Representation by Transport Action Network (Transport Action Network)
- Date submitted
- 16 September 2021
- Submitted by
- Non-statutory organisations
Transport Action Network (TAN) wishes to register its objection to the A57 Link Roads scheme for the following reasons: The proposed scheme will increase traffic which will increase pressure for more road building in the Peak District National Park. The scheme will increase carbon emissions by a minimum of 438,837 additional tonnes of CO2e, according to National Highways calculations. This figure is arrived at by adding the extra user emissions generated by the scheme estimated to be 399,867 tonnes CO2e and the construction emissions estimated to be 38,970 tonnes CO2e. This does not include the emissions resulting from site clearance and tree felling or land use change or many other aspects. The monetised cost of the additional carbon resulting from the scheme is given as -£17.4m at paragraph 5.2.21 of the Case for the Scheme. However, this does not use the new carbon values published by BEIS on 2 September 2021 which quadrupled the cost of carbon. The increase in collisions: National Highways predict there will be 102 extra collisions over the 60 year appraisal period for the scheme. However on the A57 Snake Pass, already a very dangerous road with a high collision rate, due in part to its elevation, extreme weather conditions and sharp bends, there would be an extra 160 collisions over 60 years due to the increase in traffic caused by the scheme. The Combined Modelling and Appraisal Report appears to be missing from the draft DCO application, nor is there an Appraisal Summary Table showing the impacts of the scheme over the 60 year appraisal period, and their monetised costs and benefits. There has been inadequate consultation on this scheme. The traffic data for the scheme was not available during the consultation stage which has denied people the opportunity to make an informed response. This critical data, which shows increases in traffic on many roads, was only made available in the draft DCO application documentation. Alternatives to the scheme have not been adequately assessed, including non-roadbuilding alternatives such as detrunking the A628, implementing an HGV ban in the National Park, and redirecting traffic via the motorway network. It is inconsistent with national planning policy (NPPF and NPSNN) to direct extra traffic through a National Park. The impact on the landscape and the Peak District National Park