Transport Insights

The Office of Rail and Road’s (ORR) Annual Assessment of National Highways’ performance: end of the second road period April 2020 to March 2025 has details of the company’s performance against KPIs on environmental issues and it’s a bio-diverse picture to say the least.

Cutting corporate carbon emissions is one KPI where the company has failed and failed badly; it’s also a measure where I have been tracking the moving of the goalposts for sometime, and have indeed contributed to the moving of the goalposts.

In 2023 I reported that the company was claiming to have a mechanism for reporting against its target of a 75% cut against a 2017-18 baseline that amounted to a one-way bet. The expected cut was mainly because the expected decarbonisation of electricity from the grid.

National Highways claimed to have reached a backroom deal with the government whereby its emissions were based on forecasts of the carbon intensity of electricity, even if they had been proved wrong.

This was news to the government and a few months later it announced that the calculation methodology would remain based on actual emissions, but the target would be reduced to a 67% cut. It said this wouldn’t make the easier to achieve, which was an interesting spin to say the least.

The latest ORR report notes that last year the government reduced the target again – to 56%. But…

At the end of RP2, National Highways achieved a 51% reduction in its corporate carbon emissions compared to the baseline. Therefore, the company did not meet this KPI target of a 56% reduction for the road period.

And the ORR notes that it challenged National Highways to speed up its move to LED lighting but it refused. So it ended up with a 51% cut against an original target of 75%.

The outcome on the company’s air quality KPI is more murky. The ORR notes that there wasn’t really a target figure for this KPI but that it was required to bring 128 sections of the SRN exceeding legal limits for nitrogen dioxide into legal compliance in the shortest time possible.  

At the end of the road period, there remain 19 sections that exceeded the legal limit for nitrogen dioxide.

Again the regulator gives the company a free pass:

Based on the evidence, and engagement with JAQU, we consider that the company made all reasonable efforts to deliver its obligations on air quality.

See how they switched from legal compliance to all reasonable efforts when the bottom line is that the company is breaking a law that does not consider how reasonable your efforts are?

On biodiversity, the picture is complicated by moving of goalposts, and not necessarily in the way you might expect.

National Highways’ target was to deliver no net loss in biodiversity by the end of RP2. The company estimated that without any additional biodiversity mitigation, there would be a loss of 6,148 biodiversity units over the road period.

National Highways responded well to our challenge earlier in RP2, when it was forecasting to miss its target. By developing and delivering a pipeline of biodiversity schemes, the company performed well against this KPI. It delivered a total of 6,744 biodiversity units, resulting in a net gain of 596 biodiversity units. It therefore exceeded its target to achieve no net loss in biodiversity by the end of the road period.

But last year the equivalent report said National Highways was forecasting a loss of 5,467 biodiversity units over RP2, but was promising a net gain of 2,814 units, which would have meant delivering 8,281 units.

So over the year, the company appears to have made its target of no net loss harder to achieve and still beaten it, despite falling 1,537 units short of its pledged total and more than 2,000 short of its pledged overshoot versus the target.

But hold on a minute. In the company’s Interim Period Delivery Plan: April 2025 – March 2026 it has a target to

Record the delivery of 1,169 Biodiversity Units during 2025-26. These are units that have been delivered during 2024-25 but are currently subject to assurance and validation.

It could be that these will eventually be added to the total but, given that National Highways, which always gets to mark its own homework on this, claims here that they “have been delivered during 2024-25”, suggest that it is claiming the delivery of units that have not been validated.

Obviously, if that is the case, the company could in fact have missed its KPI target.