Representation by Transport Action Network (Transport Action Network)
- Date submitted
- 5 July 2024
- Submitted by
- Members of the public/businesses
Transport Action Network (TAN) objects to the proposed scheme at Simister Island Interchange. It is one of the busiest motorway junctions in the north-west, and is already within Noise Important Areas (NIA) and Air Quality Management Areas (AQMA). Rather than increasing capacity, National Highways should be seeking to reduce demand. Instead of dealing with the severe air and noise pollution already faced by local people, this scheme would make things worse for many local residents. National Highways have only ever proposed or examined variations of a road building proposal, never non-roadbuilding alternatives to reduce demand, contrary to the National Network National Policy Statement (NNNPS) and the EIA Regulations. Construction will take place at night over a three and half year period, causing unacceptable noise and disturbance to local residents. [Table 11.18 of Chapter 11 Noise and Vibration, APP-050] Night time motorway closures will transfer traffic onto the local road network, increasing noise and disturbance for local residents at night. There will be an increase in noise at Kenilworth Avenue, Warwick Close, Warwick Avenue and Peveril Close to the south, Balmoral Avenue, Kensington Street, Glendevon and Conisborough Place, Duddon Close and Derwent Avenue, to the north, and closer to Junction 18 at Brathay Close, Rothay Close, Marston Close and parts of Parrenthorn Road and Corday Lane. [6.15.22 of Case for the Scheme, APP-146] The scheme would lead to an increase in fatal, serious and slight casualties. [1.4.1 of the Case for the Scheme, APP-146] With or without the scheme, air pollution levels will still be unacceptably high and above safe limits. The scheme reduces air quality in some areas. National Highways should be examining solutions that will decrease the unacceptable level of noise and air pollution caused by the existing road. There are no significant benefits to the scheme, only small time savings and modest economic growth, which results in the scheme being very poor value for money with a Benefit to Cost Ratio of just 1.17 (Low value for money according to the DfT’s guidance). This means that for every £1 spent on the scheme, taxpayers only see £1.17 returned to society. [5.4.4 of the Case for the Scheme, APP-146] 68 hectares of land surrounding Junction 18 is in the Green Belt. [6.8.11 of the Case for the Scheme, APP-146] Carbon emissions would be increased by 62,013 tonnes during construction [Table 14-22 of Chapter 14 of the Environmental Statement, APP-053], and 151,090 tonnes over 60 years due to the increased traffic [Table 14-23 of Chapter 14 of the Environmental Statement, APP-053]. This makes it even harder for the UK to reach its legally binding climate targets which we are already off target to reach.