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A417 Missing Link

Received 31 August 2021
From Climate Emergency Policy and Planning (CEPP) (Climate Emergency Policy and Planning (CEPP) )


Dr Andrew Boswell, Climate Emergency Planning and Policy As an independent environmental consultant specialising in climate science, policy, and law, I object to the A417 Missing Link scheme: A. Table 14-17 of the Environmental Statement shows the scheme emitting over 900,000tCO2e of additional carbon emissions into the Climate Emergency era. B. The absence of cumulative, and short, medium and long-term, impact assessment of carbon emissions renders the Environmental Statement inadequate under the EIA Regs, and subject to EIA Reg 20. C. The applicant’s carbon assessment does not reduce operational carbon emissions over the 60-year appraisal period, as required by the government’s Transport Decarbonisation Plan (TDP) for ambitious quantifiable carbon reductions in transport at the local level. D. In the critical 4th carbon budget (2023-2027), an additional 96,302 tCO2e will be emitted, and approximately a further 37,000tCO2e will be emitted in 2028-2030. These additional emissions fall in the period leading up to the UK international commitment, via its NDC under the Paris Agreement, to reduce emissions by 68% by 2030, creating a serious risk against the UK delivering on its NDC commitment by 2030. E. No carbon assessment of the scheme has been made against the period 2038-2049 when the UK is required legally to achieve net-zero, but the scheme is modelled to generate an enduring high-level of carbon emissions. Scientists are clear that a net-negative world, with massive extraction of CO2 is required urgently well before 2050. See the recent report from Climate Crisis Advisory Group, chaired by Professor Sir David King, former UK Government's Chief Scientific Advisor commentary of the IPCC 6th Assessment report “The final warning bell” at [redacted]. F. No assessment of the scheme has been made against the 36-year period 2050-2085, post the UK 2050 net-zero target when the scheme is modelled to emit infinitely greater emissions than the Government and CCC’s implied budget for the post net-zero era. The applicant has provided no indication of how these additional carbon emissions would be mitigated. This has a clear material impact on the ability of the UK to contribute to the global endeavour to stabilise global heating at 1.5oC, and it does not comply with the UK obligations under the Paris Agreement. G. CEPP do not accept that only comparing carbon emissions from the scheme against carbon budgets for the entire UK economy is a credible assessment method. It is a deliberate tactic to “loose the signal in the noise”, and it is antithetical to good science. H. Carbon emissions should be tested locally, regionally and nationally against the UK obligations under the Paris agreement including the UK’s Nationally Determined Contribution (NDC), the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), the revised NPPF 152 planning requirement to “radical reductions of greenhouse gas emissions”, the statutory duty on Highways England under the Infrastructure Act 2015 section 5(2) to have regard for the environment, and relevant local authority Environmental Policies.