Representation by Peak District National Park Authority (Peak District National Park Authority)
- Date submitted
- 16 September 2021
- Submitted by
- Other statutory consultees
The Peak District National Park (PDNP) lies to the east of the scheme; therefore, none of the works have a direct impact. However, the Environmental Statement (ES) raises concerns for the Peak District National Park Authority (PDNPA) regarding the indirect effects of the scheme. These effects are due to increased traffic flows, principally on the A628 Woodhead and A57 Snake Passes. Forecasts indicate that the A628 Woodhead Pass will see a daily increase in traffic of 850-950 vehicles (2025) and 900-1,100 vehicles (2040); the A57 Snake Pass will see an increase in vehicles of 1,150 (2025) and 1,450 (2040). This growth in traffic may negatively affect the Special Qualities of the PDNP, whilst impacting on the achievement of the Authority’s Statutory Purposes (Section 61, Environment Act, 1995). We have concerns regarding the effects of the scheme on the following: - 1) Air Quality a) Tintwistle AQMA –is acknowledged within the ES, however, there is no assessment of the effects of the predicted increased traffic flows on it. b) Designated sites (A628) – are already subject to high traffic flow and associated Nitrate deposition. Whilst predicted increased flows for 2025 do not meet the 1,000-vehicle threshold, we believe that an assessment of impact should have been undertaken. 2) Cultural Heritage a) Tintwistle Conservation Area (TCA) – will see a slight increase in traffic. The ES suggests a ‘non-significant, neutral, residual effect’. This will, however, have an adverse effect on how the TCA is experienced. b) Heritage Assets (A57) – the increase in traffic on the Snake Pass is significant (38%). The ES (Table 7.32) describes this as a ‘slight increase’ (VP23) indicating no change to the Special Qualities of the PDNP. Heritage assets are part of the attraction for people to the area. They include the Ladybower Reservoir and a significant cluster of scheduled monuments (Hordron Edge, Bamford Edge, Crook Hill and Bridgend Pasture). Increased traffic flows could impact adversely on the enjoyment and experience of these important monuments within their landscape setting. 3) Landscape and visual We are concerned with how the indirect landscape impacts (increased traffic flow) of the scheme have been assessed. National Policy seeks to ensure that road schemes and their effects are thoroughly assessed to avoid or minimise impacts on NPs. We don’t believe that appropriate landscape receptors have been adequately defined at the correct level of detail to determine indirect landscape effects (on character and perceptual aspects such as tranquillity, wildness, remoteness etc) within the PDNP. Where negative impacts have been recognised, ‘slight adverse’ effects are not considered to be material. In the case of NPs we believe that slight adverse effects are a material consideration. This is particularly pertinent due to the cumulative harm caused by additional traffic flows on what are already busy roads through affected valleys. 4) Biodiversity a) Nitrate deposition –see point 1b. b) Noise disturbance and wildlife collision – have been screened out for the A628 SPA/ SAC. However, increases in traffic, especially HGV’s, will create more constant noise and provide less breaks in the traffic, meaning that there is likely to be more potential for collision. The fragmentation of habitat will also lead to more collision risk and fatalities. Increased roadkill will attract more predators and has the potential to impact on ground nesting birds. The increase in background noise generated by additional traffic is also likely to add to the general disturbance of ground nesting birds, potentially reducing the area of usable habitat. We believe that these impacts should be reassessed taking the above into account. 5) Noise and vibration a) Effects on designated sites –see point 4b b) Effects on quiet enjoyment –existing traffic levels on the A628 Woodhead and A57 Snake Passes have a negative impact on the tranquillity of the surrounding open countryside, with traffic noise being a major feature. Increased levels of traffic along these routes will further reduce tranquillity, especially for those using the trails or footpaths that parallel or cross these busy roads (e.g. Pennine Way, Pennine Bridleway, Trans Pennine Trail (TPT)). 6) Population and health a) Severance –the A628 Woodhead and A57 Snake Passes are crossed at various points by footpaths and trails (see 5b). Crossing points are already difficult and, any increase in traffic for either route is likely to worsen conditions. Loss of tranquillity and increased severance will negatively affect the enjoyment of the PDNP by users of these routes, with an adverse impact on the Authority’s second statutory purpose. b) Road safety – the ES indicates that the scheme will result in an increase in RTCs along the Snake Pass. Given the geography of the road it’s is likely that any collisions are more likely to be severe than slight. The human cost of such events is devastating for those involved. It is also likely that any increase in collisions will require remedial works that will in turn negatively impact on the landscape of the PDNP. 7) Climate The ES contains detailed consideration of the physical effects of climate change on the scheme that appear robust and thorough. However, consideration of the schemes contribution to climate change is not analysed with an equivalent rigour. The summary of the effects of the scheme on Climate Change appear simplistic and do not offer an adequate assessment; as it is inevitable that almost all individual site or project-based greenhouse gas emissions will appear insignificant when compared to the National Carbon Budget and reduction targets. By extension, it also suggests that all individual GHG emissions can be ignored due to their relative scale when compared to National Targets; an approach which would not be considered acceptable in other areas of activity. The summary suggests that the scheme in isolation is unlikely to produce significant effects on the climate. However, it should not be considered in isolation but as part of an accumulative process that is changing the climate and damaging the environment. We would suggest that a more local assessment of impact is undertaken to consider the emissions in relation to those who are likely to benefit from the scheme and the immediate area where its impact will be felt, would be more appropriate. 8) Cumulative Impacts Our submission focusses on the indirect impacts of the scheme on the PDNP. Some of these impacts have been assessed as minor or insignificant within the ES. However, we are particularly concerned about the cumulative impacts of the scheme on the following: - a) Tintwistle – increased traffic flows through the village are likely to worsen air quality and noise & vibration; increase severance and effect experience of the TCA. b) Designated sites – increased traffic flows are likely to increase nitrate deposition, noise disturbance and collisions with wildlife. It is of particular concern that the effects of the increase in traffic on the A628 have not been assessed in relation to these impacts. c) Quiet enjoyment – increased traffic flow will affect both tranquillity and the quiet enjoyment of the landscape. It is also likely to negatively affect the use of important multi-user routes due to the increased difficulty of using crossing points.