Representation by CPRE Peak District and South Yorkshire (CPRE Peak District and South Yorkshire)
- Date submitted
- 14 September 2021
- Submitted by
- Other statutory consultees
We object to TRO10034 for the following reasons: Increasing road capacity is not the solution. Congestion and environmental pollution are caused by a majority of local commuters and a minority of through traffic of heavy lorries. Controlling the latter with a National Park-wide weight restriction, coupled with sustainable transport measures and technological improvements would bring lasting benefits and avoid the adverse impacts below. Highways England rejected this option in 2015. Far reaching changes since then - the declaration of a climate emergency; the Covid-19 pandemic; and revised Treasury rules to assess the value of new roads - make proper development of this option essential. The scheme would increase traffic, diverting some from the M62. The benefits to most of Mottram (but not all) come at the expense of the rest of Longdendale and Glossopdale where traffic increases on many residential roads. This is contrary to national policies for modal shift to walking, cycling and public transport. Road accidents would increase (102 extra collisions over 60 years) across the rest of the network. On the A57 Snake Pass, a high risk road for a fatal or serious injury crash, there would be an extra 160 extra collisions. Safety must not be compromised. Over 60 years the scheme would add an extra 399,867tCO2e. Carbon emissions must be tested against international and national legislation and guidance including the Paris agreement, the 2008 Climate Change Act’s legally binding target of net-zero carbon emissions by 2050, the UK Sixth Carbon Budget, and the National Planning Policy Framework which requires ‘radical reductions of greenhouse gas emissions’. Air pollution improves for some, for others NO2 remains above the legal limit e.g. on Market Street in Hollingworth. For one property on Dinting Vale air pollution gets worse. The AQMAs in Tintwistle and Glossop would remain. The Greater Manchester Clean Air Zone has been excluded from the air quality modelling but could lead to diversions to avoid paying the toll, creating congestion and pollution outside the Zone. Local countryside, highly valued for its natural undeveloped character, open views, tranquillity and recreation opportunities, would be urbanised. The scheme is inappropriate development in the Green Belt for which there are no ’very special circumstances’ for it to proceed. The impacts on the rich and diverse wildlife are minimised because species are considered only of ‘local value’. More traffic on routes crossing the Peak District National Park would erode its special qualities. National Park statutory purposes require the Park to be conserved and enhanced. National policy requires trunk road traffic to avoid National Parks. The transport appraisal and modelling must be scrutinised through the examination in order to ensure public confidence in the results. The modelling is based on data, assumptions and projections from before the legal acceptance of the new carbon budget and transport decarbonisation strategy and must be updated to reflect them. Cumulative effects of the scheme e.g. on the congested M60 J24 interchange, and with development in South Yorkshire and in Greater Manchester, are omitted or misrepresented.