Representation by Barnard Castle Town Council (Barnard Castle Town Council)
- Date submitted
- 4 September 2022
- Submitted by
- Local authorities
We believe that the Black route conflicts with the National Planning Policy Framework Revised 2021 [NPPF] under sections 6 (strong, competitive economy), 7 (the vitality of town centres), 8 (promoting healthy and safe communities), 9 (promoting sustainable transport), 15 (conserving and enhancing the natural environment), and 16 (conserving and enhancing the historic environment). We further believe it is not reflective of the requirements of the National Networks National Policy Statement 2014 [NPS] on linear infrastructure development in terms of heritage, the environment and safety. We also believe it is in breach of the NPS with regards to at least 5.127, 5.128 and 5.133. Historic England have stated their opinion that the Blue Route will cause “substantial harm” to two heritage assets. Given the opinion that “substantial harm” would be caused to heritage assets, National Highways have returned to the Black route at the Rokeby junction based on their obligation to avoid harm under NPS 5.133. The NPS allows consent to be granted - even when “substantial harm” might be expected to heritage assets – if “it can be demonstrated that the substantial harm or loss of significance is necessary in order to deliver substantial public benefits that outweigh that loss or harm [NPS 5.133]” (language that is mirrored in NPPF 201). This would allow the community-backed Blue junction route to be considered as an alternative, assuming it offered the necessary public benefits. We do not believe that adequate investigation has been undertaken by Highways England on the potential deleterious impact of the Black Route on the wider surroundings and population via the predicted increase in traffic from the Cross Lanes junction. We do not believe that Historic England’s assessment is accurate in its assessment of either the Black or Blue route. We further contend that our objections demonstrate the public benefits of not choosing the Black route outweigh the potential harm and, accordingly, we request the Black junction option at Rokeby be rejected in favour of the Blue eastern alternative junction. A full Local Impact Report has been prepared and we look forward to submitting it in due course.