity Crisis covers both the path to net zero and protection of the environment.
4. The crudity of some policy advice
The Green Book Review says the Treasury Green Book has been scrutinized in the context of achieving ‘the net zero commitment and the 25-year Environment Plan’ (25YEP). In 2018 the Green Book was revised to include ‘how to value unmonetizable costs and benefits’. There is new guidance from DEFRA (the Department for the Environment, Food and Rural Affairs) known as ENCA (‘Enabling a Natural Capital Approach’). The ENCA Assets Databook lists eight habitat types. They include ‘Cities’ and ‘Water’. Villages are not mentioned. No form of countryside outside woodland is mentioned apart from ‘Enclosed farmland’.
This is worse than useless in evaluating the ancient countryside that the Arundel Bypass Grey route would devastate, with its villages, hedges, ditches, lone trees, marshland, wet meadows, ponds, watercourses, field margins, ‘flushed fen’ habitat, and rare species.
25YEP, DEFRA and ENCA seem likely to be just as useless in protecting our natural assets and reducing carbon emissions as the OEP with its MOU with the CCC.
How long will it take for the concrete wall to come down and for action to follow the words? And will it be in time to save the villages of Tortington, Binsted and Walberton, and the ‘extraordinary’ wildlife area around them, threatened with destruction or massive impact by the Arundel bypass Grey Route, which is about to go through its planning process?
Emma Tristram 11 Feb 2021
 ‘Getting the building blocks right’, Green Alliance, November 2020. https://www.green-alliance.org.uk/getting_the_building_blocks_right_report.php
 Green Book Review, Final Report, 24.11.20, https://www.gov.uk/government/publications/final-report-of-the-2020-green-book-review
 Natural Capital Committee, ‘Green Book Guidance’, November 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/937652/ncc-green-book-advice.pdf.
 JCB, maker of construction equipment, has given £10m to the Tory party and is the largest donor. Wikipedia shows it received a £600m bailout loan because of the Covid crisis, despite being in profit.