• Star letter to Secretary of State for Transport

    • Rt Hon Grant Shapps MP, Secretary of State for Transport

      Great Minster House, 33 Horseferry Road, London SW1P 4DR

      29th November 2020

      Dear Mr Shapps,

      Thank you for your department’s reply in regard to my letter on the 15th November, ref 319621. I would like to raise some additional points, and have some further questions based upon the information in your reply letter.

      In the letter it is stated that Highways England’s assessment work “clearly identified that the Grey (Option 5BV1) route as the best long-term solution”. Considering that just 7% of local residents agreed with this, meaning that 93% disagreed, I am wondering how it was seemingly a ‘cut and dry’ decision. The local stakeholders have clearly been seen as either unimportant, or plainly of the wrong opinion, and thus ignored by Highways England in their decision. Please can you explain how Highways England have been allowed to disregard the respondents to the consultation so flagrantly?

      To add up statistics in the Preferred Route Announcement Document (1), all of the offline bypasses Grey, Magenta, Amber, and Crimson, add up to a total of 34%, the total combined support for an online bypass, being beige or cyan, was 35%, which is a greater percentage than 34%, and ‘do nothing’ had 25% support. It is a civic participation outrage that these voices have been dismissed out of hand, and that one of the least popular routes has been chosen, especially when considering that environmental bodies, including Natural England, the Environment Agency, the Forestry Commission and Historic England had significant concerns particularly about the ‘offline’ options, of which Grey is one. The letter also states that one of the benefits of Grey is that it avoids The South Downs National Park, however, to refer to the ‘preferred route announcement’ again, The South Downs National Park Authority submitted a holding objection to all routes, including Grey.

      The letter also describes how in the future, we will be driving zero-emission vehicles, this is an inaccurate term, as advised by the Air Quality Expert Group (2). The increased road capacity as a result of the Grey route bypass would increase exhaust emissions until the much wider uptake of EVs, and then even they result in pollutants as detailed by the AQEG.

      Regarding modernisation of the transport network, which your letter states that the ‘Road to Zero’ project aims to achieve, the focus on roads and their capacity pressure seems very backward looking when considering that the House of Commons select committee on technology concluded that current ownership and usage model of personal vehicles is unsustainable (3). More road building could end up resulting in a positive feedback loop of more traffic as a result of induced demand, which was found to be occur and be significant in some situations by the Department for Transport itself in 2018 (4).

      If the UK is to limit its contribution to the climate crisis, and be in a position to meet the aspirational aim of the Paris Climate Agreement of a rise in temperatures of no more than 1.5 degrees, traffic will need to be reduced by 20%-60% depending upon the speed at which EVs become commonplace, and grid is powered by a greater proportion of clean electricity sources (5). This is echoed by the The Committee on Climate Change which set out in 2018 that the continued rise in road transport emissions highlights the urgent need for stronger policies to reduce growth in demand for travel (6), not increase capacity for road travel, as the A27 Arundel Bypass Grey route would do.

      In your letter you state that the A27 Arundel Bypass Grey route has been factored into the UK’s 5th climate budget. Unfortunately, we are currently off track to meet the 5th climate budget (7), so shouldn’t projects with high environmental and monetary cost be shelved, especially those such as the Grey route, which would include a vast amount of embodied energy, create capacity for higher emissions from the transport sector, and destroy a host of local ecosystems?

      Whilst the letter states that “the Government’s 25 Year Environment Plan sets a vision that will embed an ‘environmental net gain’ principle for development”, the A27 Arundel Bypass Grey route that will entail severe environmental loss, which cannot be mitigated, such as:

      • Severing wildlife corridors between the South Downs National Park, Binsted Woods, and foraging areas along the marshlands of the Binsted Rife (important environmental areas extend beyond the boundary of South Downs National Park and animals do not know where the border is).
      • Increasing noise, vibration, light and chemical pollution levels in vital ecological areas.
      • Carving up a precious and rare chalk stream environment.
      • Rendering valuable farmland unviable.

      How can these issues being overlooked result in an environmental net gain?

      Pertinently for the A27 Arundel Bypass development, it can be seen on the 2016 Department for Transport Road Use Statistics report (8) that in the Arundel area, the average number of large employment centres accessible by public transport within 45 minutes is ‘none or up to 1’, whereas the average accessible by car within 45 minutes is ‘up to 7’. This bolsters the case for investment to be made in public transport and active travel in the area, and raises the question of why instead, nearly half a billion pounds is being spent on a road. Would it not be more beneficial to place a higher focus on public transport and active travel development in Sussex, rather than expanding road capacity against strong and well founded objections?

      As you can see, there are still many issues that don’t stack up to a conclusive case for the Grey route, or indeed any offline by-pass.

      • Why are Highways England determined to push for the most expensive, most invasive, most destructive route, when it has been overwhelmingly rejected by a large majority of local people, who the road would most affect, either positively or negatively?
      • Why is the government focusing so closely on road building, ploughing £27bn into it (9), when research shows that it will worsen the climate crisis (which has only £12bn allocated), at a time that the government are claiming to aim to ‘build back greener’?
      • How can the ‘environmental net gain’ principle be taken seriously when projects such as the A27 Grey route are still being backed and pushed by government despite the abundant environmental disasters it would entail, which cannot be mitigated against?

      I would appreciate a thorough and considered response to the concerns that I have raised.


      Jack B., Walberton

      1. https://highwaysengland.citizenspace.com/he/a27-arundel-bypass-preferred-route-announcement/supporting_documents/GFD20_0090%20Arundel%20A27%20Bypass%20Consultation_PRA%20October%202020%20PRINT.pdf
      2. https://uk-air.defra.gov.uk/library/aqeg/zero-emission-vehicles
      3. https://road.cc/content/news/265747-private-car-ownership-unsustainable-warns-house-commons-committee?fbclid=IwAR1PbSX96Y3lY6f7ts34xZLADN8jmW_0xvpI7CaGgStuprrkSMqsZ9n1oks
      4. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/762976/latest-evidence-on-induced-travel-demand-an-evidence-review.pdf
      5. https://policy.friendsoftheearth.uk/insight/more-electric-cars
      6. https://www.theccc.org.uk/wp-content/uploads/2018/10/Lord-Deben-to-Chris-Grayling-Greg-Clark-on-Road-to-Zero.pdf
      7. https://www.theccc.org.uk/about/our-expertise/advice-on-reducing-the-uks-emissions/
      8. www.gov.uk/government/statistics/road-use-statistics-2016 
      9. https://www.bbc.co.uk/news/science-environment-55077760
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