Representation by Peter Simon
- Date submitted
- 14 September 2021
- Submitted by
- Members of the public/businesses
I oppose the DCO Application for reasons given here in summary . 1. On balance the scheme fails to establish a benefit that outweighs the considerable adverse impacts. In particular the scheme is unworkable with unsustainable impacts at its Eastern end due to inscreased traffic flows on a constrained road network. 2. The Applications "Case for the Scheme" (CftS_ attempts but fails to establish necessary compliance with NN NPS (National Networks National Policy Statement 2008) and the NPPF with subsequent revisions (National Planning Policy Framework 2012). 3. The case for NN NPS compliance does not hold with regard to loss of Green Belt through the scheme, as no overall benefit is established (see 1) and no alternatives are considered. There are other GB issues unresolved in the CftS because cumulative and associated loss in Tameside exceeds that stated and assessed. 4. Local Policy is also a consideration. 5. The CftS climate impact assessment method predates formal national regional and local climate emergency declarations (2019) so should not be considered fit for purpose for such an assessment now. When government net zero carbon targets were set a cumulative rather than scheme specific assessment become appropriate and the application would then fail on this count. 6. Further the CftS fails to resolve ambiguities within the scheme proposal as a whole, such as possible future requirement for "A628 climbing lanes" within the National Park and the relevance of a future probable Clean Air Zone designation. Inclusion or exclusion of such matters is clearly needed to allow for a safe test of traffic model data, impacts and thus merit or otherwise of the scheme. 7. The bio-diversity loss due to the scheme is unacceptable and mitigation proposals are not plausible or sufficient. 8. PINS Advice note 17 informs the CftS assessment Section 6 Planning History etc but this is discretionary. I wish to suggest that the binding annual OAN new build quota within the plan period would be a particularly reliable indicator of planning "certainty" (eg for Glossopdale within High Peak Borough) and should have been included for a safe assessment of cumulative impact in any CftS and Environment Statement. 9. Although within the proximity of the scheme the impacts on Glossopdale are not properly considered. No transport plan for the settlement is offered. 10. The 2020 winter scheme consultation was inadequate as no critical traffic model data was available to public or statutory consultees. This renders all responses unqualified in this respect open to question as to their validity. 11. Similarly the consultation was held inappropriately at the height of an exceptional state of health emergency. It was threadbare and fragmented in the extreme which compounds the concern that due process was not followed. Similarly a significant postcode demographic including my own address were excluded from a mail shot for cost reasons, which I regard as discriminatory and unacceptable. 12. Such other matters as may arise.