A66 Upgrade Consultation 1st February 2022 We have today submitted comment to the project director A66 Highways detailing what we consider to be the inadequacies of the A66 Northern Trans-Pennine Upgrade Consultation. The full document can be viewed at the link. Our concluding comments detailed in this letter follow. Friends of the Lake District Inadequacies of A66 Consultation letter to NH (pdf) Conclusions: a. National Highways should not proceed with a DCO planning application until they have consulted properly and are clear which option is being progressed, and consult on those proposals. b. National Highways should have put forward an option to improve the safety of the A66 through junction upgrades, underpasses and bridges and use of average speed cameras without making the road a dual carriageway. We want to know why this option was not considered. c. Upgrading the A66 to a dual carriageway for its entire length from Penrith to Scotch Corner will make it more difficult to secure a sustainable future for Cumbria’s landscapes, people and wildlife. Implementation of this scheme would lead to significant damaging impacts on the natural capital of Cumbria and the North Pennines. This damage would include harm to protected landscapes, loss of and damage to habitats, severing of wildlife corridors, loss of flora and fauna, increases in noise, light and air pollution; local community severance and issues with flooding and run-off. d. The extra traffic from the eight schemes would increase carbon emissions by up to 3 million tonnes over the lifetime of the scheme (Table 7-2 in the GHG Emissions Assessment Appendix) e. The emissions resulting from the construction of the scheme would cause up to 1.4 million extra tonnes of carbon (Table 7-1 in the GHG Emissions Assessment Appendix) f. In total the scheme would lead to an increase of up to 4.4 million extra tonnes of carbon from extra traffic and the construction process. This is completely unacceptable in a climate emergency, and takes us further away from reaching our 68% cut by 2030 required under the Paris Agreement.g. It is unacceptable that consultees and the public were asked to assess this scheme without being provided with photomontages. A fly through over an inaccurately rendered cartoon depiction of the landscape at 50m height does not provide the information needed as it does not represent how people see the landscape. h. We have serious concerns about the sections from Temple Sowerby to Appleby (particularly at Kirkby Thore) and Appleby to Brough where the road goes into the North Pennines AONB. Please take these representations as coming from Friends of the Lake District, CPRE Cumbria Branch. 10th November 2021 Friends of the Lake District responded to the National Highways consultation on the upgrade of the A66. We raised concerns over the impact of the road on the landscape around Kirkby Thore, and in the setting of the North Pennines AONB, around loss of and damage to wildlife, and we also raised concerns about the huge amount of carbon emissions that the road will incur both in construction and use. You can read our response here. 15th October 2021 The A66 Upgrade East of Penrith damages the North Pennines AONB, harms wildlife and flouts the Government’s carbon budget National Highways (formerly Highways England) are consulting on building a new dual carriageway road along the boundary of the North Pennines AONB through some of the county’s most beautiful landscapes. Friends of the Lake District is concerned that the proposals to make the road “safer” are actually an excuse to make the entire road a dual carriageway, encouraging the use of this unique landscape as a rat-run for HGVs to cross the country. The landscape damage, loss of wildlife, severance of hedgerows and destruction of farmland that this road proposal will cause is of huge concern to us as a landscape charity covering the whole county of Cumbria. We have particular issues with the section of the road which will drive through the landscape north and east of Kirkby Thore. This increases the length of the road significantly, impacting on wildlife habitats, tranquillity and views into and out of the AONB. Of great concern are figures from the National Highways themselves which demonstrate that the road will increase carbon emissions over the 60 year appraisal period by 3,308,479 extra tonnes of carbon (the fourth biggest emitting scheme in the Government’s roads programme). This is just the total for the additional traffic caused by the scheme, and does not include the carbon emissions caused by the construction of the road (materials, land loss, trees felled etc). Upgrading this road will go a long way towards busting the UK’s carbon budget making it harder to meet the Government’s legally mandated carbon budgets, including reducing emissions by 78% by 2035 (sixth carbon budget), and 68% by 2030 (Paris Agreement). Throughout the route evaluation process, Friends of the Lake District has been asking for National Highways to look at upgrading junctions and building underpasses for farm traffic to increase safety on the A66, rather than wholesale dualling it. We are aware of the road’s poor record on safety, but know that these issues could be addressed through junction improvements, changes to alignment and lower speed limits. However, National Highways have not even looked at this option in their appraisal of the route, solely fixating on dualling the whole road. On this basis we do not consider that the proposal has actually adequately assessed all the options which is a legal requirement of the Environmental Impact Assessment Regulations and we will be pushing for more information on why safety upgrades without dualling were never considered. You can see and respond to the proposals here https://highwaysengland.co.uk/our-work/a66-northern-trans-pennine/ Consultation closes on 4th November 2021.