The A629 road-widening scheme is currently being considered by Kirklees Planning Department .
1. More roads = more traffic = more carbon emissions
If you build more roads, you will get more traffic, a phenomenon known as ‘induced traffic’. [Source: https://bettertransport.org.uk/roads-nowhere/induced-traffic]
The WYCA has itself admitted this: “research shows that creating additional highway capacity for cars and other vehicles induces demand” [Source: https://www.yourvoice.westyorks-ca.gov.uk/ccip2?fbclid=IwAR2HgaKO1epmwmSDAV0u-BEhI7O-Ilwg5eBl-2Ba7y9Gzdd5vrWwzTL9ZrU#q1209]
A CPRE report in 2017 report confirmed that major new roads increase traffic above the general traffic increases for their areas, with traffic increases of up to 47% over 20 years. [Source: CPRE report 2017: The End of the Road?]
The most recent IPCC report has been described as ‘Code Red for Humanity‘ and has concluded that global heating is affecting every region on Earth, with some of the changes now inevitable and “irreversible”, including sea level rises, the melting of Arctic ice, and the warming and acidification of the oceans.. The report urges politicians around the world to act decisively to avert a climate catastrophe.
2. Climate Emergency Declarations
The road expansion proposals were first developed before both Kirklees and WYCA declared a Climate Emergency and have not been re-evaluated in the light of those declarations.
WYCA have identified that traffic reductions of 21%-38% by 2038 will be necessary to meet climate targets.
3. Changing travel patterns
The congestion modelling for the project was undertaken pre-COVID and does not take into account the new situation following COVID with fewer people commuting, greater flexibility around working hours and more people working from home. Worker footfall remains below one quarter of pre-lockdown levels in all except the smallest areas. London is less than one sixth its previous level. Kirklees and WYCA need to consider whether the works are still necessary, given the new commuting travel patterns. [Source: https://news.sky.com/story/coronavirus-just-one-in-six-back-in-the-office-in-cities-as-boris-johnsons-return-to-work-plea-ignored-12053139]
4. WYCA commitment to review the carbon impacts of all existing funded programmes
In January 2020 WYCA committed to:
“Review and calculate the carbon impacts of all existing funded programmes within the Combined Authority’s Local Growth Deal, West Yorkshire Transport Fund and LPTIP Funds; and identify potential changes and associated costs in order to make them carbon neutral or negative”.
[Source: Tackling the Climate Emergency and Improving Air Quality report to WYCA Transport Committee January 2020]
By September 2020 it still hasn’t outlined the methodology by which it is going to do this and has said that this might now be delayed until June 2021.
[Source: Strengthen decision making in light of the Climate Emergency, West Yorkshire and York Investment Committee, 1 September 2020]
Specific Objections: A629 Phase 5: Edgerton/ Halifax Road
- Historical data from the DfT shows that by 2018, traffic levels fell to three quarters of their levels in the early 2000s. There is no evidence that the A629 is experiencing continuous traffic growth and therefore the scheme is unwarranted.
- The traffic assessment assumes traffic volumes will grow by 20-22% in 2031 and 28-31% to 2038. This is vastly overinflated when compared with historic growth, national trends and ambitions to reduce car traffic by up to 38% in line with WYCA and Kirklees climate targets. Kirklees population is expected to increase by just 4% by 2028 with the majority of projected change in the 85+ age bracket. There is very little change predicted in the number of working age people. Everyone would have to drive significantly more often to generate the traffic levels predicted. (Ref https://www.kirklees.gov.uk/beta/information-and-data/pdf/kirklees-factsheets.pdf)
2. Loss of mature trees
If the scheme goes ahead 126 iconic mature trees will be felled.
Replacement saplings will take a considerable amount of time to get established and deliver the same benefits that the trees currently do. Mature woodland fixes about 15 times as much carbon as 10 year old new planting per m2, mature forest maybe fixing 100-150 times new planting CO2 fixing, per m2. .
[Source: Understanding the Carbon and Greenhouse Gas Balance of Forests in Britain. Forestry Commission – Forest Research FCRP018. 2012. ISBN 978-0-85538-855-3]
A cost benefit analysis study showed that mature trees have much higher social benefits than the newly planted trees: “Retaining an existing tree (provided it has adequate space for root and crown development) is five times more cost effective than periodic removal and replacement.”
The carbon benefits of planting the small trees in the scheme will not be realised for at least another 30 years.
3. Air pollution
The council is claiming that one of the project objectives is: “Improve air quality for local residents by contributing to a target reduction of NOx levels by 10 Mg/m3 and a target PM 2.5 particulates to 7Mg/m3”.[Source: Kirklees Cabinet Meeting document 16/10/18]
However it also admits that “The improvements will contribute towards reducing pollution levels but is unlikely to bring the areas that have AQMA below legal thresholds”. [Source: https://www.kirklees.gov.uk/beta/transport-roads-and-parking/pdf/A629-halifax-road-scheme.pdf]
Academic studies have challenged the idea that by widening roads and reducing standing traffic you are improving air quality. “The studies found 10 to 30% reduction in pollutants if traffic levels remained the same, but that pollution would be increased if traffic levels increased by 15 to 30% (depending on the scenario modelled).” [Source: https://mattturner.blog/widen-roads-to-reduce-vehicle-emissions-really/]
Local residents have pointed out that cars idling at traffic lights causes a lot of the localised air pollution at the Blacker Road junction, something that will not be addressed by adding a lane of traffic at that site., as there will just be more concentrated numbers of cars idling at the junction.
4. Loss of Huddersfield cultural heritage
The scheme passes through a number of conservation areas (Edgerton/ Birkby/ Greenhead) . See maps here: https://www.kirklees.gov.uk/beta/trees-listing-and-conservation/conservation-area-maps.aspx
The character of the conservation areas will be irreversibly degraded. Huddersfield Civic Society have said the following about the scheme:
“Destruction of this kind, for a road improvement which may only have a limited ‘life’ in terms of its overall benefits, will inevitably be viewed as an act of civic vandalism in the future.” (David Wyles, Chairman of Huddersfield Civic Society, letter to WYCA consultation team 23rd June 2018)
5. Saving time?
The stated aim of the project is to: “Improve accessibility between Huddersfield and Halifax and to the M62 by reducing congestion, thus improving journey time reliability, and reduce journey times between the ring road and Ainley Top roundabout by at least 1 minute for all road users by 2022.” [Source: Kirklees Cabinet Meeting document 16/10/18]
We do not believe that the destruction and increased carbon emissions can be justified for such a small improvement in journey time.
6. Gaps in the Climate Impact Assessment
The Amended Carbon Impact Assessment (CIA), presented as Supporting Information (ref 891063, 24 August 2021) to the A629 Ph5 planning application (ref 2021/92734) is not fit for purpose: it contains significant errors, fails to follow guidance, and reaches conclusions which conflict with its own findings.
The Carbon Impact Assessment’s significant errors include:
- The calculation of Carbon emissions from Construction Energy Use is incorrect, with a conversion factor wrongly applied to tCO2e.
- This error has the effect of reducing the tCO2e Construction Energy Use figure presented to less than 30% of its true value, such that Construction and total carbon emissions are understated throughout by 1,449 tonnes.
- The Contents section omits numerous sections and section headings and wrongly references others.
The Carbon Impact Assessment does not follow the referenced Department for Transport ‘Transport Analysis Guidance’ (TAG):
- Under ‘Road Usage’, the CIA fails to present, as required, the – likely significant – carbon emissions resulting from the forecast increase in road traffic.
- The CIA – incorrectly – excludes Operation carbon from the totals in its ‘5 year UK carbon budget’ reporting table, while stating the opposite.
The Carbon Impact Assessment does not state an overall conclusion, and makes statements which conflicts with its own findings
- The CIA does not set out a clear Conclusion. From the individual CIA section findings it is apparent that the scheme overall will have a strongly negative carbon impact on the climate.
but this is left unsaid.
- The Construction carbon Conclusion makes the false claim that “the operation of the scheme…. is expected to have a carbon positive effect on the climate”. In fact, it is apparent from the Carbon Summary Table that the operation impact will be strongly carbon negative.
In the face of the climate emergency and, given WYCA commitments and legally binding UK carbon targets, properly and professionally presenting the climate impact of the A629, Phase 5, scheme is vital. This has still not been done.
Given its numerous material inadequacies, this Carbon Impact Assessment is not appropriate to present as a Supporting Document for the A629 scheme. We suggest and request it is withdrawn and replaced by a thorough, properly conducted, evidenced and presented study.
Specific Objections: Cooper Bridge Corridor
Kirklees Council is also planning a £75 million project at Cooper Bridge, near Huddersfield. We are grateful to the Action for Yorkshire Transport campaign for sharing their objections to the project, which we include extracts from below:
1. Good use of public funds?
We have looked carefully for an estimated cost for this scheme amongst the documents posted on the WYCA consultation site, and not found such a figure. Further, we have looked for some economic analysis of the proposals and found none. Why are these key considerations hiding? The proposals have all the characteristics of an engineering approach devoid of economic justification. We are highly sceptical that the proposed scheme is value for money and the proper use of public funds. Does it, for example, give a better return to the proposed investment than any other alternative potential transport investment in West Yorkshire that could be funded by the same source?
2. Increased traffic
This is a scheme that would enhance the flow of mainly car and goods traffic. Such increased capacity will lead to further generated (induced) traffic in the long term that would not otherwise occur. We draw to your attention that the SACTRA report ‘Trunk Roads and the Generation of Traffic’ (SACTRA, DfT, 1994) said in its Executive Summary at its para 10 that, “Considering all these sources of evidence, we conclude that induced traffic can and does occur, probably quite extensively, though its size and significance is likely to vary widely in different circumstances. Estimates of an additional 10% of traffic in the short-term and 20% in the long-term were given as guidelines by that report. Much more recently, the DfT has published a report entitled “Latest Evidence on Induced Travel Demand: an Evidence Review” (WSP and Rand Europe, DfT, May 2018) which endorsed the conclusions of the SACTRA report of 26 years ago and said that generated traffic was particularly likely to occur in situations where congestion was occurring currently. If one applies the central estimate of generated traffic given by the SACTRA report to the current TEMPRO traffic forecasts, one finds that after 20 years around 40% of the additional road capacity provided by a scheme such as that proposed here on the A62 will be occupied by the generated traffic, traffic that would not be there but for the proposed investment. As you claim there is currently congestion on the southern end of the A62 into Huddersfield, a rather higher incidence of generated traffic is likely and so the ineffectiveness of your proposals even greater. We also would like evidence of how and with what outcomes the question of generated traffic has entered into the estimation of the benefits of this scheme.
3. Air pollution
Generated traffic also will increase carbon dioxide, nitrogen dioxide, particulates and noise emissions and increase congestion in adjacent parts of the road network. Yet this scheme claims to “reduce traffic related pollution” in its aims. We put it to you that the net emissions effects are not what you claim as you have failed to recognise the question of generated vehicular traffic. We have found no substantiation or analysis showing that the current proposals would actually reduce traffic related pollution: where is that analysis and evidence? Indeed, you claim there is “poor air quality”, but just what measurements of emissions along this part of the A62 do you have? None are provided. At the moment, we believe this scheme is not compatible with the climate emergency resolution that Kirklees Council has adopted, will not reduce NOx emissions as the Supreme Court and Defra have required Kirklees Council to do, we do not see how it will contribute to the reduction of carbon emissions the Government has signed up to via the Paris Agreement, and we do not see how it accords to the carbon emissions reduction objective of the current West Yorkshire Transport Local Plan. It certainly does not accord to the provisions of chapter 4 of the February 2019 Strategic Transport Plan of Transport for the North.
4. Lack of traffic modelling
There is a lack of evidence that any traffic modelling has been undertaken. The public should not be taken to be stupid or incapable of understanding such.
No sense is conveyed in the material presented for this consultation that any analysis has been undertaken of the impacts of implementing these proposals on the rest of the road or transport network. If road traffic is speeded up along this section of the A62, will it not just more quickly arrive at the Southgate part of the Ring Road and extend the queues and delays all round that Ring Road and so dissipate any gains along the A62, or going northwards arrive more quickly in the Cooper Bridge area of the A62 and add to the queue lengths and durations there? The doubling of the width of part of the A62 (inbound south of Thistle Street), and the proposals in general, would continue to deter cycling and walking in the adjacent areas, and indeed add to the barrier effects of the A62.
5. Lack of road demand management policy
This scheme appears to have no link to any transport and especially road demand management policy. We have found no proposals to use parking policies applied in the central Huddersfield area to deter demand along the A62 and, especially, to deter peak hour commuting. Long-stay public parking prices in central Huddersfield have been kept constant now for around ten years such that with the effect of inflation those prices have been reducing in real terms. The quantity of long-stay public parking in central Huddersfield has been only marginally decreased in the same time period. There has been absolutely no clamp down on non-residential vehicle parking in central or outer Huddersfield in at least the past two decades. How about a Workplace Parking Levy? When has ever any personal travel planning been implemented in the whole of Kirklees? The use and enforcement of Travel Plans attached to planning permissions has lacked effectiveness. In Kirklees District, the promotion especially in the private sector of alternatives to travel such as working at home, teleconferencing, hot desking, use of the internet, skyping, and use of works collective transport has been notably absent. There is a passive car share scheme across the whole of West Yorkshire but where does that get promoted and what is its incidence of use in Kirklees? Many of these demand management measures are relatively cheap and quick to adopt, but do require a switch from engineering to behavioural change thinking. We submit that the moneys being proposed to be spent on the A62 would be much more effectively deployed if allocated to developing and implementing a road demand management programme.