Representation by Transport Action Network (Transport Action Network)
- Date submitted
- 4 November 2022
- Submitted by
- Members of the public/businesses
Transport Action Network (TAN) wishes to register as an Interested Party for the A12-A120 examination and we OBJECT on the following grounds: Climate change - The construction emissions total 428,626 tCO2e (APP-082, Table 15-21) all within the fourth carbon budget, when we need to make 68% cuts by 2030 to meet our Nationally Determined Contribution (NDC) under the Paris Agreement. The user emissions from extra traffic over the 60-year lifetime of the scheme are 1,535,559 tCO2e (APP-082, Table 15-22), giving a total of 1,964,185 tonnes of extra carbon emissions caused by this scheme. This is completely unacceptable when we need to do all we can to urgently reduce emissions. The DCO should be rejected on this basis alone. Not good value for money - The scheme has an estimated cost of up to £1.3 billion (APP-043, 2.1.1). This is likely to be an underestimate given optimism bias in scheme appraisal and current high levels of construction inflation. The scheme has an adjusted benefit cost ratio (BCR) of only 1.7 (APP-261, Table 11-12), delivering only ‘medium’ value for money according to the DfT’s value for money framework. Due to inflation and optimism bias we estimate the likely outturn cost could easily be in excess of £1.5 billion, bringing the BCR down even lower. The country cannot afford expensive and unnecessary schemes that drive up traffic and carbon emissions, whilst destroying biodiversity. Biodiversity - The scheme would destroy 45 hectares of woodland (APP-076, 9.11.91), potential veteran trees (APP-076, 9.11.58), and 16km of hedgerows (APP-076, 9.11.87). It would adversely impact on ancient woodland, including Perry’s Wood nature reserve. Protected species that would be adversely impacted include bats, badgers, otters, brown hare, hedgehogs, barn owls, breeding and wintering birds, common reptiles, and great crested newts. Loss of farmland - There would be a loss of 474 hectares of arable farmland to the scheme (APP-076, Table 9.23), adversely impacting on the UK’s food security. Air quality - The scheme would lead to an increase in air pollution which is harmful for both human health and biodiversity. NOx would increase by an extra 2,599 tonnes, and PM10/PM2.5 by 318 tonnes (APP-266, page 11) Noise pollution - There would be an increase in noise pollution, due to increased traffic and speeds, with 3,911 households suffering from increased daytime noise limits is, and 3,664 household with increased noise at night (APP-266, Table 2-1). Poor active travel provision - The provision for active travel is poor for with sharp turns and multiple crossings, many of which do not look like they are LTN 1/20 compliant. The active travel provision is often badly designed, unattractive and inconvenient. Increased severance - There would be increased severance for people walking and cycling, sending them on long detours or complicated and awkward crossings Cultural heritage - There will be an adverse impact on heritage assets including grade I, grade II* and grade II listed buildings.