ASLEF Evidence Submission – Transport Select Committee - National Networks National Policy Statement
The Transport Select Committee was carrying out an inquiry into the draft revised National Networks National Policy Statement (NNNPS). The NNNPS outlines the Government's strategic planning policy for major road and rail schemes, providing guidance to applicants in preparing and the Secretary of State in determining applications for Development Consent Orders for national networks infrastructure projects.
the NNNPS was last set in 2015 and the Government stated that it would review it to reflect the net zero commitments made by the Government since 2015. Below is ASLEF's evidence submission.
ASLEF Evidence Submission – Transport Select Committee - National Networks National Policy Statement
- The Associated Society of Locomotive Engineers and Firemen (ASLEF) is the UK’s largest train driver’s union representing over 21,000 members in train operating companies, freight companies as well as London Underground and light rail systems.
- As a rail union we will focus mainly on the impact the draft has on the rail network, its development, maintenance and integration. We will work through some of the questions below. We do however welcome the increased focus on the environment and the need for integrated networks which encourage a modal shift and grow rail freight as these will be needed to tackle the ongoing climate crisis.
Whether and in what ways the draft revised NNNPS is likely to be more effective than the current version, and whether opportunities to further improve have been missed;
- In the current draft there is a greater focus on the need for the National Networks to be better integrated and assessed in terms of how they interact with each other. This focus also looks at how future developments can improve this to the benefit of the UK as a whole by tackling transport emissions through the integration of the rail network to promote a modal shift from private motor vehicle and HGVs to passenger rail and rail freight. This may mean that the new NPS is more effective in delivering national networks that work for England / the UK longer term as the planning and assessment of projects factor in all parts of the network as well as how the project could impact on the UKs greenhouse gas emissions and achieving net zero by 2050.
- The updated language to factor in the growing climate crisis should ensure that the draft is more effective in delivering new developments that truly are to the benefit of the environment as well as the economy and the public through increased access to other parts of the UK via the upgraded networks.
- A greater focus on the need for resilience on the network is also welcomed. This has been fleshed out from the 2015 statement, mainly due to the reality that we are facing with the current impacts being felt by climate change.
- The development of the considerations to be made regarding accessibility are also welcome and should ensure that developments are designed and delivered with accessibility in mind from the outset. The previous statement did not go in to as much detail on how to this should be considered or assessed.
- We do however have concerns around the use of ‘customer’ needs rather than ‘passenger’ needs in the statement. The previous statement did not mention customers and we believe that the passengers on the rail network should be seen as passengers using a public transport network and not customers. This change of thinking can help to ensure that proposals are delivered with the intention of providing the best rail network for the public rather than a network that is focused more on profit than the needs of the public.
How effectively the draft revised NNNPS will allow the Government to deliver nationally significant infrastructure projects while also allowing for proper scrutiny of proposed projects;
- The current draft still ensures that there is scrutiny through a requirement on applicants to consult the relevant authorities when assessing the impacts of their proposals and as stated in the draft, it should include agreement on alignment to policies outlined in existing or emerging local transport plans. This ensures that the proposals work with the current network and should develop the integration of the networks.
- Applicants must still demonstrate that their proposals are in the public interest and be assessed through the proper process which considers all of the possible environmental, transport and economic impacts of the proposals.
- Whilst there are further assessments required around the environmental impact of proposals the NPS still creates a framework which will enable the Government to deliver nationally significant infrastructure projects due to the draft outlining the importance of assessing proposals for their economic, transport network and environmental benefits.
How effectively the draft revised NNNPS will prevent delays to obtaining Development Consent Orders;
- There should be less of a focus on preventing delay in obtaining development consent orders as we do not want to create a situation where any assessment is not properly carried out and rushed to enable a proposal to obtain development consent.
The validity of the draft revised NNNPS’s Statement of Need for the development of National Networks, including a) road and b) rail, including Strategic Rail Freight Interchanges;
- Focusing on the need for development we hold concerns that there has been a change in tone from 2015 with regards to the rail network. Previously the statement highlighted the importance of investing in, growing and maintaining the rail network including the need for a programme of rail electrification, we have seen slow progress on electrification and disappointing cuts to rail projects inclusive of Northern Power House Rail and HS2 despite 2015’s statement outlining the need and importance of new high speed rail.
- We know from Oxford Economics’ study that for every £1 of activity on the railway £2.50 of income is generated elsewhere in the economy so we are disappointed to see the constant mentions of financial sustainability in the draft NPS section on ‘policy for addressing need of the national rail network’. We are worried this can be used to stifle much needed developments of the rail network. We have seen underfunding of the rail network and a lack of willingness to properly invest in the rail network to ensure that it stays up to date and is fit for the future. With these failings we have recently seen a leak from Network Rail highlight that there are concerns around the level of funding in CP7 and whether this is adequate to meet maintenance needs on the network. We are concerned that the frequent use of ‘financial sustainability’ could push for a rail network that is hyper focused on profit at the expense of the public and lead to continued underfunding which ultimately holds back the rail network the UK economy and slows down the government’s ability to be net zero by 2050.
- We assume this use of language is as a result of recent unrest among parts of the Conservative party due to the spiralling costs of HS2. Recent cuts to the proposed route of HS2, citing costs, have also shown that if the plans were delivered as originally planned the spiralling costs could have been avoided, further to this, the recent cuts will also end up increasing costs and lead to job losses so we would not want the poor management of HS2 (which is not covered by the NPS) to so severely impact on the language of the statement and stifle investment in the rail network.
How effectively the draft revised NNNPS supports the ambition to achieve Net Zero by 2050;
- The draft NPS has a much greater focus on the environmental impact of any proposals and it also highlights the need to grow active travel alongside public transport to encourage a modal shift to help the UK achieve Net Zero. The increased focus on the environment and the need to invest in the rail network for both passengers and freight should be effective in helping the government achieve its net zero target.
- Transport is the sector with the highest greenhouse gas emissions, mainly due to private motor vehicle use, as such a modal shift is needed to change behaviours and attitudes toward transport to help achieve net zero. We cannot wait for and rely on electric motor vehicles as these will still bring environmental cost with production of the vehicle and in particular the battery coupled with the need to recycle a high volume of batteries. To this end the added language around financial sustainability under the rail section does throw some doubt on how effective the NPS will be in achieving net zero. This language could inadvertently discourage the needed investment in our rail network, and this would severely impact on the UK achieving net zero as a truly integrated rail network will provide passengers and businesses green routes to travel and move goods around the UK, to achieve this the adequate investment will be needed which could be construed as financially unsustainable if not modelled correctly.
How effectively the draft revised NNNPS supports levelling-up and growth;
- Again the caution around financial sustainability on the rail network and the use of ‘customers’ causes us some concerns around the draft NPS’ ability to support levelling up and growth. Levelling up is supposed to be about ensuring that regions and communities are not left behind and all parts of the UK are able to prosper, if the statement throws caution on needed investment in the rail network this could further harm left behind areas, especially if, for example, people living in regional areas are seen as customers rather than passengers this could have an impact on potential financial benefits of proposals.
- The inclusion of socio-economic to chapter five should help to support levelling up and growth as proposals would be able to demonstrate how they can level up communities and encourage growth through increasing the connectivity of the national networks.
The effectiveness of the assessment framework that underpins the general policies and considerations set out in Chapter Four of the draft revised NNNPS;
- The framework has a detailed outline of the environmental impacts which should be effective in assessing proposals. The business case, local transport model and wider strategies sections should ensure that proposals build on and integrate the networks.
- We welcome the continued commitment from the government to ensure that any rail developments are carried out to meet the required safety standards which are necessary to ensure the operation of a rail network that is safe for passengers, businesses and the workforce.
How effectively the draft revised NNNPS provides a framework for assessing the general impacts of nationally significant infrastructure projects, as set out in Chapter Five;
- By expanding chapter five the NPS should provide a more effective framework for assessing the general impacts of nationally significant infrastructure projects. There is now a greater push for applicants to engage with relevant and statutory bodies and on assessing the environmental impacts of proposals. This should be effective in ensuring that new proposals help the UK reach net zero by 2050 and also build a network that utilises nature based solutions to help bolster biodiversity.
- The inclusion of a whole life carbon assessment as part of the process should be effective in ensuring that any proposals which may initially output a higher level of emissions than desired, are still considered by factoring in the longer term benefit from reduced emissions caused by the completion of the proposal.
- We welcome the inclusion of socio-economic impacts to the NPS, whilst some proposals may cause some short term impacts they can, if delivered correctly, create employment opportunities for the local economy which will then be able to benefit further once the project is operational. As we have outlined above, due to the economic benefits of developing and investing in the rail network this part of the assessment should further highlight the economic sense in investing in and developing the rail network.
- We welcome the inclusion of 5.264 as this presses the importance of ensuring that any project is integrated properly to the transport network and encourages a modal shift to sustainable modes of transport such as active travel, public transport and rail freight.
The effectiveness of the NNNPS in ensuring alignment with local transport plans and local networks, and taking into account the impact on communities where national networks are located.
- The draft NPS has importantly made greater reference to local transport plans than the previous NPS which gave this area little consideration. To further ensure the integration of national networks to local networks an alignment with local transport plans is required. Although as the NPS states “This should include agreement on alignment…” rather than ‘must’ / ‘will’ there could be some concern as to how effective the NPS in ensuring there actually is alignment, although being so prescriptive could and insisting on agreement could enable nimbyism to prevail.
- As the Examining Authority and Secretary of State should give consideration to the impacts on policies set out in local transport plans as part of their decision making process, then hopefully this more holistic approach can ensure greater alignment with local transport plans via the NPS.
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