Representation by Transport Action Network (Transport Action Network)
- Date submitted
- 20 August 2022
- Submitted by
- Non-statutory organisations
Transport Action Network would like to register as an Interested Party for the A66 Examination. The proposed scheme would 1) increase traffic growth and carbon emissions by 2,190,452 tonnes over its lifetime; 2) increase emissions from its construction by at least an additional 518,562 tonnes, all within the critical fourth carbon budget when we need to achieve 68% reductions in UK carbon emissions by 2030 under our legally binding commitments under the Paris Agreement; 3) in total, increase emissions by 2,709,014 tonnes, taking us backwards on achieving net zero; 4) directly impact on the River Eden Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI), and the habitats of many endangered species; 5) directly impact on the North Pennines Area of Outstanding Natural Beauty (AONB) and its setting; 6) air pollution and noise pollution which will have direct and indirect impacts on humans, the AONB, SAC, SSSI and species, and the Yorkshire Dales National Park; 7) increase severance of local communities and the rights of way network; 8) impact on heritage assets. The huge environmental harm and economic cost of the scheme cannot be justified as the Combined Modelling and Appraisal Report shows that the scheme has a Benefit Cost Ratio of under one, which is classed as “poor” value for money by the DfT’s Value for Money Framework. This shows the scheme would cost more than it would ever deliver in benefits. The calculated emissions from constructing the scheme have been significantly reduced since the statutory consultation (down from 1.4 million tonnes to 518,562 tonnes). The methodology that the Applicant has adopted to minimise the carbon footprint from the construction of this scheme needs to be thoroughly scrutinised. We are also concerned about the secretive consultations, with the consultation documents not publicised and inaccessible unless you had been given the web link. This made it very difficult to fully assess the impacts of the scheme, and to comment. For these reasons we believe that the DCO application is premature. Non-roadbuilding alternative options have not been properly assessed such as reducing speed limits and moving freight onto rail, or small-scale engineering solutions that increase safety.