Mr. Peter Robottom,
A556 Knutsford- Bowdon Scheme,
The Planning Inspectorate,
Temple Quay House,
2 The Square,
Bristol, BS1 6PN.
Monday, December 30th, 2013 Your ref: TR010002
Dear Mr. Robottom,
HIGHWAYS AGENCY APPLICATION RE. A556 KNUTSFORD-BOWDON SCHEME
Interested party ref: 10019087
This submission is in response to your, (the Examining Authority), request for comments on the consistency of the DCO (Development Consent Order) with the Draft National Policy Statement for National Networks and the National Infrastructure Plan 2013, as requested in your letter of December 9th, 2013.
Draft National Policy Statement (NPS) for National Networks vis a vis NPPF
It is important at the outset to stress the following two points:
1. “National Policy Statements form part of the overall framework of national planning policy” (bullet 3, Introduction, National Planning Policy Framework 2012 – our highlighting), the other major key part being the NPPF itself, and
2. this is a consultation document; it could change before the final version
The NPPF begins by quoting the UK Sustainable Development Strategy and its five guiding principles and by emphasising the three dimensions to sustainable development, ie. economic, social and environmental (bullet 7, Introduction).
It then explains applying the presumption in favour of sustainable development
“For decision-taking this means: 10
· approving development proposals that accord with the development plan without delay and
· where the development plan is absent, silent or relevant policies are out-of-date, granting permission unless:
- any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole or
- specific policies in this Framework indicate development should be restricted 9
9 For example those policies relating to sites protected under Birds & Habitats Directives and/ or
designated as Sites of Special Scientific Interest, land designated as Green Belt, ……
10 Unless material considerations indicate otherwise” (bullet 14, Introduction)
In the case of the A556 scheme, it should be noted that:
o Cheshire East Council, in whose area the A556 lies, currently has no Local Plan in place
o The latest stage in the development of the Cheshire East Local Plan (prior to the publication of the Draft Local Plan) is the Pre-Submission Core Strategy, consultation on which closed on December 16th, 2013. This document did not depict the Highways Agency’s (HA’s) A556 scheme in the key diagram (fig. 8.4) on page 73, nor did it mention it in Policy CO2 on ‘Enabling business growth through transport infrastructure’ (on pages 156 and 157) where other HA schemes are listed, nor is it referenced in the ‘Connectivity’ chapter and nor is it in fact mentioned anywhere in the document. This demonstrates that Cheshire East Council is not concerned whether this scheme is delivered or not. It is certainly not a priority for them. (Document at: http://cheshireeast-consult.limehouse.co.uk/portal/planning/CS/cspre).
o As the HA has not conducted a wider economic impact assessment it is not possible to tell whether or not any economic benefits would outweigh environmental and social disbenefits
o Neither the Highways Agency nor HS2 Ltd. nor any other body has carried out an environ-mental impact assessment that looks at the combined impacts of the A556 scheme and the HS2 proposal which cross and run alongside each other in the vicinity of the RAMSAR site of Rostherne Mere and both of which together impact on Green Belt. Consequently, it is not possible to make a reasoned judgement about the combined level of environmental dis-benefits let alone the combined disbenefits to local communities from matters such as noise.
Draft NPS for National Networks
The Draft National Policy Statement (NPS) for National Networks sets out how the Secretary of State for Transport will make decisions on planning applications for nationally significant infrastructure projects (NSIPs) on England’s strategic road and rail networks and on strategic rail freight interchanges (SRFIs).
The document argues that, although there has been a decline in road traffic levels, this was “largely a response to the economic downturn and the rising price of oil” (para. 2.8) and goes on:
“The Department expects that as the economy grows and population increases there will be significant traffic growth, particularly on the strategic road network” (para. 2.9).
This claim, of course, is one that the Campaign for Better Transport (CfBT) is disputing both through the evidence it has presented to this inquiry and in other arenas, with the assistance of research input by Professor Phil Goodwin. CfBT has presented to the public inquiry both generic and area specific traffic data which makes a strong case for recalibrating the traffic model used for the A556 scheme and they and the North West Transport Roundtable (NW TAR) are obliged to you, the examining authority, for pursuing this line of enquiry. We are not in a position to comment further on this specifically if and until the results of a new modelling run is made public
but we offer the following generalised comments:
In the case of the A556
o If a new traffic modelling run shows that traffic growth in future would be lower than previous forecasts and/or traffic would travel slower than originally estimated, such factors affect the scheme’s cost benefit analysis (COBA) and weaken the case for it and
o If a new modelling run shows that traffic growth would still be at about the level that was previously predicted (or higher), then this would cause problems with air quality
The Department for Transport (DfT) acknowledges in the NPS for National Networks that air
quality could be a reason for individual projects not being delivered. It says:
“5.7 The Secretary of State should consider air quality impacts over the wider area likely to be affected, as well as in the near vicinity of the scheme. In all cases the Secretary of State must take account of relevant statutory air quality thresholds set out in domestic and European legislation.
5.8 Air quality considerations are likely to be particularly relevant where schemes are proposed within or adjacent to Air Quality Management Areas, areas with exceedences of Limit Values or national objectives or where they may have potential impacts on Natura 2000 sites including those outside England.
5.9 The Secretary of State must give air quality considerations substantial weight where a project would lead to a significant air quality impact and/or lead to a deterioration in air quality in a zone/agglomeration79 where the air quality breaches air quality limit values
79 The United Kingdom is split into 43 zones and agglomerations for the purpose of reporting air quality within those zones to the European Commission under the Air Quality Directive” (‘Decision making’, page 44).
The NPS then goes on to discuss mitigation measures and the need for the Secretary of State to consider whether mitigation measures put forward by the applicant are acceptable.
In the case of the A556 scheme:
o The version initially lodged by the HA would breach air quality thresholds
o The HA’s mainly off-line alignment lies adjacent to air quality management areas. These apply not only to the extant A556 at Mere and the M6 but also to the A50 Manchester Road, Knutsford (www.cheshireeast.gov.uk/environment_and_planning/environmental_health/local_air_quality/review_and_assessment/aqma_area_maps.asx) and to a Natura 2000 site Rostherne Mere)
o At its northern end, the HA scheme lies adjacent to the Trafford part of the Greater Manchester agglomeration zone for which there is an extant plan for the achievement of EU air quality limit values (http//:uk-air.defra.gov.uk/library/no2ten/index?aid=3).
o The very recent mitigation measure suggested by the HA to tackle air pollution has been a proposal to introduce speed limits, albeit potentially only for the first few years of the scheme. But, as pointed out in our joint letter with CfBT, this would affect the COBA which is an integral part of the HA’s case for the scheme and this therefore needs to be re-evaluated.
Probably the other key most relevant section of the NPS to the A556 scheme is the section on bio-diversity and geological conservation which references the Natural Environment White Paper. This section emphasises the need to take account of climate change and impacts on biodiversity and
particularly flags up the importance of protecting sites with international designations. It says:
“5.22 Where a proposed development on land within or outside a SSSI is likely to have an adverse effect on an SSSI (either individually or in combination with other developments) development consent should not normally be granted” (page 47 – our highlighting)
In the case of the A556 scheme
o There has been no environmental investigation conducted into the joint effects of the HA scheme and HS2 scheme on the RAMSAR site of Rostherne Mere and its environs or on climate change – or if a study has been carried out it has not been released into the public domain.
H.M. Treasury National Infrastructure Plan
The National Infrastructure Plan 2013 sets out the government’s plan for the next decade and beyond. In doing so, it commits to “drive efficiency and value for money in infrastructure” (Executive Summary, page 3 – our highlighting) and it declares that a modern, successful and competitive economy will require “an integrated transport system that provides reliable, cost effective domestic and international connections for organisations and individuals” (para. 1.3, page 13 – our highlighting).
Under ‘Roads’ the strategic objectives set out are:
“3.6 The government is committed to developing and maintaining a road network that will facilitate people’s day-to-day activities, drive economic growth and meet the needs of road users now and in the future. In particular it is focused on:
· addressing road quality, increasing capacity and tackling congestion, and ensuring the network provides critical connections
· securing the network by fixing the instability and institutional problems that have led to 20 years of underinvestment
· adapting to, and taking advantage of, technological change and meeting the govern-ment’s environmental and climate change targets” (page 34 – our highlighting)
Under ‘Key programmes/ projects’ the document states:
“3.19 …. The government will particularly monitor five high capital value trunk road and junction improvement projects in the investment programme due for start of works in this parliament, where successful delivery is therefore particularly critical in ensuring the overall value for money of the programme:
· A1 (Leeming to Barton)
· M1/M6 Junction 19
· A556 (Knutsford to Bowdon)
· A453 widening
· A5-M1 Link Road” (page 37 – our highlighting)
As far as the A556 scheme is concerned:
o It is unknown whether or not the HA’s scheme will drive economic growth or lead to more jobs in the wider area because no wider economic impact assessment has been conducted
o It is unknown whether or not the scheme will deliver value for money because all the detailed and necessary facts and figures, based on the most up-to-date iteration of the scheme now before the ExA (with reduced traffic speeds in place) are not known and
o It is unknown what effect the HA's scheme, combined with the HS2 scheme, will have on the local environment or on climate change because no work has been carried out on this.
The number of unknowns and uncertainties relating to the A556 Knutsford to Bowdon scheme (and the HS2 scheme which impinges on the same area) are legion. There are too many for a reasonable judgment to be made. We submit the inquiry should either be delayed until all the missing information becomes available and can be properly analysed or it should be abandoned.
Yours sincerely,
LILLIAN BURNS, Convenor, NW TAR E-mail:
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