Representation by Campaign for National Parks (Campaign for National Parks)
- Date submitted
- 23 August 2022
- Submitted by
- Non-statutory organisations
We object to TRO10062 for the following reasons: The proposal fails to take account of the additional protections that apply in National Parks and Areas of Outstanding Natural Beauty (AONBs) and the duty that all public bodies have to take account of the potential effect of their decisions and activities on the statutory purposes for these areas, including activities undertaken outside their boundaries which may affect land within them. The construction of bridges, embankments and other infrastructure would damage the landscape and setting of the North Pennines AONB. Creating extra capacity on the A66 to the east of the M6 would also lead to increased pressure to dual or widen non-dualled sections of the route to the west of the M6, within the Lake District National Park. The proposal is, therefore, incompatible with the long-established presumption against significant road widening or the building of new roads in National Parks and AONBs “unless it can be shown there are compelling reasons for the new or enhanced capacity and with any benefits outweighing the costs very significantly. Planning of the Strategic Road Network should encourage routes that avoid National Parks, the Broads and Areas of Outstanding Natural Beauty.” (paragraph 5.152, the National Policy Statement for National Networks). It is also incompatible with the general presumption against major development in National Parks and AONBs and the additional protection for the settings of these areas set out in the National Planning Policy Framework. National Highways own assessment makes it clear that the proposal represents extremely poor value for money with a benefit-cost ratio of less than 1 even before the current increased level of inflation is taken into account. This makes the scheme completely inappropriate during a time of constrained public resources and a cost-of-living crisis. The benefits clearly do not outweigh the costs very significantly as national policy requires for roadbuilding to even be considered in such a sensitive location. The scheme is also completely incompatible with the urgent need to tackle the climate emergency and the UK’s international and national commitments to reduce carbon emissions including the Paris agreement, the 2008 Climate Change Act, the legally binding target of net-zero carbon emissions by 2050, the UK Sixth Carbon Budget, and a National Planning Policy Framework which calls for ‘radical reductions of greenhouse gas emissions’. National Highways’ own figures show that the project will generate over two million extra tonnes of carbon over the 60 year appraisal period (Table 7.23, Environmental Statement Chapter 7). National Highways has failed to give adequate consideration to smaller scale solutions and has instead focused entirely on dualling. Far more attention should have been given to identifying options which do not require extensive additional roadbuilding. We recognise that there are safety issues that need to be addressed at particular locations along the A66 Trans-Pennine corridor but we believe that National Highways should be developing alternative ways of addressing these issues such as reduced speed limits, junction improvements and the use of underpasses for farm crossings.