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Friends of the earth response

 
 
noroadm
Banned
Friends of the earth response
30th January 2013 at 12:31PM
Manchester Friends of the Earth
Green Fish Resource Centre
46-50 Oldham Street
Manchester
M4 1LE
25
th
January 2013
SEMMMs Project Team
Stopford House (Fred Perry House)
Stockport,
SK1 3YQ.
Dear Sir/Madam
Please find enclosed Manchester Friends of the Earth's response to the A6 to Manchester
Airport Road (A6 – MARR) consultation.
According to the SEMMMS website this consultation is a “first phase” seeking views of the
preferred options for the scheme – largely in terms of junction layouts.
1
We also note that a

second phase will follow where we will seek your views on the preferred
scheme, prior to a planning application for the A6 to Manchester Airport Relief Road. This
second phase of consultation will begin in Spring 2013.”
Manchester Friends of the Earth does not support the proposed A6-MARR and we believe
that the proposed scheme will not achieve the economic and transport benefits claimed for
the scheme. We also believe that the proposed scheme will have a wide range of detrimental
environmental, economic and social impacts effects. We will campaign for the proposed
investment to be used to support public transport and active travel schemes.
Therefore we have not responded to the questions regarding specific junction layout options.
We have briefly outlined several key areas of concern and will submit a more detailed
response to the “second phase” consultation in Spring 2013.
Yours sincerely
Pete Abel
Dr Graeme Sherriff
Manchester Friends of the Earth
1

Scope of the consultation – review of other non-road building options.
Since the original SEMMMS study, which was completed in 2001, there has been no full up-
to-date review of the need for the A6-MARR in comparison to other non-road building options
to address traffic congestion problems. This is despite a national flattening out in traffic
growth, changes to travel patterns, new legislation on air quality and climate change.
The A6-MARR would be close to other major infrastructure schemes which would affect traffic
levels and air quality and carbon emissions, including Manchester Airport City Enterprise
Zone, plans for Woodford Garden Village on land at the former Woodford Aerodrome site
south of the A6-MARR,
2
and plans for a major new settlement east of Handforth at the
junction of the A555 and the A34.
3

Air pollution
The UK Air Pollution report 2011 found that annual mean concentrations of NO2 beside busy
urban roads frequently exceed 40 μg m-3, the limit value set by the European Union to
protect human health.
4
The report showed that the Greater Manchester agglomeration had
locations with measured or modelled mean NO2 concentrations higher than the 40 μg mean
limit.
The Greater Manchester Local Transport Plan 3 (LTP3) acknowledges that the European
Union requirements to meet NO2 concentration targets by 2010 have not been met, but does
not set out how transport planning decisions will enable the 2015 deadline to be met.
5
Despite
the focus on meeting EU limits on NO2, the Greater Manchester Air Quality Strategy and
Action Plan ‘made very little difference’ (LTP3 section 9.3) to NO2 concentration at most road
side locations.
6
The LTP3 also acknowledges that ‘financial penalties may have a significant
impact on future budgets’. Greater Manchester is not due to meet legal NO2 limits until 2020,
which puts the UK, and in turn Greater Manchester authorities, at risk of large fines up to
£300 million.
7
The Greater Manchester LTP 3 states that a detailed assessment and air quality modeling is
being carried out by the Greater Manchester Transportation Unit through the Greater
Manchester Emissions Dispersion project to provide a forecast for emissions for 2015/16.
However, this does not appear to be referred to in either the A6-MARR Business Case or
Environmental Scoping Report.

Major Scheme Business Case (MSBC)
The Economic Assessment Report (EAR, MSBC Appendix B6) does not provide a sound
strategic case for the A6-MARR proposal. Taken at face value, it illustrates that neither the
“with scheme” nor the “do nothing” scenarios will prevent the worsening congestion in the
study area. Manchester Friends of the Earth would therefore argue that this totally
undermines the implied EAR claim that the scheme will generate an economic benefit
2
compared with the present situation, and casts severe doubts on the estimates of GDP and
productivity growth that depend on time-savings.
Additionally, the low discount rate, combined with assumptions about income growth, means
that only about 30% of the estimated benefit are projected to accrue in the first 30 years. The
overwhelming bulk of the benefit arises so far in the future as to be of little use.

Accuracy of Traffic modeling
The supporting documentation available does not seem to provide an analysis against
identified objectives and problems, as required in the Webtag methodology. Walking or
cycling is not included in the modeling, which conceals the real impact of locating the new
development in the planned locations and accessing them primarily by road.
The public transport forecasts do not appear to be robustly validated and thus mode choice
and the impacts of the scheme are not well represented.
In particular the mode split predicted by the model for areas where it is currently measured,
such as central Manchester and surrounding areas including Stockport, is not shown for the
modelled base year or future years.
Some of the Department for Transport guidance does not appear to have been followed, for
example there is no options report nor an analysis of time costs and savings by size.
It is also important to note the limits of the traffic forecasting, which does not consider induced
traffic. Induced traffic occurs when a greater volume of traffic is generated as a result of extra
road capacity, and evidence of this has been well documented.
8
9
The 1994 report by the Standing Advisory Committee on Trunk Road Assessment, entitled
“Trunk Roads and the Generation of Traffic” stated 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. (Conclusion 10)”
and that:
“These studies demonstrate convincingly that the economic value of a scheme can be
overestimated by the omission of even a small amount of induced traffic. We consider
that this matter is of profound importance to the value for money assessment of the
Road Programme.” (Conclusion 12)
and:
“We therefore recommend that scheme appraisal must be carried out within the
context of economic and environmental appraisals at the strategic area-wide level
which take account of induced traffic through variable demand methods. Much more
emphasis needs to be placed on the strategic assessment of trunk routes within a
3
corridor or regional or urban context. (Conclusion 17)
10
If induced traffic is not fully included in the assessment of the scheme, the traffic and resultant
air pollution and carbon emissions will be underestimated which further undermine that
projections included in the A6-MARR supporting documentation.

Climate Change legislation.
The Climate Change Act 2008 introduced a binding reduction target requiring the UK to
reduce its emissions by at least 80% by 2050 against 1990 levels and a reduction of at least
34% by 2020.
11
The Government has set out plans for achieving the emissions reductions committed to in the
first four carbon budgets up to 2027 in ‘The Carbon Plan’ published in December 2011.
12
Emissions for the transport sub-sector, which accounts for 24% of overall UK emissions, are
dominated by the car: 58% car, vans 12%, Heavy Goods Vehicles 17%. The Plan requires
that sustainable travel choices are a key element of any developments to de-carbonise travel.
At the NW regional level, the North West Climate Action Plan outlines a vision for a low
carbon region by 2020.
13
The action plan outlines how by 2020 public transport and car
sharing are the mode of choice for many journeys and walking and cycling will be preferred
for short journeys. As a result of this approach,
which clearly excludes road-building
, the
action plan says that road congestion and health will be improved.
At the Greater Manchester level, the GM Climate Strategy outlines a plan to build a low
carbon economy by 2020 and reduce collective carbon emissions by 48%.
14
Cheshire East Council has produced a Carbon Management Plan which sets out how it will
reduce emissions from its own operations.
15
Tackling climate change is a priority of the
council’s Corporate Plan 2010-2013
16
and a key aim of the Sustainable Community Strategy,
“Ambition for All”.
17
A6-MARR impacts on climate change.
The Major Scheme Business Case (MSBC) states that other measures which would have a
positive impact on carbon reduction – such as new bus services and modal shift to cycling –
have not been included
in the modeling. It would inform appraisal of the contribution of the
scheme to carbon reduction objectives if it were possible to compare this with the greenhouse
gas impacts of a public transport improvement and cycling and pedestrian infrastructure only
option, without the A6-MARR.
Table 4.3 Appraisal of impacts shows that the scheme will lead to a projected increase in
carbon emissions over a 60 year period of approximately 10,300 tonnes. The scheme has
been appraised to have a ‘neutral’ impact on climate change emissions. However, in the
context of the UK’s legal commitment to reduce greenhouse gases by at least 80% by 2050,
4
an actual increase in carbon emissions is a very negative outcome in terms of climate change
impacts.
The Environmental Scoping Report has not considered climate change adaptation. The UK
Climate Change Risk Assessment 2012 states that transport infrastructure may face an
increased risk from river flooding.
18
There are two main areas with flood risk within the
scheme area, at the confluence of Norbury Brook, Poynton Brook and Lady Brook, and the
area surrounding the River Dean and Spath Brook. The Business Case states that ‘a detailed
flood risk and drainage study is being undertaken’ – this should have been completed and
presented as part of the consultation and to inform the decision-making process, including
future risks.
Notwithstanding the flaws in traffic modeling and likely higher greenhouse gas emissions,
taken at face value the proposed scheme’s claims to have a negligible change in overall
emissions show that the scheme will therefore make no contribution towards the three
councils’ core objectives for ‘lower carbon emissions’ (Business Case para 3.12 and Tables
3.2 to 3.4) nor the commitment to reduce carbon emissions in line with UK Government
targets, as set out in Greater Manchester LTP3. This obviously raises the question of why
such significant sums of public money should be spent on a scheme which will make, at best,
no contribution towards lowering carbon emissions.
Manchester Friends of the Earth
January 2013.
Endnotes
5
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noroadm
Banned
Re: Friends of the earth response
1st February 2013 at 4:38PM
Bump
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noroadm
Banned
Re: Friends of the earth response
25th April 2013 at 12:04PM
This obviously raises the question of why
such significant sums of public money should be spent on a scheme which will make, at best,
no contribution towards lowering carbon emissions
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Norma_Stitts
Supervised

Norma_Stitts
Re: Friends of the earth response
26th April 2013 at 12:30AM
The only questions it raised for me were as follows;

1) Did you expect a group of tree hugging hippies that wear jumpers knitted from lentils to be against the road?

2) Did anyone read the first post? It looked like the normal copy/post rubbish normally posted by Ian so I didn't bother.

3) What came first, the chicken or the egg?

4) Ignoring yourself and the 'Copy/paste King' with a tendancy to vanish when he cannot answer questions, who else is against this road? Where are they?
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noroadm
Banned
Re: Friends of the earth response
26th April 2013 at 8:48AM
Norma_Stitts Wrote:

The only questions it raised for me were as follows;

1) Did you expect a group of tree hugging hippies that wear jumpers knitted from lentils to be against the road?

2) Did anyone read the first post? It looked like the normal copy/post rubbish normally posted by Ian so I didn't bother.

3) What came first, the chicken or the egg?

4) Ignoring yourself and the 'Copy/paste King' with a tendancy to vanish when he cannot answer questions, who else is against this road? Where are they?


----

1. Ah ok -but they are modern now - they all have ipads and eat surf n turf

2.Ah ok - but Ian , like me finds information and posts it accordingly

3... In the garden of eden , God did not give planning permission for the road , so he created the egg that hatched the chicken that fed Adam and eve , that kept the evironment clean

4. Freewill if you wish to ignore , We are just imparting information . There are a total of 9 against and six for the road . So that is a majority . It is only those who are effected my the road who are going to voice up . The rest will descover later what an impact the road will make . Noise , breathing diffculties - ashma , 5 years of inconvienience with road building ... we have said all this before .
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Norma_Stitts
Supervised

Norma_Stitts
Re: Friends of the earth response
3rd May 2013 at 11:51PM
noroadm Wrote:

1. Ah ok -but they are modern now - they all have ipads and eat surf n turf

2.Ah ok - but Ian , like me finds information and posts it accordingly

3... In the garden of eden , God did not give planning permission for the road , so he created the egg that hatched the chicken that fed Adam and eve , that kept the evironment clean

4. Freewill if you wish to ignore , We are just imparting information . There are a total of 9 against and six for the road . So that is a majority . It is only those who are effected my the road who are going to voice up . The rest will descover later what an impact the road will make . Noise , breathing diffculties - ashma , 5 years of inconvienience with road building ... we have said all this before .


1. Ipads in itself is a laugh. How are they 'friends of the earth' if they are using products from the biggest market cap company in the World?

2. Fair play as long as it is relevant.

3. God didn't give planning permission for your house either though did he? In order for a chicken to hatch it needs more than just an egg. If you have an army of chickens but no cock then the eggs will never become a chicken, they will remain unfertalised. I'm not against religion as such. I think it's a load of poppycock. However I realise that it gives certain people a 'structure' that they need from life and it makes them a grounded individual, as long as they are not extremist in their views.

4. You are looking at the subscriptions on this forum I assume? It's not representative.

P.S. Love the new avatar.
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noroadm
Banned
Re: Friends of the earth response
21st May 2013 at 1:10PM
Thank you

your a man really arnt you Norma
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Norma_Stitts
Supervised

Norma_Stitts
Re: Friends of the earth response
22nd May 2013 at 12:46AM
noroadm Wrote:

Thank you

your a man really arnt you Norma


It's lucky that you don't bottle your powers of perception as I don't think they would sell too quickly...
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