Representation by Campaign for National Parks (Campaign for National Parks)
- 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. There is evidence that road schemes justified on the basis of reduced journey times fail to deliver the promised economic benefits and road-building is particularly damaging in areas in or close to National Parks where the economy is heavily dependent on a high quality environment. Full consideration should be given to adopting alternative solutions to the traffic and congestion problems in this area before any consent is given to road-building. For example a National Park-wide weight restriction in conjunction with sustainable transport measures and technological improvements would bring lasting benefits and avoid the adverse impacts below. The Covid-19 pandemic has had a significant impact on our working and travelling patterns and the focus should now be on developing future travel options which encourage people to use alternatives to the car. The scheme is completely incompatible with the urgent need to tackle the climate emergency and the UK’s international and national commitments to reduce carbon emissions including the Paris agreement, the 2008 Climate Change Act, the 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’. Over 60 years the scheme would add an extra 399,867tCO2e. The scheme would damage the special qualities of the Peak District National Park and is incompatible with the statutory purposes of National Parks which are our finest landscapes with the highest level of protection. There is a long-established presumption against significant road widening or the building of new roads in National Parks “unless it can be shown there are compelling reasons for the new or enhanced capacity and with any benefits outweighing the costs very significantly” (paragraph 5.152 of the National Policy Statement for National Networks). It would also damage areas of local countryside which are highly valued for their natural undeveloped character, open views, tranquillity and recreational opportunities. By causing some traffic to divert from the M62, the scheme would result in increased traffic on many residential roads in Longdendale and Glossopdale. This undermines national policies to encourage walking, cycling and public transport for local journeys. It would also result in increased traffic on trans-Pennine routes through the National Park which is contrary to national policy. Furthermore, this increased traffic would lead to increases in collisions, particularly on cross-Park routes such as the A57 Snake Pass which already experience high levels of fatal and serious collisions. 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 publication of the Transport Decarbonisation Strategy. It must therefore be updated to reflect them.