Supporting Sustainable Growth

In this article I offer my review of the Draft National Policy Statement for National Networks. In doing so, I should point out that (continuing on from other roads related matters of late) my focus is on roads (rather than also considering rail). I should also warn you, this is quite a long article (over 5000 words). I’ve arranged it in four parts:

Part 1 – Making sense of what the NPS and the new version are all about

Part 2 – Weighing up alternatives

Part 3 - Appraisal of Sustainability

Part 4 – Ten outrages

Part 1 – Making sense of what the NPS and the new version are all about

If you are an NPS guru and deep inside the worlds of major scheme appraisals and Development Consent Order processes then you can probably jump over this section (or tell me what I’ve misunderstood).

Confused from the outset?

OK. Take a deep breath for this. I’m trying to get some clarity at the outset over what this is all about. It takes some rummaging around to get yourself familiarised (or at least it did for me).

What is it called, surely I can get that right?

When reviewing a significant new policy and planning document it’s reasonable to want to know what it is and what it is for. In this case, one has to start with knowing what it is called!

The December 2014 version (designated – i.e. published - in 2015) currently in force is called National Policy Statement for National Networks, on the cover. In the first sentence of the Introduction to this document it is called the National Networks National Policy Statement – abbreviated to NN NPS we are told, and then to NPS. For good measure, the announcement in July 2021 of the review of this version refers to it as the National policy statement (NPS) on national networks. Meanwhile the issuing of the draft revised version for consultation on 14 March 2023 uses the abbreviation NNNPS. Though the draft itself then uses the abbreviation NPS.

Maybe it’s the academic in me getting hung up on getting the name and abbreviation right. Anyway, from now on in this review of mine, I’m going to simply refer to it as the NPS, as seems common to do so.

Intended to speed up the process for approving major new infrastructure projects

It helps, I think, to appreciate that it is one of a series of twelve National Policy Statements NPSs) – which are described by the Planning Inspectorate. In other words, this particular NPS is for National Networks (national road and rail networks). NPSs exist because of the Planning Act 2008. This Act is intended to speed up the process for approving major new infrastructure projects (Nationally Significant Infrastructure Projects – NSIPs). The means of being able to achieve this speeding up is through the NPSs which are intended to set out the need for development and other policy deliberations. As noted on Wikipedia, “The National Policy Statements were intended to make the outcome more certain by following guidelines. This had clear benefits for applicants who invested in a wealth of resources in order to bring development consent into fruition and in financial matters”.

As the then Secretary of State for Transport, Grant Shapps, said in announcing the review of the NPS for National Networks: the NPS provides “a proper basis on which the Planning Inspectorate can examine, and the Secretary of State for Transport can make decisions on, applications for development consent.”

Just as an aside, when reference is made to ‘speeding up’, you may wish to note that for the biggest proposed investment in the second Road Investment Strategy (RIS2), the Lower Thames Crossing, the submission of evidence for the DCO examination I understand runs to over 60,000 pages. And you were starting to think this review was getting heavy going!

What’s an NSIP?

Oh, and what constitutes a Nationally Significant Infrastructure Project (NSIP)? Well, the draft NPS rather than telling us, points us to Part 3 of the Planning Act 2008. We’re told in Clause 14 that “In this Act “nationally significant infrastructure project” means a project which consists of any of the following….”. The list that follows includes “highway-related development”. Under this sub-clause heading are further details of what is in and out of scope for roads. At which point I got quite lost. I went back to Google and then found a document in the House of Commons Library called “Planning for Nationally Significant Infrastructure Projects”. In answer to the question ‘what are NSIPs’ it says they are “large scale developments (relating to energy, transport, water, or waste) which require a type of consent known as “development consent”.” In the case of roads, if National Highways has a major new road scheme, it must put forward an application to the Planning Inspectorate for a Development Consent Order. According to this DCO factsheet, “A Development Consent Order (“DCO”) application for consent to undertake a NSIP is made to the Planning Inspectorate who will consider the application and make a recommendation to the Secretary of State, who will decide on whether development consent should be granted for the proposed scheme.”

So when is a major scheme an NSIP? Quite often! The National Infrastructure Planning page from the Planning Inspectorate allow you in turn to go to a page which lists all NSIPs – allowing you to search for those for transport according to which stage they are at in the process.

In summary

Are you still there? Hope so.

So, here’s my attempt in plain-ish English to try and summarise. In England, when National Highways wants to take forward a major new road scheme, it needs to apply for and get a Development Consent Order (DCO) to be able to do so. This has to come from the Secretary of State for Transport (SoS) who is advised on their decision by the Planning Inspectorate (PINS) which will have considered the application and all related evidence thoroughly. National Highways, PINS and the SoS should be guided by what is said in the National Policy Statement (NPS) for National Networks. If this NPS has been followed then the outcome should be more certain, thereby making the effort involved worthwhile and – in theory – the process quicker. Since, as explained by Wikipedia, “The sustainability of the policy [NPS] has to be assessed beforehand to ensure compliance with environmental sustainability standards”, a DCO application should not fall foul on environmental grounds.

Here's my attempt at an even pithier summary. The UK Government gives many billions of pounds to National Highways every five years – according to a Road Investment Strategy - to spend on our trunk roads and motorways, including new schemes to change the road network that first require permission from the Government to go ahead. An important document called a National Policy Statement helps determine whether that permission is granted. Therefore, what is in that document can be considered fundamental to shaping our future road network and its use.

Further gearing up to reviewing the draft NPS

I have a few more considerations that seems important for setting the scene for reviewing this draft new NPS.

Not a National Transport Strategy

The NPS covers England. The Scottish Government and Welsh Government have national transport strategies. There is not a national transport strategy for England. Yeah, I know. The NPS may be a policy statement but it concerns itself with large scale transport investments on road (and rail); it is not a national transport strategy. It’s worth bearing that in mind if you read the NPS or read about it.

Why is there a new draft NPS?

The NPS was written nearly a decade ago. A lot has changed since then. In July 2021 an announcement was made for the NPS to be reviewed and revised. Quite important really – though the decision for the review was not readily forthcoming – read here about the High Court proceedings to challenge the initial refusal of the Secretary of State to review the NPS. The Government is currently in the process of preparing the next (third) Road Investment Strategy (for the period 2025-2030). Schemes that have been or are currently part of the second Road Investment Strategy (2020-2025) have been working against the 2015 NPS. They are still working against that NPS, in spite of how much has changed since 2015.

As the Government itself acknowledges (emphasis added) “The current National policy statement (NPS) on national networks, the government’s statement of strategic planning policy for major road and rail schemes, was written in 2014 – before the government’s legal commitment to net zero, the 10 point plan for a green industrial revolution, the new sixth carbon budget and most directly the new, more ambitious policies outlined in the transport decarbonisation plan.”

There is an urgent need for an updated NPS to be published and to be guiding major road scheme investments. There is also an imperative to get this revised version right.

Spot the difference

I must confess, I haven’t read the 2015 NPS cover to cover, have you? However, given the significance of the review and revision in process I might have expected (you know, in the interests of transparency and helping speed things up for all of us) to see a document up front that explained the key changes that are made in the revised draft, as well as the key features that remain from the 2015 version. No such luck. It was only after I had been through the draft NPS (and the Appraisal of Sustainability document – more later) and then wandered into the consultation page that I then found a section labelled ‘Draft NNNPS summary’ which claimed to “outline the changes made to NNNPS chapters as part of the review process and the rationale for making them”. Not an untrue claim but blink and you’ll miss it, it’s so short. So, since I don’t have time to compare and contrast the old and the draft revised NPS my review is based on the new NPS itself.

Part 2 – Weighing up alternatives

In this part of the review – which in some ways is an extension of the first part – I consider the fact that the NPS itself is not really concerned with consideration of alternative options when it comes to major infrastructure schemes. I go on to examine how it seems we can treat the NPS itself as something for which there had been consideration of alternative options.

Consideration of alternatives

It’s easy to keep falling into the trap when reading the NPS of thinking ‘but what about the consideration of alternatives when it comes to arguing for new infrastructure investment?”. As is made clear in the document early on “The NPS provides policy and guidance on matters such as good scheme design, transport decarbonisation, avoidance and mitigation of environmental effects and environmental enhancement.” Conspicuous by its absence is ‘consideration of alternatives’. The document goes on to explain that “both the National Planning Policy Framework and the NPS seek to achieve sustainable development, by ensuring the right infrastructure is delivered in the right place and at the right time to support sustainable growth”. ‘Supporting sustainable growth through infrastructure investment’ could have been the subtitle of the NPS. Since it is not a national transport strategy, the NPS is not about guidance for the bigger picture that might include other ways of supporting sustainable growth. Remarkable in a service-based economy such as the UK that nothing is said about the growing role of digital connectivity and accessibility in working and social lives (as alternative and/or complementary means to road networks supporting growth). The only mention of digital is as it pertains to the road network and its use directly.

Only at page 40 in the 105 page document do we get to a heading ‘Alternatives’. However, we are advised that “The Examining Authority and the Secretary of State should satisfy themselves that the options appraisal process has been undertaken” and “Where an options appraisal process has been undertaken, it should not be necessary to consider alternatives”. This, I recall, is in line with the 2015 NPS. In other words, attention is mainly on whether the preferred road scheme is acceptable or not.

The NPS states that “improved connectivity and accessibility, both locally and inter-regionally, facilitates deeper labour markets giving individuals better access to jobs and education, and businesses better access to skills”. Yes indeed. Oh, hang on, you mean ‘improved connectivity and accessibility through road (and rail) schemes’ because improvement could not instead come from spatial proximity and digital connectivity – in short it must come from physical motorised mobility.

Alternatives to the NPS

Reference is made in the draft NPS to alternatives having been considered. I was scratching my head over this to start with – alternatives to the NPS? To make sense of this you have to step away from the NPS and read the Appraisal of Sustainability document (I’ll come to that in the next Part of the review). In this 26-page document it explains that (emphasis added):

“DfT consider that there are three reasonable approaches to development of the NNNPS. These reasonable approaches are:

• An approach which delivers balanced national priorities (as selected by the DfT as the basis of the draft NNNPS);
• An approach which prioritises environmental sustainability benefits (Alternative 1); and
• An approach which prioritises wider economic and levelling up benefits (Alternative 2).”

This document goes on to say “In the light of updated travel demand forecasts and the policy framework provided by the Transport Decarbonisation Plan, it was not considered reasonable to include a ‘do nothing scenario’ as an alternative.”

OK – so don’t be confused by the use of the term ‘scenario’ to refer to (as far as I can gather) the option of not making any changes to the existing NPS, i.e. a ‘do nothing scenario’. By all accounts then ‘options’ for the NPS are also being called ‘scenarios’ (not with the intention to confuse of course!).

So, it would appear that part of the process of getting to the revised NPS is to have considered three substantive alternatives to not changing it at all. With little insight (other than brief consideration in the six-page Appendix 1 of the Appraisal of Sustainability), two alternative courses the NPS could have taken would have been to prioritise environment over economy or economy over environment (and with levelling up into the mix). Instead, we have an NPS which is referred to as ‘delivering balanced national priorities’ which in turn has been translated into ‘supporting sustainable growth’. However, since the NPS only concerns major road (and rail) schemes, balancing national priorities of economy and environment can only be achieved in NPS terms through new infrastructure. This in turn suggests that for the most part the reason for delivering new infrastructure will be for economic reasons and then with a hope that this is not to the detriment of environmental sustainability.

So let’s move onto that next.

Part 3 – Appraisal of Sustainability

An Appraisal of Sustainability has been conducted on the draft NPS (as indeed it was for the 2015 NPS). Indeed as the current Appraisal of Sustainability document explains “The Planning Act 2008 requires that an AoS is carried out before an NPS can be designated”.

All in good order

The headline conclusion of this exercise (for both the current NPS draft, and the 2015 designated NPS) is that “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS.” As I understand it then, if a scheme promoter follows the NPS they can be confident that their major infrastructure scheme will be able not only to deliver growth but to do so sustainably. Of course, devil will be in the detail within a Development Consent Order process but for the NPS itself, this is presumably intended to give confidence that with the right guardrails in place in terms of scheme design (as set out in the NPS), major road schemes need not be environmentally problematic.

So, this Appraisal of Sustainability (AoS) seems quite important to the revision to the NPS – foundational one might say since the announcement of the need for the review emphasised the changes in relation to the decarbonisation agenda not least.

Expert judgement and precautionary

We are told of the AoS: “The assessment has been carried out and reported using an expert, judgement-led qualitative assessment. A ‘precautionary approach’ is taken, especially with qualitative judgements and judgements are documented in the assessment tables.”

OK – so a lot rests on experts and their judgement. That to me immediately begs the question “so who were the experts involved?” And indeed “was it a diverse group of experts from a broad range of disciplinary perspectives and backgrounds?” We are not told, unless this detail is tucked away in the appendices somewhere though I didn’t spot it. It certainly didn’t seem important enough to include in the main document (all 26 pages of it). Stage D of the process followed involves consultation, which I assume is something different – this involved four Statutory Environmental Bodies, and four ‘other consultee’ responses; it also involved several stakeholder workshops.

So what of the precautionary approach? Well, first of all the qualitative assessment culminates in a score ranging from ‘significant positive’ (++) to ‘significant negative’ (--) passing through ‘neutral’ (0) and ‘uncertain’ (?).

Notably, “uncertain effects will be treated as significant negative effects and mitigation and monitoring recommended”. The main body of the AoS has very little in the way of results from the assessment but when these do appear, they highlight the following. Greenhouse Gas and Air Emissions potential effects of the NPS are judged to be uncertain. Meanwhile Economic Impacts, User Experience and Safety are all judged to have significant positive potential effects. It is judged that there is an “uncertain effect on greenhouse gas emissions from road users due to investment in road infrastructure (Operation)”. Mitigation recommended is that “All new SRN [schemes]…could be required to ensure they can be delivered without impacting on ability to meet net zero GHG emissions at a network/investment programme level”.

So, if I understand correctly, the NPS should deliver balanced national priorities in support of sustainable growth for which “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS”, even though there is uncertainty over greenhouse gas emissions which ‘could’ not ‘must’ require NSIPs be delivered without impacting on ability to meet net zero (at a network/investment programme level). Forgive me but either I have not followed the nuances and details of the commentary or this sounds distinctly unconvincing as a precautionary approach.

Digging deeper on greenhouse gas emissions

More detail regarding the assessment requires the reader to go into the appendices to the AoS. In terms of greenhouse gas emissions from road network users this is tucked away in Appendix 3, page 2. It’s perhaps worth drawing this text out in full here (emphasis added):

“Explanation of Assessment

Draft NNNPS: The Draft NNNPS supports a significant package of improvements and enhancements across the road networks, and these could result in substantial increases in greenhouse gas emissions due to increased use of the network, and facilitation of further growth. The Draft NNNPS acknowledges that operational GHG emissions from some types of national network infrastructure cannot be totally avoided. National Highways’ Evaluation Insight Paper (2019) analyses 85 scheme evaluations, relating to all major schemes opening between 2002-2014. The report states “The majority of major schemes resulted in an increase in carbon emissions in the opening year. Changes in carbon emissions were typically due to changes in traffic volumes, journey distances, vehicle composition and/or speed of traffic”. The Draft NNNPS states that a net increase in operational GHG emissions is not, of itself, reason to prohibit the consenting of national network projects or to impose more restrictions on them in the planning policy framework, and that The Secretary of State does not, therefore need to assess individual applications for planning consent against operational carbon emissions and their contribution to carbon budgets, net zero and the UK's NDC.

However, the Draft NNNPS includes several requirements on applicants to drive down emissions at every stage of development including during operation. In addition, the Government has published the Decarbonising Transport Plan, and the Climate Change Committee has indicated that this is a reasonably comprehensive strategy for transitioning to a system in which almost all journeys are zero-carbon.

There is uncertainty over several factors relating to decarbonising road transport, including of the rate of the transition to low emission vehicles and management of demand. Overall, this effect is considered uncertain. There could be an increase in emissions, but there is uncertainty in the assessment due to lack of modelled evidence and uncertainties around the effectiveness of carbon reduction measures.”

Nothing to see here?

This information in brought forwards into the NPS itself. I assume user emissions are being treated as part of operational emissions as opposed to being a separate category. So let me get this straight, significant improvements and enhancements to the road network could result in substantial increases in greenhouse gas emissions due to increased use of the network, and facilitation of further growth, and yet “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS” and “The Secretary of State does not, therefore need to assess individual applications for planning consent against operational carbon emissions”. In the NPS it also notes that “in the case of road projects while the developer can estimate the likely emissions from road traffic, it is not solely responsible for controlling them”. I’m sure I’d make better sense of the meaning of all of this if I was a lawyer. However, the overriding impression I get is “do what you can but nothing to see here folks”.

Part 4 – Ten outrages

The rest of my review I’ve characterised as ‘ten outrages’. As I read through the NPS, certain moments of (minor) outrage or incredulity arose for me along the way. Some are (probably) minor. Some may be more serious.

Number one - a Freudian slip?

The DfT’s ‘second cycling and walking investment strategy’ (updated 10 March 2023) reiterates an earlier stated political ambition that “50% of all journeys in towns and cities should be walked or cycled by 2030”. However, in the NPS it states that “It is a government commitment for more than half of personal journeys in our towns and cities to be made by active travel by 2030s.” Spot the difference? A careless little ‘s’ at the end not picked up in proof reading, or a carefully placed ‘s’ to subtly soften the target and buy another decade of time?

Number two - publication of the new guidance for LTPs is imminent

I understand it is still the official line that the new guidance for Local Transport Plans is imminent. Yet in the draft NPS it makes reference to ‘Updates to Local Transport Plan Guidance’ as if already available to see. Maybe I’ll let this one slip given the draft status IF indeed the publication of the (draft) new guidance is indeed imminent.

Number three - we’ve almost done transport decarbonisation?

The NPS states “Government’s Transport Decarbonisation Plan demonstrates how we will deliver transport's contribution to emissions reductions in line with net zero, much of which has already been delivered or is in progress.” I’ll give you a similar phrase I just made up which is also true “I have a plan to colonise Mars which is in progress”. The TDP may demonstrate how we could deliver, it doesn’t definitively demonstrate how we will deliver. Saying ‘much of which is already in progress’ is largely meaningless unless we know how much progress has been made and to what effect.

Number four – tailpipe emissions are projected to fall significantly

We’re told “The National Road Traffic Projections 2022 provide a strong analytical basis for understanding the potential evolution of traffic growth, congestion, and emissions under a wide range of plausible future scenarios. In all scenarios carbon dioxide tailpipe emissions are projected to fall significantly due to the anticipated uptake of EVs.” Let’s put aside questions over whether we all agree on the first point (particularly on whether the set of scenarios is entirely appropriate). Yes, it’s true that tailpipe emissions go down in all scenarios. However, in five of the eight scenarios (including the ‘core’ scenario), CO2 emissions from road transport remain well above 40 Megatons per year by 2050. Hardly grounds for celebration. But no need to worry it seems.

Number five – increase in demand on the SRN is inevitable

We are told that “There has been a steady growth in the population of Great Britain over the last 20 years and the population is projected to increase further by 4% between 2025 and 2060. Continuing growth in the economy and the population will increase the demands placed upon the SRN. Without investment and infrastructure interventions, increasing demand will lead to decreasing network performance for users, for example, poorer journey time reliability, which comes with economic and social costs.” Note the definitive ‘will’. No room for ‘could potentially’ or ‘unless other measures are put in place, will likely’. Simply ‘will’. A bald statement that if economic prosperity is needed, you have to invest in infrastructure. Never mind the fact that for the devolved nations there are targets for absolute reduction in road traffic levels which suggests these are possible futures. So – we can’t say ‘will’ to increasing demand in Scotland and Wales, but we can for England? Yet even for England the NPS lists “a range of measures that can be employed to make the best use of all road capacity (not just the SRN) which may impact upon demand for the SRN”. These don’t expressly include reducing the need to travel (on the SRN) but, in any case, they suggest increase in demand is not a foregone conclusion.

Number six – believe in Elon Musk?

The NPS states that: “Evidence that development on the network leads to induced demand is limited” and points to a WSP/RAND report (a 2018 report intended as an update to the 1994 SACTRA report).  The report (a review of 25 papers) says “There is little evidence that extreme levels of induced demand would therefore occur on the Strategic Road Network”. It also points to a “wide range of elasticities” and a “wide range of percentage changes in traffic flows”. The report noted that “The evidence reviewed in this study supports the findings of the SACTRA (1994) report that induced traffic does exist, though its size and significance is likely to vary in different circumstances”. My minor outrage was that this statement in the NPS came immediately after being told demand on the SRN will increase because of population and economic growth. It seemed as if the message was ‘demand will increase, we need more capacity unless we want to stifle growth, and we needn’t be concerned too much about induced demand from more capacity’.

Number seven – no need to get your ‘facts’ about uncertainty correct

The latest National Road Traffic Projections report states “From 2025, traffic is projected to grow between 8% and 54% by 2060”. This only came out in December 2022. However, in the NPS it states “all scenarios have projected a growth of traffic between 2025 and 2060 for England and Wales, with forecasts ranging from 12% to 54%”. The next sentence, however, almost invites us to not worry too much about the incorrect range anyway because “The Core scenario, which represents a world in which deviation from historic trends in the key drivers of demand and current Government policies is minimal, projects a 22% increase in traffic between 2025 and 2060”. Even though DfT has an uncertainty toolkit and even though DfT emphasises how uncertain future road traffic demand is, we can’t resist being drawn to ‘core’ for a source of comfort it seems.

Number eight – either we’re uncertain or we’re not

Still fixating over the core scenario (the most likely source of truth for some it seems?), we delve into the madness of false precision in some sort of desperate attempt to give a sense of authority and confidence when wanting to make a point about user experience. Here we go: “Increases in the number of seconds of time lost due to congestion on motorways also varies under the Core scenario; from 81.8% in one region to 215.5% in another”. Give. Me. Strength. Reporting an increase in seconds of lost time to four significant figures of precision when looking out over a 35-year period into the future to 2060. Not only that, giving us a range of what I would refer to as ‘between roughly 80 and 220%’ but still being unable to resist the false precision at either end of the range. Quite remarkable. And to add insult to injury, the very next paragraph starts with “These projections are not definitive predictions of what will happen in the future and are not a predictor of the level of expansion required on the national road network”. Not definitive predictions but please do be as falsely precise as you’d like!!

Number nine – long live predict and provide?

The NPS recognises that the Transport Decarbonisation Plan committed to moving away from Predict and Provide towards Decide and Provide. However, it is at pains, it seems, to point out that “vary challenges will be presented at certain sites” such that a vision-led decide and provide approach “will not always offset the need to increase capacity”. It goes on to point out that “In some cases, to meet the need set out in this NPS, it will not be sufficient to simply expand capacity on the existing network [with new and improved junctions and slip roads, dualling of single carriageways, and additional lanes on existing dual carriageways]. In those circumstances new road alignments and corresponding links, including alignments which cross a river or estuary, may be needed to support increased capacity and connectivity”. More boldly, the NPS elsewhere states that (emphasis added) “They [the national road traffic projections] do, however, demonstrate that continued absolute traffic growth is likely under all scenarios, and therefore enhancements on the national road network will be necessary in order to ensure the national road network operates effectively in the face of growing demand.” There you have it – long live predict and provide. England is different to Wales.

Number ten – mention biodiversity net gain but not too much

I reached a section in the NPS on page 41 titled ‘Biodiversity Net Gain’. Ah, I thought, perhaps COP15 has worked its magic and we are finally moving past ‘minimising biodiversity loss’. No mention of COP15, but in the half page, four paragraph length of this section the following is included. “Biodiversity net gain is an approach to development that delivers measurable improvements for biodiversity by creating or enhancing habitats in association with developments. Applicants should therefore not just look to mitigate direct harms, but also identify and deliver appropriate opportunities for nature recovery and wider environmental opportunities for enhancements by providing net gains for biodiversity.” (Biodiversity is returned to later in the NPS on page 59). I’m not sure if this is tenth in my list of outrages or the start of a list of encouragements. My concern, however, is that there is no room, it would appear, to entertain a Nationally Significant Infrastructure Project that is primarily an investment in achieving biodiversity net gain, as opposed to it being (still?) an (aspirational?) by-product of new infrastructure schemes. Mention is made of a ‘Biodiversity Gain Statement’ in the NPS three times but without it being further explained. My understanding from reading elsewhere is that the Environment Act 2021 makes Biodiversity Net Gain mandatory in England and “To achieve biodiversity net gain, a development must show evidence that a development will increase the biodiversity value of a site by at least 10%”. Let’s hope National Highways is not just banking on planting more trees for this based on the reported recent A14 experience where “National Highways planted 850,000 saplings as part of the A14 upgrade, but an internal review seen by Sky News revealed that three-quarters of them have died”.

Conclusion

I’m not convinced by this revised NPS – I see multiple areas for challenge, and strong signals of the ‘old school’ philosophy of predict and provide. I’m really unclear about how a conclusion can be reached that “The Appraisal of Sustainability found no significant adverse effects of the policy set out in this NPS”. But then I’ve only been (trying to be) a transport professional for about three decades so perhaps the mists will clear when I have more knowledge and experience under my belt.

It has taken the best part of two years for this NPS review to result in the draft now available for consultation. I imagine countless person months of effort have gone into it. I’ve spent the best part of two days trying to dig into it. I’ve not been commissioned to do that.

Major scheme promoters with deep pockets are able to produce much material that requires a skilled eye to make sense of and unpick, only for those wishing to scrutinise having to do so on a shoestring. Similarly, I feel as though the invitation for people and organisations to respond to the consultation on this draft NPS has the consultees for the most part at a disadvantage in terms of time and resource at their disposal. Hopefully the lawyers out there can dig deeper.