The Transport Action Network (TAN)
Representative introduced himself and stated that TAN were a
national organisation that worked to support local communities who
would be affected by national road schemes, and had been in
operation for two years. He stated that in March 2020 the
government budget had committed to Road Investment Strategy 2
(RIS2), but TAN had challenged this decision on climate grounds and
carbon emissions. He explained that this had been heard in the High
Court in June who had ruled in favour of the government, but TAN
had applied to appeal this decision in the Court of Appeals, and
would be hearing next week if this had been accepted. He explained
in recent years, and particularly since COP26 in Glasgow, the UK
had been more aware of climate change and the effect of road
building on the climate. He stated that this year the UK had
committed to a carbon emission cap as part of the Paris Agreement,
and had agreed to reduce carbon emissions by 68% of 1990 levels by
2030. The TAN Representative explained that the sixth Carbon Budget
had been agreed in June which outlined the acceptable levels of
carbon emissions between 2033-37, and
was much stricter than the previous fifth Carbon Budget. He stated
that NH would compare the scheme’s emissions against the
Carbon Budget, but TAN had raised issues with how the emissions
levels were applied in this instance. He added that the budget for
RIS2 had decreased from £27bn to £24bn due delays with
the LTC, and therefore LTC funding could be pushed into RIS3 in
The TAN Representative explained that recently the government had made the Environment Bill into a law, which instituted new air quality limits. He added that in September 2020 the World Health Organisation (WHO) had also reduced their maximum emission guidelines for PM2.5 to 5mg per cubic metre. He explained that UK limits on PM2.5 were currently 25mg per cubic metre, which was five times the WHO limit. He stated that TAN and other organisations were lobbying the government to enshrine WHO limits on PM2.5 as the UK limit. He added that WHO had also recently updated the maximum emissions guidelines on nitrogen dioxide to 10mg per cubic metres, compared to the current UK limits of 40mg per cubic metres. He explained that WHO had updated these guidelines based on evidence and facts, but had admitted that there were no safe levels of these emissions. He clarified that WHO had not yet updated their guidance regarding other pollutants, but were working to develop maximum emissions guidance for these pollutants too. He stated that these guidelines would add weight to communities’ arguments regarding pollutants, particularly the fact that there were no safe levels of pollutants.
The TAN Representative added that the Business Department had updated their values for emissions in September, and these had been adopted by the Department for Transport, which provided the official guidance for National Highways (NH). He explained that these emissions values assessed the economic value of carbon emissions, and had increased the carbon cost by ten times. He stated that currently the carbon cost for constructing a road that emitted 2mn tonnes of carbon dioxide, would have an economic cost of £0.5bn. He summarised and stated that the landscape for NH submitting their scheme was changing as the UK government and people became more aware of the impact on climate change of road building. He stated that people were working hard to reduce carbon emissions and NH would have to prove their carbon emissions levels during examination phase. He stated that TAN were working closely with the Thames Crossing Action Group and others to monitor the work of the LTC closely, as it would be the biggest road programme in a generation and would be significant to the people of Thurrock and the wider communities.
Councillor Muldowney asked how the target to reduce carbon emissions by 68% by 2030 would relate to the LTC scheme. The TAN Representative replied that there was a Climate Change Committee that set the Carbon Budget on a yearly basis to ensure the UK would hit the target of net zero emissions by 2050. He stated that the Carbon Budget reduced the allowed carbon emissions every five years and ensured that the UK were meeting its targets set out in the Climate Change Act. He explained that NH had to meet emissions targets outlined in the Carbon Budget, and as the scheme was so significant it would compare its proposed emissions to the UK total allowed. He clarified that the 68% reduction by 2030 was much stricter than any Carbon Budget that had come before, and although the LTC scheme emissions were small in comparison to the UK total, the government had to add all road schemes and other additional areas of emissions together to ensure it remained within the Carbon Budget. He felt that even though the LTC scheme would be a small percentage of the total UK Carbon Budget, it was moving in the wrong direction by increasing road capacity and therefore increasing emissions. Councillor Muldowney agreed that the LTC scheme was at odds with the UK’s carbon emissions goal. She stated that the government were planning to go out to consultation regarding PM2.5 levels, before the government could commit to new targets in October 2022. She asked if this could affect the DCO submission for the LTC scheme, as if the WHO guidelines were agreed then the LTC scheme would fail. She asked that if the LTC scheme did not meet WHO guidelines, would there be a system of legal address for Thurrock to oppose the scheme on these grounds. The TAN Representative replied that it would depend on the legal limits of PM2.5 set by the government, who were currently resisting adopting WHO limits. He stated that TAN and other groups were lobbying the government to accept WHO PM2.5 limits. He felt that if the LTC did not meet limits on PM2.5 then Thurrock and other local authorities would have a case against the scheme, although this might not stop the scheme altogether. Councillor Muldowney highlighted that the proposed route would come within 200 yards of a school, a special school, and a care home, and felt that the route would damage the health of local residents due to pollutants and particulate matter. She felt disappointed that NH had not provided an update of the Health Impact Assessment. The Interim Assistant Director Regeneration and Place Delivery replied that Thurrock Council were in discussion with NH regarding all of the points that TAN had raised, including the claim from NH that emissions from the LTC would be insignificant. He stated that the LTC would increase traffic across the Thames by approximately 50% which would increase emissions significantly for local residents and the UK as a whole. He stated that the Council continued to seek data from NH regarding noise, health and air quality, and were also asking for access to the air quality modelling data from NH.
The Resident Representative asked if emissions levels would be different during construction and route operation. He asked if both of these would fail PM2.5 guidelines if adopted by the government. The TAN Representative replied that significant emissions would be released during both construction and operation. He explained that emissions during construction would include land clearing, tree felling, earth and spoil and moving, and steel and concrete emissions. He stated that NH were seeking to dump spoil and earth near the tunnel entrance which would reduce carbon emissions, but emissions would still increase overall as the majority of HGVs and dumper trucks currently run on diesel. He moved on and stated that once the scheme was opened the majority of emissions would be from users, and local authorities would need to compare current emissions levels to emissions levels once the route had been opened. He stated that he was confident emissions would increase as traffic would increase substantially. He stated that TAN were currently undertaking assessments into the accuracy of the NH assessment regarding the proposed 2 million tonnes of carbon emissions. Councillor Byrne asked for clarification regarding what elements were included in the carbon emissions data. The TAN Representative replied that all elements, such as tree felling and steel production were included in the carbon emissions data, and NH predicted that this would be 2mn tonnes of carbon produced during construction. The Interim Assistant Director Regeneration and Place Delivery added that the figure for carbon emission during route operation should also include the increased traffic generated across the wider local road network, for example on the A13 and A130.
Councillor Muldowney stated that emissions from cars was heavily regulated, but non-exhaust emissions such as from brakes and tyres remained relatively unregulated. She added that electric vehicles produced more non-exhaust emissions as they were heavier because of the battery, and therefore the tyres on these cars wore down more quickly. She asked if these pollutants and emissions had been taken into consideration. The Interim Assistant Director Regeneration and Place Delivery replied that it would take decades for the majority of cars on the road to become electric, even with the government’s ban on the sale of petrol and diesel cars in 2030, unless there were additional government interventions. He stated that this was compounded by the fact that HGVs and LGVs were not yet making significant moves to electric due to their size and amount of energy needed. He stated that the Council had asked NH to release their emissions and air quality data, which they still had not done, so the team did not know if these non-exhaust emissions had been factored into their data. Councillor Chukwu asked what additional measures were being undertaken to ensure the government met its target to reduce emissions by 68% by 2030. The TAN Representative replied that the UK needed to reduce its overall traffic levels to meet this target, which undermined the need for new roadbuilding projects. He stated that the majority of cars on the road still used petrol and diesel, including HGVs and LGVs. He highlighted that Wales and Scotland were working to reduce traffic levels by reducing the number of miles that cars drove and reducing the number of personal journeys that people made. He summarised and felt that NH needed to implement strategies regarding demand management rather than increasing traffic through road building.
The TAN Representative left the meeting at 6.47pm.