Ms. Irene Ofei,

Project Manager,

Regional Investment Programme,

Highways England,

Piccadilly Gate,

Store Street,

Manchester, M1 2WD.

Monday,April 3rd, 2017

Dear Ms. Ofei,

Consultation on the Trans Pennine Upgrade Programme

The North West Transport Roundtable (NW TAR), which operates under the auspices of the Campaign for Better Transport (CfBT), promotes sustainable transport and land use and healthier lives. We espouse ‘Smart Growth’ and reducing the need to travel.

Background Commentary

First of all, thank you for your personalised circular email of March 21st, 2017 which apologised for the fact that incorrect information was imparted in an email dispatched by you on March 8th in respect of a consultation event relating to the TransPennine Upgrade Programme that was held at Tankersley (ie. it gave the wrong date for the event). At the end of that message, you offered to meet on a one-to-one basis. This is just to say that Anne Robinson of Friends of the Peak District (FoPD) and also the author of this letter (and please note that we both also operate on behalf of the Campaign to Protect Rural England within our respective regions) may take you up on that offer.

You should be aware that, for Anne Robinson and myself, there is a strong element of ‘deja-vu’ about proposals for a Mottram-Hollingworth-Tintwistle Bypass. We were both heavily involved in the public inquiry that was held into this proposal a decade ago and which collapsed due to the inaccuracy of the traffic flow figures that the (then) Highways Agency presented. On behalf of the organisations that we represent – FoPD, CPRE and NW TAR – we objected to the proposals for a Mottram-Tintwistle Bypass – for a wide range of environmental reasons – and we still object to that concept as well as to the principle of additional ‘climbing highway lanes’ through a National Park for the same reasons. What has changed in the meantime is the introduction of a ‘Smart Motorway’ scheme on the M62 to the north which we would argue weakens the case for providing more highway capacity on other unsuitable cross Pennine roads.

Just for clarification, I should add at this point that environmental NGOs do not support hard shoulder running because we see it as merely another way of increasing highway capacity and therefore its impacts – induced traffic on the motorways and access roads and increased pollution and severance – are little different than adding highway lanes in the traditional manner. However, we are simply making the point that, in this case, the ‘smart motorway’ now already exists and therefore so does the extra capacity it affords.

Comments on the Upgrade Programme

Highways England’s Spring 2017 consultation leaflet maintains that an upgrade programme is necessary on the A57/ A628/ A616/ A61 corridor in order to provide both strategic and local benefits.

From a strategic viewpoint, the case has altered significantly since the Mottram-Hollingworth-Tintwistle Bypass was previously promotedbecause of the extra capacity afforded by the introduction of the M62 smart motorway. This has attracted some long distance traffic away from the less suitable cross Pennine roads. And, according to the HE’s own Post Opening Project Evaluation (POPE) report on the M62 J25-30, published in April 2016, there is plenty of spare capacity on the M62 smart motorway and take-up has been less than expected. It is surely illogical, therefore, to aim to draw strategic traffic back onto the old TransPennine routes.

The HE itself is predicting that if either their ‘Option A’ or their ‘Option B’ went ahead, there would be a cross-National Park traffic increase of between 7% and 8%. However, this is not broken down and seems low. But, in any event, since these figures were arrived at, the new DfT regional traffic models have become available. Consequently, the raw data ought to be fed into the new traffic models. Also, there needs to be a full origin and destination analysis which projects how much strategic traffic would move from the M62 to the A57/ A628/ A616/ A61 corridor if the historic TransPennine routes were upgraded.

Meanwhile, the claimed local benefits steadfastly ignore fundamental concepts proven two decades ago by the Standing Advisory Committee on Trunk Road Assessment (SACTRA), that new trips are generated when new highway capacity is provided (Trunk Roads and the Generation of Traffic) and that, in a mature economy such as that which exists in the UK, there is no automatic economic benefit to be found by providing more transport infrastructure (Transport and the Economy). The leaflet also completely ducks the huge issues of air pollution and carbon generation. The entire Longendale Valley is an Air Quality Management Area (AQMA). The ‘upgrade programme’ would merely serve to extend the limits of the AQMA – because (a) a large percentage of the traffic is known to be locally generated and (b) as the bypass gradually fills up with traffic, a proportion of it would re-route back to the original roads being bypassed. This situation would be exacerbated by infill development between the bypass and the existing settlement boundaries.

These statements are not hyperbole. The scenario outlined has happened time and time again, most notably in recent years in respect of the A34 Newbury Bypass. The key question is, why do we never learn?

We would like to commend to Highways England, the very recent publication by CPRE, ‘End of the Road’

(March 2017). This independently-written report reveals (again) that road building is failing to deliver either the congestion-relief or the economic benefits that are claimed. It does so (primarily) by studying HE’s POPE reports. It ought to prompt some serious reflection on the current expansive road building programme and on how POPE studies are conducted. (It calls for a number of changes). But will it?

From what we have said, it must be apparent that we do not support either ‘Option A’ or ‘Option B’ put forward as part of the HE consultation on the TransPennine Upgrade Programme, both of which rely on providing extra highway capacity. We do, however, support the response to the consultation submitted by FoPD and we would most particularly point up their comment that no case has been presented to show that economic benefits would outweigh environmental disbenefits if the proposals went ahead.

We trust that these comments are of some value and will be taken into account.

Yours sincerely,

LILLIAN BURNS, Convenor, NW TARE: Tel: 01625 829492

1