National networks national policy statement consultation nears close amid controversy

Some years after it was initially timetabled, the NPS for roads, railways and rail freight interchanges was finally published in draft in December and is known as the NPS for National Networks.  The draft can be found here.

Responses to the consultation are to be sent to the Department for Transport by next Wednesday, 26 February, which is also the deadline for written submissions to the Transport Select Committee of the House of Commons.

The draft has proven controversial, with a campaign by the Campaign for Better Transport (CBT), for example, encouraging responses to the consultation and claiming that 997 have been made so far.  Not mincing its words, CBT describe the NPS as 'a national disaster' and 'dangerous' for its alleged encouragement of road-building to meet the predicted increase of 42% in demand for road journeys between 2010 and 2040.  It slightly elides that point into 'plans for 40% more cars', and it is not clear if its case is 'there won't actually be a 40% increase in demand' or 'the government should not meet the 40% demand'.  The pre-filled out response email seems to suggest the former.

CBT don't like paragraph 3.4 either, where it says 'Increases in carbon emissions from a development should not therefore need to be considered by the Examining Authority and the Secretary of State'.  Echoes of long-term nuclear waste disposal not being a matter for examination of new nuclear power station applications.  The NPS does say in the next paragraph that the road-building the government expects to take place would result in less than 0.1% of the 'fourth carbon budget'. The fourth carbon budget is the amount allowed for in the period 2023-27.

CBT also don't like what it says about biodiversity and ecological issues.  It is true that the general approach is as in paragraph 5.28: 'The Secretary of State should refuse consent where harm to the habitats or species and their habitats would result, unless the benefits (including need) of the development clearly outweigh that harm', which could be quite a significant 'unless', but is this a change to existing policy?  NPSs were always supposed to be expressions of existing policy, but sometimes the existing policy hasn't been expressed very clearly so it's not always that easy to tell.

Less controversial but the subject of much discussion nonetheless, is that the draft NPS is not 'location-specific'.  In other words, unlike the Nuclear Energy and Waste Water NPSs, it doesn't say where the government thinks infrastructure should go.  You might think that where transport infrastructure actually is is something of a key feature, but then again the now adopted (or 'designated') Ports NPS managed to be unspecific about new or expanded port locations.

Although unable to attend them myself, I have heard that the NIPA meetings on the NNNPS have been fairly vociferous affairs.  This is somewhat ironic since the government decided not to hold any meetings itself, given that previous meetings during NPS consultation periods had been poorly attended.  That's not quite right - the energy and ports NPS meetings were quite well attended, but the hazardous waste and waste water ones were indeed, well, a waste.

What happens next?  On the general public consultation, things will go quiet until the government produce a response and revised NPS later in the year.  Parliamentary scruntiny will be a more public affair, though - the Transport Select Committee is likely to call witnesses and the House of Lords will debate the draft in one or more committee sessions.  All of this will of course be covered in future blog entries.