POS is grateful for the opportunity to respond to the Department for Transport (DfT)'s consultation on the 'Draft National Policy Statement for National Networks (NN NPS). The National Networks comprise the Strategic Road Network (SRN) under the control of the Highways Agency (HA), the national rail network, and strategic rail freight interchanges. Our comments are restricted to the NN NPS as it relates to the road network.
As officers of local planning authorities, the principal interest of the vast majority of POS membership is the impact of NPS NN on road transport and on the entirety of Britain's road network, particularly the 98% that is not under the control of the HA. Although a third of all road traffic is carried by the SRN, almost all of these journeys begin and end on local roads, under the control of the local highway authority. We therefore do not think it sensible to devise a NN NPS that does not include strategies for the 98% of the network outwith HA control.
The traffic forecasts quoted, produced using the National Transport Model, indicate that road traffic on English roads will increase by 42% between 2010 and 2040. On the strategic road network, road traffic is forecast to grow by 46% over the same period. The outcome of this increase will be exponential increase in congestion which will impact most severely on the SRN. The NN NPS says that alternative approaches such as demand management and modal shift will be ineffectual in dealing with the forecast traffic increase and that the Government's response will be to increase capacity on the SRN, which will include new road alignments and links.
We are sceptical of the underlying forecasts that Government policy is predicated on and concerned that the approach outlined will disproportionately focus investment on the SRN. This effectively amounts to a return to "predict and provide"; the traffic generation effects of which have been well documented. The outcome will be to increase pressure on local roads whilst effectively starving local highway authorities of funds.
Increase in the strategic road capacity, without also adequately investing in methods to reduce travel demand, will make the most congested places worse, fail to deliver on the Government's strategic objectives for the national networks, ultimately causing harm rather than benefit to the economy and failing to reduce carbon emissions from road transport. We would therefore urge a complete review of Government policy in respect of the NN NPS.