Representation by Friends of the Lake District (Friends of the Lake District)
- Date submitted
- 25 August 2022
- Submitted by
- Non-statutory organisations
Friends of the Lake District (FLD) is the only membership organisation dedicated to protecting and enhancing Lake District and Cumbrian landscapes FLD objects to this proposed project. The Benefit Cost Ratio (BCR) for the whole road is 0.92. This puts the A66 upgrade in the bottom 1% of value for money of all transport infrastructure projects assessed by the DfT 2015-2019. This is a questionable project to be brought forward and paid for by the public purse during a cost of living crisis, high interest rates and recession when it does not break even on overall benefits. It is difficult to square the climate emergency with these proposals which will emit 518,562 tonnes of CO2 during construction and 2,190,452 tonnes over its lifetime. The value of cumulative carbon emissions from the scheme has not been used in the BCR calculations because no cumulative assessment has been done. This will make reaching the UK’s legally binding 68% carbon reductions by 2030 and reaching net zero even harder. As the Benefits to Cost ratio is under 1, then harm to landscape, tranquillity, wildlife, heritage and local residents’ quality of life will not be outweighed by the benefits of the road and cannot be justified. The NNNPS states “There is a strong presumption against any significant road widening …in… Areas of Outstanding Natural beauty, unless it can be shown there are compelling reasons for the new or enhanced capacity and with any benefits outweighing the costs very significantly.” Research demonstrates that upgraded roads induce traffic, increase demand and cause more CO2 emissions. FLD has consistently pointed out that road safety could be improved significantly on single carriageway sections of the A66 without needing to dual through and adjacent to an AONB in open countryside. These measures include better junctions, underpasses and bridges for local traffic, and speed limits. As this upgrade is for freight, a 70mph speed limit is unnecessary as freight is limited to 60mph. Bringing the speed limit down would reduce accidents less destructively and more cheaply than building a dual carriageway as well as saving millions of tonnes of CO2. There will be a loss of tranquillity due to increased traffic and faster vehicles and significant visual intrusion of major road infrastructure into open countryside. The long term damage to tranquillity and negative visual impact on the landscape of the North Pennines AONB and its setting is acknowledged in the ES, but cannot be adequately mitigated meaning that this project will leave a legacy of landscape harm. The scheme would directly impact on the River Eden Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI), many hedgerows, mature trees and the habitats of endangered species. FLD had no contact from National Highways/Highways England between 2018 and 2021 despite having previously been part of the stakeholder group. Minutes in Environmental Statement 3.4 Appendix 1.1 show that there were no non-statutory organisations involved in pre DCO consultation. It is concerning that the consultation process appears to have broken down.