Representation by Emma Nicholson
- Date submitted
- 4 September 2022
- Submitted by
- Members of the public/businesses
I object to NH DCO application to dual the Temple Sowerby to Appleby (west section) . I am impacted as landowner and homeowner. I submitted a 34 page written response to NH’s Statutory Consultation . This was neither acknowledged nor responded to. I submitted a second separate document hi-lighting inadequacies in NH consultation process at Kirkby Thore. Again this has been acknowledged nor responded to by NH. That is typical of the secretive way in which NH have operated throughout Project Speed. NH should be co-operating/consulting with interested parties seeking to narrow/resolve issues. That is not our experience. Whilst on each occasion apologies are offered for lack of consultation(to include by both Heads of Project) the failure to answer questions persists. NH originally maintained that they had chosen the northern route as that is what Kirkby Thore wanted. They stated the village considered the northern route the only way to remove HGV traffic. The efforts to accommodate British Gypsum by assisting it to remove HGV from Kirkby Thore could cost the British taxpayer 500 million pounds. That figure is rising. NH will not disclose it stating is commercially sensitive. This is taxpayers money. It must be questioned why the British tax payer should pay to resolve an access issue for a French Company (which due to dwindling mine reserves ) now imports the majority of its gypsum supplies from Europe. The problem of HGVs travelling through Kirkby Thore is real, but possibly time limited. It is acknowledged by Gypsum that at current rates of extraction the mine only remains viable for another 15 years approx. The likelihood that St Gobain (the French Parent Company) would continue with a factory once the gypsum supplies are exhausted is low. After 15 years the only other alternative for gypsum extraction at Kirkby Thore would be open casting to access deeper mines. Gypsum say that is too costly. That (combined with the unpopularity of open casting) is the reason Gypsum already importing from Europe to supplement mine supplies. Given the uncertain future why are we spending 500 million, incurring 600,000 tonnes of carbon, impacting on the Eden SAC/SSI, intruding into an AONB, exposing a village to air/light/noise and tyre pollution to remove HGV’s from a factory with a limited life span. It is a sledgehammer to crack a nut. The problem of HGVs in Kirkby Thore could be resolved by enforcing planning restrictions. Gypsum were supposed to transport gypsum to the factory via rail and has its own railhead for this purpose. A lack of enforcement has allowed HGV’s to increase. British Gypsum Social charter states they are moving transport to rail to reduce transport emissions. The Kirkby Thore plant is considered one of the key places the company can make reductions. The Kirkby Thore plant sustainability manager confirms that Gypsum are seeking to establish a transport plan in line with its Social Charter. The Planning Inspectorate should consider whether the justification of removing HGV’s ( daily number not stated) from Kirkby Thore can possibly be justification in light of the limited lifespan the factory may have and the other available alternatives. Faced with mounting scrutiny of its choice of route and over-reliance on the benefit to British Gypsum, NH suddenly raised roman archeology as the sacred cow justifying the northern route. National Policy meant the road must go north to avoid the Roman Viccus. This is so farcical that even Historic England have given written confirmation that Cultural heritage is just one of the factors to be considered . This letter is already available to the Planning Inspectorate. If avoiding the Roman Viccus was the dominating factor, then presumably the southern route would never have been proposed. Seeking to rely on archeology over and above all other factors is an example of NH doubling down on its decision to go north and is evidence of its bias. NH even moved the southern route closer to the Roman Vicus in May 2021 when putting forward a revised version of the southern route. Again this indicates that either they were purposefully trying to create a route which they could not accept or that archeology is a issue which can be overcome with mitigation. It is not the absolute bar that NH have stated it to be River Restoration Project It remains unclear how much land NH will take from Sleastonhow Farm as part of the DCO. The frustration caused by NH’s lack of consultation on land take was then compounded by efforts to commandeer an existing river restoration project planned at Sleastonhow Farm. This project is not environmental mitigation advanced by NH. This is stealing an existing project which existed as an easy way to achieve mitigation. Losing land will impact of the future viability of Sleastonhow farm as a business. It makes Sleastonhow (which has farmed to benefit nature for generations) less able to devote land to this planned River Restoration project. NH acknowledge this River Restoration project as important. NH sifting matrix included the protection of this project as a priority. It is unclear why they have not included the actual landowners in any discussions. Eden Rivers Trust, Natural England and the Environment Agency should be consulted on the impact to the SAC should this project not proceed. I wish to be given the opportunity to attend the Examination in person. As a landowner and homeowner (which NH accept they have failed to consult) and as someone whose home and businesses will be irreparably impacted should this project proceed, I also wish to make representations on the following -Cost -Carbon - GHG emissions are x3 than the southern route -Landscape -Impact on the SAC -Loss of agricultural land -Increase in properties in Kirkby Thore exposed to noice and air pollution -Failure to consult on junction change/WCH/Compounds in the Statutory Consultation -Biodiversity loss at Sleastonhow Farm