ICE submission to the Department for Transport consultation on the revised National Networks National Policy Statement

This submission discusses the ICE’s views on the revised NNNPS including:

• How the NNNPS needs to be clearer on how project benefits and impacts in the devolved nations will be considered in assessing projects that are physically situated within England. For example, projects developed to improve rail and strategic road connections to Scotland (HS2 services to Scotland and A1 north of Newcastle).

• The need for national networks has been well established within the NNNPS.

  Reducing carbon and protecting the environment are clearly dealt with within the NNNPS in support of this aim. The focus on ensuring resilience in networks is also welcome.

  However, while policy is stated for addressing the need for the development of national networks, there is a failure to deal with priorities and hence trade-offs in specific areas.

  In section 3.9 focusing on resilience, the NNNPS does not acknowledge that capacity is the basic enabler for resilience.

  As stated in the ICE’s paper on resilience, it’s imperative first to understand how to better maintain the condition of existing assets to improve how their resilience can be better in the future.

• Section 3.46 also refers to “measures to enhance the capacity of the motorway network”, however more details around these measures must be provided and are not expanded on within the wider document.

  There’s no evident policy on how road capacity should be increased now that the previous policy of smart motorway capacity has been formally abandoned.

  As the ICE highlighted in evidence to the Transport Committee inquiry on strategic road investment, asset and maintenance activity must become a priority in the next road investment strategy (RIS3) to ensure the lessons learned from smart motorways are incorporated.

  Any measures to expand motorway capacity must be fully planned through in advance of execution.

• Integration between road and rail is inferred throughout the NNNPs through support for rail freight interchanges, and an inferred preference for rail freight over road.

  But there’s no clear policy evident that sets out whether rail should be expanded to handle a greater proportion of certain categories of freight.

  Further clarity is needed from an NNNPS around the policy for modal preference and whether it’s government policy to drive modal switch from road to rail.

• Section 3.76 also states that there’s a requirement for rail development to be balanced against financial sustainability, which could lead to a nil investment when compared to other wider economic priorities.

• The NNNPS adequately addresses carbon considerations and wider environmental targets in the development of national networks.

  Decarbonising the infrastructure system is cited as a priority within Section 2.3, which aligns with the ICE’s focus on decarbonisation as outlined in its pathways to decarbonisation insights paper.

• Generally, data sets, especially in the initial sections of the NNNPS, are inconsistent and require further evidence-based verification. This can cause confusion and could by extension make the document vulnerable to challenge. A single NPS with consistent evidence-based data sets would create more certainty.