Representation by Friends of the Earth England, Wales and Northern Ireland (Friends of the Earth England, Wales and Northern Ireland )
- Date submitted
- 15 September 2021
- Submitted by
- Non-statutory organisations
We object to the scheme for the following reasons: 1. Over 60 years the scheme would add an extra 399,867 tonnes carbon dioxide. Carbon emissions must be tested against international and national legislation and guidance including the Paris Agreement, the 2008 Climate Change Act and UK Sixth Carbon Budget that legally commits the UK to a 78% reduction in emissions (compared to 1990 levels) by 2035, and the National Planning Policy Framework which requires “radical reductions of greenhouse gas emissions”. The Committee on Climate Change’s 2021 Progress Report states “Decisions on investment in roads should be contingent on analysis justifying how they contribute to the UK’s pathway to Net Zero. This analysis should demonstrate that the proposals would not lead to increases in overall emissions”. 2. The scheme would increase traffic. The benefits to Mottram (but not those on Market Street or near the new underpass) come at the expense of the rest of Longdendale and Glossopdale where traffic increases on many residential roads. This does not comply with national policies for climate change and modal shift to walking, cycling and public transport. 3. Air pollution improves for some households but for others nitrogen dioxide remains above the legal limit. The Air Quality Management Areas in Tintwistle and Glossop would remain. The Greater Manchester Clean Air Zone has been excluded from the air quality modelling therefore its impacts on traffic flows and routes have not been included in air pollution assessments of the scheme. 5. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and of protected species, such as bats and barn owls. The impacts on the rich and diverse wildlife are minimised because species are considered only of ‘local value’. Local countryside, highly valued for its natural, undeveloped character and open views, would be urbanised and the Green Belt would be bisected. 6. Genuine solutions for congestion, air pollution and climate emissions should be pursued instead of building new road capacity – for example a ban on lorries, sustainable transport measures, and technological improvements. These measures would bring lasting benefits and avoid adverse impacts. Highways England rejected this option in 2015. Far reaching changes since then - as the climate crisis has come to the fore, the impacts of the Covid-19 pandemic, and a review of the Treasury’s rules to assess the value of roads - make scrutiny of this option essential. 7. The Peak District National Park is a haven for wildlife, carbon storage and a place where everyone can get outdoors and enjoy nature. More traffic on roads would harm these special qualities. National policy requires trunk road traffic to avoid National Parks. 8. The transport appraisal and modelling must be made available and 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 Covid pandemic and must be updated to reflect recent and future levels of home-working and the shift towards virtual meetings.