Climate Change

Releasing it's response to the draft National Allocations Plan, FIE has pointed out that the Plan fails to comply with European rules in a number of respects:
- There has not been the required public consultation.
- The plan does not specify the other measures to be undertaken to reduce emissions.
- The plan does not include compliance with EU law on the pollutants which cause acid rain.
- The plan is over-generous to major polluters such as the cement industry.

FIE is opposed to the giving out of permits on the basis of existing pollution emissions. Permits should be auctioned. FIE also calls for the plan to be amended to ensure the peat-fired power plants are converted to burning willow or other biomass.
Response to Public Consultation on Draft National Allocation Plan


1. The initial (EU) decision to ?grandfather? was a bad decision.

We appreciate that this consultation is limited to the decision on the draft Irish National Allocations Plan, which must be drawn up to fit in the EU Emissions Trading Scheme for carbon dioxide. Nonetheless we must emphasise that we consider that the decision to allocate emission credits for free to existing polluters was a bad decision. It creates fundamental unfairness between different sectors of the economy and windfall gains for some large polluters. Additionally it is now evident how appallingly complicated it is to implement; problems include the validity of baseline emissions, relevance of early action, allowances for future entrants and planned developments, as well as manipulation of the system by Member States to benefit all or some national industries. All of these open opportunities for gaming with the system, and the generation of windfall gains at the expense of the economy as a whole.

2. There has been no public consultation on the question of the division between trading and non-trading sectors.

The draft Plan appears to indicate that the consultation being carried out is only in relation to the EPA?s role in allocating emission rights from the total allocation decided by the government. It states that

?Public consultation through a NAP workshop with all stakeholders (inside and outside the ETS) was undertaken by the Department of the Environment, Heritage and Local Government.?

This is not correct. The consultation at a stakeholders? workshop on 22nd October 2003 was not public consultation. It was not advertised to the public in any way. It took the form of a presention by the Department and its consultants on the study which the Department?s consultants intended to carry out.

The government decision on the total allocation to the trading sector has not been offered for public consultation in any way. The Minister for the Environment has indicated in response to a question in the Dáil that this decision has been made and is not now open for consultation. This is a non-compliance with the Commission?s guidelines.

3. The draft Plan does not contain an adequate description of the policies and measures to be applied to the sources not covered by the emissions trading Directive.

The plan says in this regard:

?The precise mix of additional policies required to achieve this reduction is still to be finalised in the review of the National Climate Change Strategy.?

In fact the draft Plan contains no details other than references to a plan to introduce carbon tax and a plan for the government to purchase Flexible Mechanisms carbon credits, as well as predictions for sink credits from domestic forestry.

This failure to specify policies and measures is a non-compliance with the Commission?s guidelines.

4. The planned carbon sequestration by forestry are not realistic.

The plan is based on an unrealistic assessment of carbon sequestration by forestry. The model on which these sequestration calculations are based does not take any or sufficient account of the impact of afforestation on soil carbon in Ireland. Much of the afforestation is being carried out on organic peaty soils. Afforestation of such soils involves drainage which lowers water tables and exposes soil carbon to oxidation.


5. The draft Plan has apparently not taken account of the need to comply with the National Emissions Ceilings Directive 2001/81/EC.

Although the draft Plan lists the NEC Directive in Appendix 3, there is no explanation as to what the consequences of this Directive are for carbon dioxide emissions.

This is presumably because there is not yet any National Transboundary Pollutants Strategy in place. On 22nd January 2003, the European Commission issued a formal notice to Ireland for non-compliance with the Directive. Public consultation on a discussion paper was carried out in Summer 2003. However, the round-table discussion planned has not yet taken place.

In our response to the Discussion Paper on Transboundary Air Pollutants, we emphasised the need to integrate the policy measures to deal with long-range pollutants and greenhouse gases. We attach a copy of that response.

The content of the planned National Transboundary Pollutants Strategy is of considerable importance in relation to CO2 emissions. The major challenge in meeting Ireland?s ceiling is the need to reduce emissions of NOx. How the ceiling wlll be met is not clear. Some of the potential measures that might be included in that Strategy in order to reduce NOx emissions would lead to a decrease in CO2 emissions. Others would lead to an increase in CO2 emissions.

This is a non-compliance with the Commission?s guidelines.

6. General comments in relation to market-based mechanisms.

We support in principle the use of market-based mechanisms to address greenhouse gas emissions. However we have major concerns about the current scheme.

We have already emphasised our opposition to the allocation of free emissions rights on the basis of existing emissions. If emission rights are to be allocated free, they should be allocated free to all. They are the rightful property of natural persons, not legal fictions.

We would like to see the ETS scheme adjusted to mesh with a system of Domestic Tradable Quotas, as proposed by FEASTA, the Foundation for the Economics of Sustainability in their response to the recent carbon tax consultation. This would meet the important requirement that all actors in the market are treated equally, and the need for economic efficiency and social equity. In addition it would bring the carbon dioxide market to the forefront of public awareness and thereby contribute substantially to public support for and participation in greenhouse gas reduction measures.

7. Subsidies to greenhouse gas emissions must be removed.

Friends of the Irish Environment and FEASTA cooperated last year on a report commissioned by Comhar, the National Sustainable Development Partnership on Subsidies and Emissions of Greenhouse Gases from Fossil Fuels. We attach a copy of the study.

The study identifies major direct and indirect subsidies to the major polluters which should be removed in order to allow emissions trading, carbon tax, domestic tradable quotas or any other market-based mechanisms to operate effectively and maximise economic efficiency.

The most important of these for the purpose of Emissions Trading is peat-fired electricity.

8. The emissions trading scheme should ensure the end of peat-fired electricity generation.

The draft National Allocation Plan provides for the allocation of over 2 Mt of emission allowances to peat-fired electricity generation.

Peat electricity plant allocation t CO2
Edenderry (open) 614 563
Lanesboro (not yet open) 583 504
Shannonbridge (not yet open) 875 256
total 2 073 323

Of these, 1 400 000 t are being allocated to plants which don?t yet operate.

It is instructive to compare this enormous allocation to the government?s intended purchases of 3.7 Mt CO2 per annum during the commitment period.

Of course, even with these free allocations, peat is not economic at the current level of Public Service Obligation (PSO) subsidy. The assumption made by the EPA (or it?s consultants) in their consultants? report is that any extra costs to the peat-fired power plants resulting from the Emissions Trading Scheme will be covered under the PSO. In other words, the captive electricity consumer will pay. What this would also mean of course is that the peat-fired power plants, the worst polluters in the electricity sector, would be essentially exempt from any of the market forces the ETS is intended to set in operation.

The current PSO is (for 2004) ?58 million. This is anticipated to rise. In addition, the plan envisages a free allocation of over 2Mt, which will have to be paid for by government purchases with taxpayers? money at a cost between ?20million/year (at ?10/t) and ?40 million/year (at ?20/t).

What is particularly interesting about the peat issue is the fact that the combustion of peat is far from best available technology. The peat-fired power plants are essentially being rewarded for their inefficiency.

An interesting question arises about the conversion of peat-fired plants to biomass fuel. All three plants are capable of using biomass for electricity generation; indeed this is included as a condition in their IPC licences. The ETS should be allowed to operate to drive this conversion.

A subsidiary question is should the operators be allowed derive a massive windfall profit from the ETS if they carry out the conversion. We suggest they should not. We believe the Commission?s guidance can assist in this:

2.1.3. Criterion (3) ? Potential to reduce emissions
Quantities of allowances to be allocated shall be consistent with the potential, including the technological potential, of activities covered by this scheme to reduce emissions. Member States may base their distribution of allowances on average emissions of greenhouse gases by product in each activity and achievable progress in each activity.

Introduction
26. No definition or further determination of the term ?potential? has been established, and potential should therefore not be limited to technological potential but may include, inter alia, economic potential. As the technical options available to reduce emissions by a tonne of carbon dioxide as well as the costs of doing so vary between activities, an allocation may be made to reflect that in some cases a reduction can be achieved at lower cost, and in other cases an equivalent reduction may be more costly. The implication is that more might be asked of activities that can make cheaper reductions, and less might be asked of activities whose reductions are expensive.

The above guidance if applied to the peat-fired power plants means that an economic assessment should be made of the conversion of the generating plants to biomass. The allocation if any of emissions trading credits should be made at the necessary level to bring about this conversion and no more.

9. Electricity allocations should take account of reductions in demand resulting from energy conservation measures.

We assume that energy conservation measures will be undertaken by Sustainable Energy Ireland or other government bodies. They should of course in an integrated sustainable electricity regulatory system, be undertaken by the Commission for Electricity Regulation. Unfortunately the CER seems to have no appreciation of emissions issues or sustainable development as applied to electricity policy.

We are astonished that the draft Plan appears to assume that no such measures will be taken.

10. The rules to cover new entrants, known planned development and plant closure are a complex mixture which result in a number of nonsensical situations.

It appears that Cement Roadstone Holdings is being allocated emissions rights for a planned new kiln in Limerick which has not yet been built. The EPA has indicated that if this kiln is not built, the company might lose these rights. Yet it seems that if it closes any other of it?s kilns, it will not lose any of its allocation.

In any case, if a company closes any entire site, it would lose the rights at that site.

The result of all this is that any company with more than one location has an incentive to keep all locations open rather than rationalise production at one location. Cement Roadstone in the above example would benefit by opening the new kiln even if that meant reducing production at other existing kilns. One can easily envisage companies opening new facilities while reducing production at existing facilities.

The fact that under the draft it will be possible to retain one?s existing emissions allocations (and then sell the excess) by maintaining a facility at 5% production while if, on the other hand one closes the facility entirely, there is no emissions allocation is bizarre.

11. Electricity regulation must operate to prevent windfall profits from public services

While this point is not directly within the scope of the National Allocations Plan, it is a matter of public policy which follows from the provisions of the ETS and the NAP and we take this opportunity to emphasise it.

Given the ability of electricity producers to take windfall gains from the operation of the Emissions Trading system, electricity regulation must be altered to prevent these profits being made at the cost of the electricity consumer. In addition, as we have emphasised before, electricity regulation must be altered to support greenhouse gas reduction policies and promote sustainable development.


Attachments

¬? Douthwaite, R., and Healy, D., 2004, Subsidies and Emissions of Greenhouse Gases from Fossil Fuels, (being published by Comhar)
¬? Friends of the Irish Environment, Submission to Review of Implementation of National Climate Change Strategy, 5 May 2003
¬? Friends of the Irish Environment, Strategy to Reduce Emissions of Transboundary Air Pollution by 2010 Submission in response to Discussion Paper , 15 September 2003
¬? Friends of the Irish Environment, Submission in Relation to Carbon Tax, 30 September 2003
¬? Friends of the Irish Environment, Response to Renewable Energy Consultation Document, 27th February 2004


Appendix 1. Dáil Question No. 225 of 19 February 2004

225. Mr. Sargent asked the Minister for the Environment, Heritage and Local Government if the public consultation to be carried out by the EPA, with regard to the national allocation plan for emission allowances, will include consultation in relation to the allocation of emission allowances between the trading and non-trading sectors.

Minister for the Environment, Heritage and Local Government (Mr. Cullen): I refer to the reply to Question No. 436 of 10 February 2004. The Government has determined the allocation of emission allowances between the trading and non-trading sectors, for purposes of the emissions trading scheme under Directive 2003/87/EC, having regard to a consultancy report, Determining the share of National Greenhouse Gas Emissions for Emissions Trading in Ireland, by ICF Consulting, London and Byrne O'Cleirigh, Dublin, which was prepared to underpin decision-making in this regard. Public consultation with all relevant stakeholders was part of the preparatory process which preceded the Government decision. It is now a matter for the EPA to complete the national allocation plan, NAP, including proposed individual allocations to installations eligible to participate in the trading scheme and undertake appropriate consultation prior to its submission to the European Commission by 31 March 2004.
TAXPAYER FUNDS FREE RIDE FOR CO2 INDUSTRIES
The recent announcement by the Minister for the Environment permits Irish industries to continue to emit 96% - 98% of their current carbon dioxide emissions. As the costly emissions credits are being given to industry for free, it is hard to see how the Minister can make good on his 'warning' of July 3, 2003 that 'there would be no free rides'.
Full Text

TAXPAYER FUNDS FREE RIDE FOR GREENHOUSE GAS INDUSTRIES

The recent announcement by the Minister for the Environment permits Irish industries to continue to emit 96% - 98% of their current carbon dioxide emissions.

This will mean the Government will have to purchase 18.5 million tons of carbon dioxide emission credits on the international market in the years 2008 - 2012.

The Government estimates the cost per ton of carbon dioxide emissions at ?10 a ton, but if other countries follow Ireland's lead the price will rise sharply.

FIE calculates the costs could easily reach ?60 a ton, giving a total cost to the taxpayer of ?1.1 billion euro.

As the emissions credits are being given to industry for free, it is hard to see how the Minister can make good on his 'warning' of July 3, 2003 that 'there would be no free rides'.

Based on this announcement, it appears Mr. Cullen would be more suited as Minister for Industry rather than Environment.


Verification and comment: David Healy 01 8324087, 087 6178852

No Free Rides DoELG Press Release of July 3 2004
http://www.environ.ie/DOEI/doeipub.nsf/enSearchView/B0CE3C25AD085CDF80256E300040DE30?OpenDocument&Lang=en
In making this submission we are aware of other submissions having been made by ENGOs including Feasta and Grian. We share a consensus approach with these and other ENGOs and therefore we think that it would neither be necessary nor helpful to rehearse everything which has been said by other NGOs.

5th May 2003


Scope and Format of Submission

In making this submission we are aware of other submissions having been made by ENGOs including Feasta and Grian. We share a consensus approach with these and other ENGOs and therefore we think that it would neither be necessary nor helpful to rehearse everything which has been said by other NGOs. In addition, through our representative on Comhar, we have had input into the submission by Comhar and agree with that submission, with the exception of those comments which reflect the view only of the economic sector in Comhar. Therefore, we have chosen in preparing this submission, to focus on a few areas in which the integration of climate change considerations is particularly lacking. There are a number of attachments to the submission, and we would be grateful if these could be read as part of the submission itself.


Seriousness of issue

The consensus view of Irish ENGOs in relation to the seriousness of climate change as an challenge to current government policy is set out in the statement issued by a number of ENGOs in response to the announcement of Sustaining Progress, the current National Partnership. We attach a copy of that statement for your consideration.


Policy Integration

Climate change policy must be integrated with other elements of government policy. This is not happening. The recent Sustaining Progress agreement is a good example of this failure. As the NGOs point out in the attached statement, climate change is an area which requires an agreed partnership approach. That greenhouse gas emissions were not addressed in the agreement is indicative of a failure to place the climate change strategy at the core of government policy.

At the moment a Mid-term review of the National Development Plan is underway. Furthering the NCCS and compliance with the Kyoto targets do not appear to be central goals of that review.


Transport and Spatial Planning

The clearest example of this failure to integrate policy is transport. This is also the policy area where the relevant government bodies seem most resistant to acknowledging climate change policy.

Many government capital investment programmes determine future energy demand for decades to come. Similarly the conditions under which private capital is invested also often determine future energy demand. This is obviously the case with the heating requirements of buildings for example. The need to control capital investment in building to minimize future energy demand is recognised in government policy (although we would prefer stronger measures).

However, in the area of transport and spatial planning the relevant government agencies seem entirely resistant to integrating energy or greenhouse gas considerations into their policies and programmes. We were concerned about the likelihood that sustainability concerns would not be integrated into the National Development Plan and therefore made a submission to the government in relation to the plan. We attach a copy of that submission. Unfortunately many of the concerns expressed in it are still valid.

The NDP, in particular the roads plans contained in it are in conflict with the NCCS. Since it was published we and other NGOs have repeatedly pointed this out. For instance, we attach a copy of the article "The Roads Frenzy" published in "Telling it Like It Is: 10 years of unsustainable development in Ireland".

Current policies are producing a form of what economists call "lock-in" into particular technologies, in this instance roads-based transport and spatial patterns of development.

There is an ongoing resistance on the part of both the National Roads Authority and the Department of Transport to addressing the greenhouse gas impact of their capital investment programme. Friends of the Irish Environment is one of the nominating bodies to Comhar, which has nominated a representative to the ESIOP Monitoring Committee. This committee monitors the expenditure of funds under the Economic and Social Infrastructure Operational Programme of the NDP, including examining the sustainability and environmental impacts. Comhar's representative on the Committee has raised issues of policy integration, and in particular sought to have the Committee recommend that climate change considerations be integrated into the Mid-term review of the National Development Plan. The relevant recommendations made by Comhar to the Monitoring Committee were:


Recommendation 4
Proposed Recommendation of the ESIOP Monitoring Committee
Add to end of "The Committee notes":
The Committee recommends that consideration of the need to meet Ireland's Kyoto Greenhouse Gas Emission Commitment be integrated into this decision-making process.

Recommendation 8
Proposed Recommendation of the ESIOP Monitoring Committee
Add to end of "The Committee notes":
However the Committee recommends that variable demand modelling be used in all road planning analysis and Environmental Impact Statements and that Environmental Impact Statements include quantitative information on changes in emissions resulting from the scheme.

The response of the Department of Transport has been to reject these recommendations and to express the formal view that investment in transport infrastructure does not affect levels of usage of that infrastructure. In line with this approach, the National Roads Authority and local authorities operating under its aegis refuse to acknowledge induced traffic and carry out transport modelling on the basis of fixed demand models.

In addition, for clarity, we attach a briefing note on induced traffic.


Subsidies to Aviation

The substantial subsidies to internal aviation are socially regressive and environmentally very damaging. These subsidies should be withdrawn, and the money saved used to subsidise the railways.

Peat

The government is well aware to our opposition to the public subsidy to peat-fired electricity. In addition the licensing of Bord na M??na's extraction operations without EIA is in breach of both Irish and EU law, yet no appropriate action has been taken. The cross-subsidy of this most carbon-intensive of fossil fuels indicates a lack of sincerity in the government's stated intention to address climate change.



Note on Induced Traffic for ESIOP Monitoring Committee

Note on Induced Traffic For ESIOP Monitoring Committee

1 Induced traffic

An increase in road capacity leads to an increase in traffic volumes using the routes in relation to which potential time savings have been enabled. This is particularly so in situations of urban congestion.

This phenomenon has been empirically verified in a number of studies and accepted as real by official working groups and review bodies. In the United Kingdom, the Standing Advisory Committee on Trunk Road Assessment (SACTRA) published its report entitled Trunk Roads and the Generation of Traffic in 1994. As a result of this report, all analyses of road proposals in the UK are required to assess the impact of induced traffic which would result from the proposal.


2 SACTRA

The reason for this is clear from the SACTRA report itself. Among its conclusions (see pp. i to iv) are the following:

"Induced traffic can and does occur, probably quite extensively, though its size and significance is likely to vary widely in different circumstances"

"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 of money assessment of the Road Programme"

"Induced traffic is of greatest importance in the following circumstances:
¬? where the network is operating or is expected to operate close to capacity;
¬? where traveller responsiveness to changes in travel times or costs is high, as may occur where trips are suppressed by congestion and then released when the network is improved;
¬? where the implementation of a scheme causes large changes in travel costs."

"Routes should be assessed in their entirety for environmental reasons - decisions on schemes in one part of a corridor should not pre-commit environmentally sensitive decisions elsewhere in the corridor without a thorough economic and environmental appraisal of the overall strategy."

"We recommend that variable demand methods should now become the normal basis of trunk road traffic forecasts, and that these forecasts must be carried through into operational, economic and environmental evaluation of schemes in a systematic way. In particular, where networks are operating close to capacity, suitable procedures must be used to represent the constraint of traffic in the base case and the release of traffic growth in the do-something case as additional capacity is provided."


3 European Conference of Ministers of Transport

Another important report in the area is that of the OECD European Conference of Ministers of Transport, 105th Round Table dealing with Infrastructure-induced Mobility (1996). Its conclusions include the following:

"In the case of new road infrastructure, we can expect to see an average increase in mobility of 10 per cent in the short term and 20 per cent in the longer term, although induced traffic can range anywhere from zero to 40 per cent, depending on circumstances.

"It is nonetheless true that even where the additional traffic has the advantage of better conditions (an obvious benefit to the community), it also contributes to congestion and environmental nuisances. This can erode the perceived benefits, sometimes substantially. The net effect depends on the existing levels of congestion - in areas that are heavily congested, the net benefit will be very much less, if not negative, since the new scheme will only add traffic to an area that is already saturated, with consequence that are all too familiar. In urban areas, new road construction to alleviate congestion is unlikely to be successful, although it will improve accessibility."


4 United States Environmental Protection Agency

Noland (1996) of the U.S. Environmental Protection Agency carried out an analysis of induced traffic within the framework of transport economics. He concluded that

"these results strongly suggest that induced demand effects are real and need to be considered both by planners for specific projects and by policy makers at both the regional and national level."


5 Where does induced traffic come from?

Induced traffic results from one or more of the following:

¬? trips which otherwise would not have been made (or where the demand was previously suppressed by congestion),
¬? trips now made by private motor vehicle which would otherwise have been made by public transport, foot or bicycle,
¬? trips now being made at peak times which would otherwise have been made off peak,
¬? in the longer term, trips resulting from changed land use patterns induced by the road.


6 Policy consequences of induced traffic

The phenomenon of induced traffic means that it is generally impossible to reduce congestion or improve air quality by providing more road space. This conclusion has been extensively demonstrated (Newman and Kenworthy, 1989). This conclusion forms the basis for the shift in transport and traffic policy represented by the Dublin Transportation Initiative Final Report. Furthermore any improvement in the emission rates of individual vehicles resulting from reduced congestion is less than the increase in emissions resulting from increased numbers of vehicle-miles which are induced by the reduction in congestion. (Newman, et al., 1988).


7 Practice in Ireland in relation to induced traffic

Traditionally, induced traffic was never considered by traffic modellers in Ireland. UK policy now requires the use of variable demand models. A UK engineering consultancy has asked the NRA if variable demand modelling should be used for a motorway scheme in Ireland and has been advised not to use it.


8 References

European Conference of Ministers of Transport, 1996, Round Table 105 Infrastructure-induced mobility, OECD Economic Research Centre

Newman, P., Kenworthy, J., and Lyons, T., 1988, Does free-flowing traffic save energy and lower emissions in cities?. Search Vol 19, pp. 267-270

Newman, P., and Kenworthy, J., 1989, Cities and Automobile Dependence, an International Sourcebook, Gower, Aldershot

Noland, R, 1999, Relationships between highway capacity and induced vehicle travel, Paper no. 991096, Paper presented at the 78th Annual Meeting of the Transportation Research Board, www.epa.gov/trb-rn.pdf

Pearce, F., 1997, False forecasts leave cities choking, New Scientist, 8 February 1997

Standing Committee on Trunk Road Assessment (SACTRA), 1994, Trunk Roads and the generation of traffic, Department of Transport, London

David Healy, Comhar
This email address is being protected from spambots. You need JavaScript enabled to view it.

Friends of the Irish Environment has made a brief submission in relation to the government's decision on allocating carbon dioxide emission rights. Unfortunately the EU has required that these rights are given out free under the EU trading system. Our submission points out that certain areas are subsidised and emission reduction here will also save money. Peat-fired electricity and internal aviation are directly subsidised. Transport in general, particularly road transport is indirectly subsidised and externalises its costs
To: Department of the Environment and their consultants

A chairde,

We refer to the recent seminar on the division between trading and non-trading sectors of the economy. The proposal to develop marginal abatement cost curves for greenhouse gas abatement is a worthwhile one. Friends of the Irish Environment wishes to draw your attention to a few issues which arise from this proposal.


Transport

The correct estimation of marginal abatement costs for transport in particular requires internalisation of external costs. There is a substantial body of literature containing estimates of these externalised costs would could be used for the analysis. This would show substantial abatement at negative cost.

The presence of substantial external costs indicates that transport levels are above optimal. Food miles analysis leads to the same conclusion.


Road transport

Claims that various infrastructural improvements reduce congestion and that, by achieving lower emission rates per kilometre, they will lead to overall reductions in emissions are not verified in practice. In practice, congestion acts as a limiting factor on quantity and length of trips. Reducing congestion stimulates demand or releases latent demand. Where the measures to reduce congestion involve an increase in road capacity the result is net higher emission levels. The only infrastructural work which lead to net reductions in emissions are those which reduce road capacity. Therefore claims of emission reductions for Luas, Dart etc. considered on their own when implemented in a situation of road congestion are not correct. We attach a briefing note on induced traffic.


Subsidies.

Friends of the Irish Environment and Feasta have recently produced a report for Comhar on subsidies to greenhouse gas emissions in Ireland. We enclose a pre-publication copy. The most important points for your purpose may be the availability of negative cost emission reduction for internal aviation and for peat-fired electricity even without considering externalised costs. A transparent study must show these options even if other government policies indicate they may not be availed of.

_________________




Note on Induced Traffic

1 Induced traffic

An increase in road capacity leads to an increase in traffic volumes using the routes in relation to which potential time savings have been enabled. This is particularly so in situations of urban congestion.

This phenomenon has been empirically verified in a number of studies and accepted as real by official working groups and review bodies. In the United Kingdom, the Standing Advisory Committee on Trunk Road Assessment (SACTRA) published its report entitled Trunk Roads and the Generation of Traffic in 1994. As a result of this report, all analyses of road proposals in the UK are required to assess the impact of induced traffic which would result from the proposal.


2 SACTRA

The reason for this is clear from the SACTRA report itself. Among its conclusions (see pp. i to iv) are the following:

?Induced traffic can and does occur, probably quite extensively, though its size and significance is likely to vary widely in different circumstances?

?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 of money assessment of the Road Programme?

?Induced traffic is of greatest importance in the following circumstances:
¬? where the network is operating or is expected to operate close to capacity;
¬? where traveller responsiveness to changes in travel times or costs is high, as may occur where trips are suppressed by congestion and then released when the network is improved;
¬? where the implementation of a scheme causes large changes in travel costs.?

?Routes should be assessed in their entirety for environmental reasons - decisions on schemes in one part of a corridor should not pre-commit environmentally sensitive decisions elsewhere in the corridor without a thorough economic and environmental appraisal of the overall strategy.?

?We recommend that variable demand methods should now become the normal basis of trunk road traffic forecasts, and that these forecasts must be carried through into operational, economic and environmental evaluation of schemes in a systematic way. In particular, where networks are operating close to capacity, suitable procedures must be used to represent the constraint of traffic in the base case and the release of traffic growth in the do-something case as additional capacity is provided.?


3 European Conference of Ministers of Transport

Another important report in the area is that of the OECD European Conference of Ministers of Transport, 105th Round Table dealing with Infrastructure-induced Mobility (1996). Its conclusions include the following:

?In the case of new road infrastructure, we can expect to see an average increase in mobility of 10 per cent in the short term and 20 per cent in the longer term, although induced traffic can range anywhere from zero to 40 per cent, depending on circumstances.

?It is nonetheless true that even where the additional traffic has the advantage of better conditions (an obvious benefit to the community), it also contributes to congestion and environmental nuisances. This can erode the perceived benefits, sometimes substantially. The net effect depends on the existing levels of congestion - in areas that are heavily congested, the net benefit will be very much less, if not negative, since the new scheme will only add traffic to an area that is already saturated, with consequence that are all too familiar. In urban areas, new road construction to alleviate congestion is unlikely to be successful, although it will improve accessibility.?


4 United States Environmental Protection Agency

Noland (1996) of the U.S. Environmental Protection Agency carried out an analysis of induced traffic within the framework of transport economics. He concluded that

?these results strongly suggest that induced demand effects are real and need to be considered both by planners for specific projects and by policy makers at both the regional and national level.?


5 Where does induced traffic come from?

Induced traffic results from one or more of the following:

¬? trips which otherwise would not have been made (or where the demand was previously suppressed by congestion),
¬? trips now made by private motor vehicle which would otherwise have been made by public transport, foot or bicycle,
¬? trips now being made at peak times which would otherwise have been made off peak,
¬? in the longer term, trips resulting from changed land use patterns induced by the road.


6 Policy consequences of induced traffic

The phenomenon of induced traffic means that it is generally impossible to reduce congestion or improve air quality by providing more road space. This conclusion has been extensively demonstrated (Newman and Kenworthy, 1989). This conclusion forms the basis for the shift in transport and traffic policy represented by the Dublin Transportation Initiative Final Report. Furthermore any improvement in the emission rates of individual vehicles resulting from reduced congestion is less than the increase in emissions resulting from increased numbers of vehicle-miles which are induced by the reduction in congestion. (Newman, et al., 1988).



7 Practice in Ireland in relation to induced traffic

Traditionally, induced traffic was never considered by traffic modellers in Ireland. UK policy now requires the use of variable demand models. A UK engineering consultancy has asked the NRA if variable demand modelling should be used for a motorway scheme in Ireland and has been advised not to use it.


8 References

European Conference of Ministers of Transport, 1996, Round Table 105 Infrastructure-induced mobility, OECD Economic Research Centre

Newman, P., Kenworthy, J., and Lyons, T., 1988, Does free-flowing traffic save energy and lower emissions in cities?. Search Vol 19, pp. 267-270

Newman, P., and Kenworthy, J., 1989, Cities and Automobile Dependence, an International Sourcebook, Gower, Aldershot

Noland, R, 1999, Relationships between highway capacity and induced vehicle travel, Paper no. 991096, Paper presented at the 78th Annual Meeting of the Transportation Research Board, www.epa.gov/trb-rn.pdf

Pearce, F., 1997, False forecasts leave cities choking, New Scientist, 8 February 1997

Standing Committee on Trunk Road Assessment (SACTRA), 1994, Trunk Roads and the generation of traffic, Department of Transport, London