Representation by Cumbria County Council (Cumbria County Council)
- Date submitted
- 2 September 2022
- Submitted by
- Local authorities
Application by National Highways for an Order Granting Development Consent for the A66 Northern Trans-Pennine Project (“the Project”) (also referred to as the A66 Trans-Pennine Dualling Project) Relevant Representation of Cumbria County Council This representation is made by Cumbria County Council (“the Council”) to explain in summary the matters that it wishes to raise and have considered during the Examination. The Council has been working closely with Eden District Council during the pre-application stage of the Project supported by a Planning Performance Agreement (“PPA”) with National Highways and currently intends to submit a joint Local Impact Report (“LIR”) at the appropriate stage of the Examination process. A draft LIR has been prepared, which identifies the impacts which officers consider to be the most significant. However, the LIR will need to be formally approved by each local authority and consequently there may be additional matters which are raised. Until the submission of the application for the Project the Council was adequately resourced through the PPA to respond to the consultations and engagement with National Highways. Since then, there has been minimal support and the Council has lacked the resources to carry out a review of the application documents. It is not clear therefore, if the Project as submitted has addressed the Council’s concerns which were raised in consultation responses. The Council has been left with no alternative but to raise these issues in this representation and set them out in more detail within the accompanying Principal Areas of Disagreement Summary Statement (“PADSS”). There is a need to resolve this resourcing issue to enable the Council to engage effectively with National Highways, engage in the application process and contribute to the detailed design of the Project to support its delivery under Project Speed. On 1 April 2023 local government in Cumbria will change. The current six district councils, along with county council, will be replaced by two new ‘unitary’ councils. For the area of the County in which the Project is located, the new Westmorland and Furness Council will be created. It will inherit the roles and functions of, and replace, Cumbria County Council and Eden District Council. From this date Westmorland and Furness Council will be responsible for providing all the services currently delivered in those areas by the three district and borough councils and Cumbria County Council. A Joint Engagement Statement is submitted alongside this representation and sets out how the existing and replacement authorities will engage in the Pre-examination and Examination stages of the Application process. This representation relates only to the matters of most concern to the Council. Support for the Project 1. The Council supports the principle of dualling the remaining single carriageway sections of the A66 between Penrith and Scotch Corner, as well as improvements to junctions along the route. A suitably designed scheme will improve connectivity within and beyond Cumbria, improve resilience, road safety and journey time reliability, and help to support future economic growth and investment. 2. The Council acknowledges that the Applicant has engaged in a statutory and non-statutory consultation process. It is however concerned that the inclusion of the Scheme within Project Speed has resulted in an application that has been submitted against extremely tight deadlines and there are some negative impacts of the Scheme that could have been further mitigated with time for more consultation and engagement and the provision of more detail. These matters will need addressing during the Examination. Key Tests 3. In response to the A66 Section 42 consultation, the Council identified a number of areas where mitigation was required to minimise negative local impacts and ensure the benefits of the Project are realised. These were identified as the Council’s ‘key tests’ for the Project and represent the issues of greatest importance to the Council. The key tests are: • Connectivity - Improving Connections to Local Communities, Maintaining North-South Connectivity and Minimising Severance • Key Junction Improvements • De-Trunking of the Existing A66 • Active Travel • Network Resilience • Improved Facilities for HGVs • Maximising Socio-Economic Benefits • Construction impacts (including Diversion Routes) • Environmental Mitigation, including drainage Each of these issues is summarised below and is set out in more detail within the accompanying PADSS. Improving Connections to Local Communities, Maintaining North-South Connectivity and Minimising Severance 4. The Project should result in clear and effective junction strategies across the A66 and greater junction safety and legibility, supporting both east and west bound journeys. There should be no loss of north-south connectivity or loss of connectivity for communities and key destinations across the route. The main areas that will suffer an impact on connectivity are around Penrith (M6 Junction 40, Kemplay Bank and Skirsgill) and at a number of locations along the route where right turn movements will be removed or where the new road severs an existing route. Key Junction Improvements 5. The Project should develop effective junction solutions that are able to support forecast traffic flows and alleviate any congestion issues (such as those experienced on a Friday at M6 J40) and at Kemplay Bank. Junctions that are critical to diversion routes should be enhanced to address capacity and resilience concerns. Junction capacity needs to be informed by a clear approach to traffic modelling and forecasts. De-Trunking of the Existing A66 6. The Project needs a clear strategy for the sections of the A66 that will be de-trunked, so that assets adopted by the Council are at an acceptable and agreed standard and appropriate commuted sums are provided to support future upkeep. The transferred assets should be subject to enhancements where necessary to reflect their new role as part of the local road network. There is no agreed approach to de-trunking and the Council needs to have a full understanding of the liabilities that may arise. There are specific concerns regarding the transfer of structures as these carry particular risks. Active Travel 7. The Project should support the delivery of an east-west corridor suitable for walking, cycling and horse riding. The design details need to be agreed and must comply with recognised standards, including LTN 1/20 and Active Travel England guidance. Clarity is needed regarding maintenance responsibilities. The design for walking and cycling. The scheme should also address the needs of travellers to Appleby Horse Fair and incorporate meaningful improvements for horse drawn traffic. Network Resilience 8. To increase the resilience of the route once operational, the scheme should incorporate the use of more and smarter technology, for example variable message signs. Consideration should be given to enhancing the existing strategic diversion routes, specifically the A6 and A685. The impact of the Project on permanent diversion routes needs to be considered and mitigated during the planning and construction phases. Improved Facilities for HGVs 9. Consideration of the adverse impacts arising from substantial increase in HGV traffic is required. The Project should act as a catalyst to the provision of high quality and dedicated HGV parking and service provision across the A66 corridor. To support the logistics sector NH need to provide clarity on provision of parking and services to accommodate increased usage by HGVs and parking and services demands. Maximising Socio-Economic Benefits 10. The Project should maximise the economic benefits resulting from the scheme, deriving social value and legacy benefits. This should include support for skills development to enable local take-up up of employment opportunities from the Project, as well as support for the local supply chain to position local businesses to win work. The impacts of accommodating the construction workforce are unclear and may have an adverse impact on the visitor economy, local housing and communities through use of existing accommodation or poor siting of the accommodation. Opportunities should be taken to generate lasting benefits from the provision of accommodation. Construction impacts (including Diversion Routes) 11. There should be a clear construction traffic management plan and the establishment of suitable diversion routes to support the construction of the new upgraded sections of the A66. Potential diversion routes are not suitable without mitigation and fall outside the DCO boundary. Environmental Mitigation 12. The scheme should provide environmental mitigation to minimize harm and boost benefits. There should be opportunities for carbon offsetting across the scheme. Biodiversity net gain is also an issue of importance. 13. The Council has concerns about the drainage proposals for the Project and the potential impact on the water environment. There are matters that need resolving in terms of drainage design principles and details, which have impacts on the extent of land needed for drainage systems, particularly with regard to flood risk and future maintenance liabilities. Other Matters 14. From a property and land perspective, the Council has significant concerns about the land National Highways is planning to acquire on a permanent basis at Skirsgill and Kemplay Bank due to the serious detrimental effect this will have on the Council’s ability to provide essential services.