National Infrastructure Commission call for evidence:
Trans-Pennine Tunnel project (TPT)
This is a submission prepared by the three representatives of various environmental organisations (including Campaign to Protect Rural England, Friends of the Earth, and Friends of the Peak District, which also come together in the Transport Activist Roundtables for the North West, and Yorkshire & Humber - TARs) who are members of the DFT/Transport for the North stakeholder reference group for this project. It has also been endorsed by Stephen Joseph on behalf of Campaign for Better Transport.
In October 2015 we together submitted a document entitled Trans-Pennine Tunnel Strategic Study: Testing the fundamental feasibility of the project. This is appended together with a related literature review. Its purpose was ‘to identify a number of questions or issues relating to the fundamental feasibility of the project that we believe have not been adequately addressed during this first phase, to the extent that members of the reference group can be satisfied that ‘proof of concept’ has been established.’ Eleven such issues were identified, relating to the treatment of spatial economic and agglomeration benefits, integration with wider transport strategy, and impacts and risk. In late November the study’s Interim Report was published, and then another reference group held on 9th December allowed us to further review whether the issues we raised had been adequately addressed.
Our submission to you now is a contribution to the National Infrastructure Commission’s call for evidence in relation to Northern Connectivity. We have also seen your statement of 7th December specifically responding to the TPT study, which talks about ‘a new approach, building broad consensus behind a long term plan backed up with serious and sustained investment’. Our position is that such a ‘broad consensus’ does not exist about the TPT, because the questions we have asked have not been adequately answered, including in the Interim Report. In view of the magnitude of this particular project we believe it is incumbent on the NIC to scrutinise this proposal with particular rigour.
We believe that the critique we have prepared of the TPT work so far is consistent with the five questions identified in the Connecting northern cities part of your consultation. In particular we strongly support the open-ended nature of NIC Qs2 and 3, which seeks to establish, with evidence, first of all ‘which city-to-city corridors’ should be the priority for interventions, without a starting assumption which privileges any particular corridor or mode. This is the same point we have made in Q4 of our October submission.
The NIC Q1 asks about the broader economic ‘weaknesses in transport connectivity holding back northern city regions’, but you will note that the Interim Report does not provide an analysis or evidence that supports the argument that the absence of this specific intervention - that is, a road improvement to the Manchester-Sheffield corridor in particular - is either a significant weakness holding back either city, or the northern economy more generally, or that a road intervention is optimal rather than that of other modes, and specifically rail. Instead it only refers to generalised analysis about North-South economic inequality, and the benefits of connectivity improvements, which are uncontested. We ask critical questions about the approach to transport connectivity underpinning the TPT concept in Qs3 and 5 of our submission.
If we broaden the scope of NIC Q4 to include connectivity needs across the North (and also to the rest of the UK) as well as international connectivity, it is effectively asking ‘what should be the transport and connectivity strategy that Transport for the North and the Northern Powerhouse should be implementing and investing in over the next decades?’ The joint DfT/TfN One North, One Vision, One Agenda report in March 2015 is more of a blueprint - and also a prospectus – which then ought to be supported sequentially by an overall spatial framework for the North that ensures the distribution of connectivity and resultant benefits across and within all city regions, and a demonstration at the macro level of how future road and rail network investments such as HS3 will integrate with each other. In the absence of these at the moment the TPT project is proceeding prematurely, as our Q6 pointed out. Indeed this TfN macro analysis has already been pre-empted to an extent by the Greater Manchester Spatial Framework (Stage 1 September 2014) and its Transport Strategy: Our Vision for 2040 (July 2015), which it could be argued are acting to distort the strategic direction. These are grounds for allowing the TfN process to catch up before over-committing to a particular corridor scheme.
However we also point to the implicit bias contained within the wording of NIC Q4, which appears to privilege international over regional or national connectivity. Whilst the ports representatives on the TPT reference group (specifically Peel Ports) have made a good case in favour of improved rail connections across the North and nationally - which will not be assisted by an improved Manchester-Sheffield road corridor - the predictable beneficiary of a TPT road improvement will be Manchester Airport, diverting market share from other regional airports east of the Pennines, and with a consequence also of increased aviation climate emissions. By contrast we believe that the NIC objective of better connecting northern cities should be focused on delivering spatial and economic benefits as much within city conurbations as between them, whilst always contributing to environmental sustainability, particularly air quality, and carbon reduction.
Our Q8 asked how the process of east and west tunnel portal selection would be undertaken (whilst Q7 relatedly considered the problem of the traffic generation that an improved road corridor could unleash across highway networks), and whilst the December reference group provided more information on that it also revealed further conceptual difficulties in terms of the definition of the Manchester-Sheffield corridor endpoints. Simplistically one might assume that these would be the two cities themselves, with economic/agglomeration benefits accruing primarily and concentrically to their city centres, but in discussion a number of points were made: i) that the trend in urban policy is to reduce, not increase, the quantity of traffic, proceeding into cities; ii) that the corridor endpoints should instead be understood to be the much larger but also more amorphous Manchester and Sheffield city regions; and iii) that maybe ‘Manchester’ meant instead ‘South Manchester’ and specifically Manchester Airport and the Airport City development which is being promoted. By contrast improvements to the Manchester-Sheffield rail corridor would bring benefits much more precisely targeted to the two cities (and onward connecting points). In the absence of an agreed spatial strategy for the corridor area, and the two locations it connects, how can this conceptual uncertainty be resolved?
Our Qs9-11 examined various impacts and risks. Our document did not even begin to probe the multiple environmental impacts, but just taking one example, the superficial treatment of air quality issues in the Interim Report (table 7.1) only hint at the range of difficulties (e.g ‘Impacts of ventilation may introduce new air quality issues, particularly in the National Park.’) We also draw one additional risk to your attention. The Interim Report points to a project opening date some 20-25 years into the future, that is around 2035-2040 NIC Q3 asks about which corridors should be the priority ‘for early phases of investment?’ In view of this very extended time horizon and also the strategy uncertainties to which we’ve previously alluded it’s difficult to understand how TPT could be treated as an NIC priority.

Finally NIC Q5 asks about ‘governance concerns’. Our Qs1-2 did examine some issues relating to governance – and we are still exploring the adequacy of the governance arrangements for TfN overall - but the principal concern must be, in view of its extraordinarily high cost, why the TPT scheme is being promoted - presumably as a result of advocacy by particular interests - in advance of so many other schemes, modes, corridors and city locations which could be crowded out, left unexamined or without economic and social benefits by the premature advancement of this single scheme.
We ask you to consider these various points alongside those made in our October submission.

Lillian Burns (CPRE and NWTAR)
Anthony Rae (Friends of the Earth and YHTAR)
Anne Robinson (Friends of the Peak District and CPRE)
and Stephen Joseph, Campaign for Better Transport
8th January 2016
Trans-Pennine Tunnel Strategic Study:
Testing the fundamental feasibility
of the project
Submission to the Department for Transport/ Highways England and Transport for the North
- by the Campaign for the to Protection of Rural England, Friends of the Earth, Friends of the Peak District[1], and the NW & Y&H Transport Roundtables
- endorsed by Campaign for Better Transport

As members of the Reference Group for this study representing environmental transport non-governmental organisations (NGOs), Wethe authors of this paperhave beenwere advised at itsits third meeting on 6th October 2015 that the conclusion of its preliminary ‘scoping’ phase had been brought forward and would come to an end on 28th October. A report would then be submitted to, with a judgement being made as to whether the study should proceed further, at a meeting of the Tunnel Project Board in mid-January.
In view of the significance of a project of this scale, and its possible environmental and sustainability impacts, we have tried to engage constructively with this process, as we believe its officers the project team will testify. We have placed particular emphasis in this first phase on urging the study investigation ionors of the study to establish what might be called a ‘proof of concept’: whether there are particular issues or circumstances which, if found to be not feasible - and if necessary after further review - would require the study process to pause or stop. We received assurances from the project team that they shared this perspective. Of course, if no such ‘showstoppers’ were to be found, then the study would proceed.
The purpose of this submission is to identify to the Department for Transport and Transport for the North – its two co-sponsors - a number of questions or issues relating to the fundamental feasibility of the project that we believe have not been adequately addressed during this first phase, to the extent that members of the reference group canould be satisfied that ‘proof of concept’ hasd been established. We would ask you to review each of these points. In view of the scale of the project, and the nature of the issues raised, we would be grateful if this short document could be circulated to both the Tunnel Project Board and Steering Group. If it ’is the case that there are not yet adequate responses to the questionsm raised then that should be a casereason for an extension of the scoping stage until feasibility has been properly demonstrated.

Questions relating to fundamental feasibility
1.No evidence has been produced to the reference group to substantiate the ‘findings’ about which we have beenare asked our opinion. The process has involveds the reference group being shown a small number of slides at its meetings and being asked for comments on their very general content. No papers arehave been provided in advance, not even paper copies of the slides at the meeting. By contrast, for example, two of us were members of the South and West Yorkshire multi-modal study SWYMMS undertaken a decade ago and the other was a member of the MIDMAN multi-modal study which investigated the M6 corridor.mMembers of thatose reference groupswouldreceived detailed research reports in advance and bewere able to base their input on that evidence. In the absence of written evidence to support them, information on slides can only be regarded as ‘assertions’. We are not arguing that detailed work to support the slides does not exist somewhere, but that if it does we have not seen it.
We would expect to see appropriately detailed evidence in order to test each of the following questions (and please see point 11 below). Without being able to test the assertions being made, and to understand the qualifications and assumptions relating to particular detailed analyses and modelling (which are always influential in such a study) we cannot regard this study process as being of an acceptable quality standard. We suggest that there has to be an agreed approach for participants in the reference group whereby their responses can have to be based upon actual evidence which they are able to challenge.[2]
2.Has an actual need for the improvement of this road corridor been established? Whilst it is possible to hypothesise a theoretical case that there is a need for an ‘all-weather road route between Manchester-Sheffield’, that it immediately has to be grounded and challenged with reference first to the existing level of expressed demand particularly for end-to-end journeys on the various routes [3]. Of course the purpose of the study is to investigate what would happen if the existing constraints on end-to-end connectivity were to be lessened (to a defined extent) but seeing that the existing flows are relatively small then the absolute scale and impacts of possible increases ought to have been calibrated against this baseline. WebTAG recommends a three-stage initial approach: (1) set objectives and identify problems (2) develop potential solutions (3) create a transport model for the appraisal of alternative solutions. If this had been followed we would have expected to see by now the framework for a package of alternative multimodal measures to address the problems in this corridor.

(As just a first example of the link between this and the previous point concerning ‘evidence’: aA key input to this investigatory work should be the one year POPE study on the M62 smart motorway which is now nearly a year overdue. The POPE study is particularly pertinent to the TPT study given the interactivity of traffic flows between the M62 and the A628 corridor. The NGOs have been asking to see it with increasing urgency because its findings will relate to all three strategic DfT/HE studies currently underway in the North of England, but access to it has so far been denied.)

The next few questions concern the approach towards agglomeration and spatial economic benefits underpinning the study

3. Are agglomeration and spatial economic benefits to be achieved by increasing, rather than reducing, distance travelled? The study appears to be based on the approach that the economic benefits for the project are to be sought by increasing the catchment area or travel to work/shop etc area across a range of sectors, and by road, rather than by reducing distances travelled.For example presentations have been made about the advantages to be obtained by increasing the catchment area across the Pennines of major shopping centres such as Meadowhall/Trafford Park, Manchester Airport and labour market commutes to work. The consequences of this approach would tend to be increased carbon and traffic levels across both strategic and local highway networks (as well as widespread localised economic gains and losses - see point 5). ButAnd the counter-balancing argument - that economic benefits should be sought whilst reducing transport distances/carbon - has not been presented.
4.Only the agglomeration and spatial economic benefits of this particular road corridor are being tested, without equivalent comparators. The case for and feasibility of a Trans-Pennine tunnel (TPT) will be determined by the value of positive economic benefits attributed by modelling. But a proper test of this case would require that the cost/benefits of a Manchester-Sheffield road corridor should be compared to (variously): a Manchester-Sheffield rail corridor; a Leeds-Sheffield road/rail corridor [4]; or benefits within Greater Manchester and/or South Yorkshire rather than between them [5]. Such a comparative exercise has not been included or referred to, so the prior privileging of the Manchester-Sheffield road corridor cannot be substantiated.
Nor have the agglomeration and economic benefits of other types of transport infrastructure investment, in whatever location, been tested against the modelled benefits of providing a very long (and therefore very expensive) road tunnel on the Manchester-Sheffield corridor. Another version of this comparator would involve working upmulti-modal alternatives for the corridor itself along with smart measures
5.Will theagglomeration/economic benefits of a Manchester-Sheffield road corridor be positively allocated to both poles of the corridor, or disproportionately allocated to one? The SACTRA studies of the 1990s analysed the situation where the poles at either end of an enlarged road corridor might not equally or positively benefit, but that instead the benefits of its improvement might disproportionately accrue to one pole. So, in the case of this project, it might be that the economy of Greater Manchester would be disproportionately strengthened, at the expense of that of South Yorkshire which would be weakened. This outcome could also apply to particular sectors e.g Manchester Airport would benefit at the expense of Doncaster Robin Hood; or major retail hubs such as Meadow Hall/Trafford Park at the expense of lower shopping tiers. If sSuch an analysis was pursued it might then argue in favour of an alternative scenario where e.g the corridor between West-South Yorkshire would be strengthened, whilst that between Greater Manchester and South Yorkshire would deliberately be left unimproved - on the basis that net benefits on both sides of the Pennines would still be increased and optimised.