Guidance majors on measurement, rather than interventions

Without fanfare or formal announcement, the DfT's Quantifiable Carbon Guidance has been published, writes Peter Stonham

It is interesting to note that the DfT's long-awaited Quantifiable Carbon Guidance (QCG) simply appeared on the DfT website on 28 August as a publication, without any formal ‘news announcement’ or supportive quote from even a junior minister. And perhaps significant too that what had been originally been referred to within the Department as QCR (Quantifiable Carbon Reduction) has now become entitled Quantifiable Carbon Guidance.

Back in 2021 the Johnson Government’s Transport Decarbonisation Plan actually said.

“We will drive decarbonisation and transport improvements at a local level by making quantifiable carbon reductions a fundamental part of local transport planning and funding.”

In the new guidance significant back pedalling is evident with this statement being the nearest equivalent in paragraph 

2.2. While responsibility for achieving carbon budgets and Net Zero lies with national Government, local authorities are uniquely placed to influence transport decarbonisation through transport and place-based planning.

To support decarbonisation across all emissions sources associated with transport, authorities should consider and account for emissions from the construction and maintenance of infrastructure, as well as user carbon.

So a big shift from fundamental to optional, and a narrowing of what the document sets out to do.

There may thus be disappointment amongst Climate Change campaigners that with a concentration on detailed carbon calculation, measurement and impact assessment this guidance makes no attempt to advocate or present possible options for packages of measures that would help achieve carbon reduction within a transport strategy. Despite such approaches probably being the best hope of meeting Net Zero targets, transport strategies are only considered at a high level in the document, with some broad examples of policy areas that might be addressed, leaving a gap between this and the assessment of prospective useful ameliorative outcomes of individual interventions.

It is thus also interesting, for example, that a report on estimating benefits of active travel investment, commissioned from Leeds University ITS by Active Travel England, was posted by DfT only in July. 

In a list of current gaps, this said that: “area-wide strategies are important to the success of active travel policy, and the appraisal methods could do more to enable and encourage the assessment of schemes as part of a strategy, rather than in isolation”. The report is dated 2023, so seems to have been wastefully sitting on the shelves since then.*(see ref below)

Likewise modal change discussion in the QCG is limited to vehicle use rather than car ownership, without considering what policy approaches might reduce it and thus address levels of Scope 3 life-cycle carbon emissions, from vehicle manufacture, maintenance and scrappage.

The context of the behaviour change challenge is meanwhile set in the QCG by references to existing road traffic demand forecasts, with the statement that 

“Authorities should as a minimum develop an estimate of future emissions under a BaU scenario that uses current DfT/TAG datasets and recognised growth forecasts such as the National Transport Model (NTM) / National Road Traffic Projections (NRTP)”. 

Some may feel this over embraces at least part of the long -criticised ‘Predict and Provide’ paradigm.

Will the guidance just help to measure and indicate how significant the challenge of carbon reduction is for transport, rather than feeding into a process that prompts appropriate new local transport policy approaches? The focus is just on “the process of developing transport strategies [LTPs] and schemes”, with no linkage across to consideration of carbon impacts in wider local planning/spatial development strategies in which transport is now supposed to be a significant part.

There is one throwaway mention of a wider world in paragraph 

2.11: The approach and methodologies outlined in this guidance may have wider application beyond transport strategies, intervention and policy development and evaluation. For example, the analysis of current and future emissions at an area-wide level could be of value to local authorities when developing climate strategies or Local Plans.”

It is also thus worth asking what status, if any, adherence to the new QCG document might have in the consideration of the transport-related carbon impact of housing and other development proposals, and any involvement the planning inspectorate may have in them ?

Sadly, it looks again as though transport matters are still sitting firmly in their own low status silo.

https://tinyurl.com/ykd4xwnr