Representation by Eden District Council (Eden District Council)
- Date submitted
- 10 August 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 Eden District Council This registration has been made by Eden District Council (EDC), and sets out the topics on which the Council wishes to make representations at the Examination into the A66 Northern Trans Pennine Project. EDC has been engaged with Highways England throughout the pre-application Development Consent Order process, including attendance at the stakeholder meetings organised by Highways England. The authority has also made a number of responses to consultations carried out by National Highways during that period. It should be noted that on March 31st 2023 Eden District Council will cease to exist and will be succeeded by a new unitary Authority which is currently in shadow form. This representation is, therefore, made not only on behalf of Eden District Council but also for its successor Westmorland and Furness Council which will take over the functions of both Eden District Council and Cumbria County Council on the 1st April 2023. This will include engagement in the examination process after that date. The council wish to make representations on a number of areas which we have summarised here. We feel there has been a lack of detailed information provided on the project up to submission. Many of the issues raised have not yet been responded to or resolved. As a result we expect to make representations in relation to these matters during the examination process. Summary of Matters to be Subject to Representation: 1. Land acquisition: The Council is open to entering informal without prejudice discussions with respect to the acquisition of land owned by the Council and this has been acknowledged by National Highways. However, this is in the very early stages and we are likely to require further information. 2. Non-Motorised transport: We seek to ensure that acceptable provision is made in relation to continuity of cycle routes, standard of route, effectiveness of crossing/connection points. Routes through major junctions. In addition, we need to make sure provision is made for horse drawn vehicles particularly as access routes to historic traveller festivals are affected by the proposals. 3. Air quality impacts and mitigation need to be understood at a number of locations along the route. 4. Noise Impacts and mitigation need to be understood at a number of locations along the route. 5. Landscape quality of the route corridor needs to be understood and commensurate with a route that provides access to and travels through or between the North Pennine AONB, Yorkshire dales National Park, the Westmorland Fells, the Eden Valley and the Lake District National Park which is a World Heritage Site. The way the area presents itself to the users of the route will be important to the long term economy of the area which is to a significant extent reliant on tourism driven by the landscape beauty of the area. 6. The design of structures on the routes needs to take into account the effect on the high quality landscape and historic environment. 7. Climate change and Carbon Offsetting. We need to be happy with the measures taken in view of national policy and EDC declaration of a climate emergency. A project of this scale, the largest affecting the area, needs to complement and not undermine other local and national efforts towards achieving net zero. 8. Impacts on Wetheriggs Country Park that is affected by land take by the project that impacts on sports facilities, an informal leisure facility, sensitive housing receptors, mature landscaping and biodiversity. A detailed masterplan for this area needs to be put in place to mitigate these impacts in the most effective way. 9. Worker Accommodation Strategy needs to be agreed to avoid negative impacts on a sparsely populated rural area that relies heavily on its accommodation stock to support its important tourism industry. 10. A local economic optimisation strategy needs to be agreed to impact positively on the local area particularly during the construction phase. 11. Impacts on watercourses need to clear and appropriate mitigation agreed. 12. Biodiversity mitigation and net gain in line with the requirements of the Environment Act 2021 need to be delivered. 13. All impacts on the historic environment are not yet understood. Mitigation needs to be agreed. 14. The potential for post construction use of compounds needs to be considered including permanent access and suitability for other end uses. 15. HGV and other services along the route have not been provided for. Proposals need to be agreed and assessed in terms of environmental impacts before the project is consented. 16. Diversion Route impacts and mitigation need to be clear discussed and agreed. 17. Construction Impacts and mitigation need to be clear, discussed and agreed. 18. Negotiations on the purchase of land owned by EDC is underway but there are a number of unresolved issues yet to be agreed which need to be the subject of discussion in the Examination. 19. Proposed route alignments requiring removal of mature trees and demolitions need to be avoided wherever possible. There are number of locations where agreement on this is required. 20. Water Quality: the potential for the scheme to increase surface water run-off, via additional carriageways and traffic, adding to the nutrient load in rivers and watercourses, which in turn will exacerbate the nutrient neutrality problems facing housing development in the Eden catchment.