The government’s agency for planning and maintaining the trunk road network, Highways England, has been consulting on its plans for future investment. The Campaign for National Parks (CNP), which works closely with all the national park “Friends” groups, has submitted the following response to the consultation, which is fully endorsed by the Society.
February 2018
1. The Campaign for National Parks is the independent national voice for the 13
National Parks in England and Wales. Our mission is to inspire everyone to enjoy
and look after National Parks – the nation’s green treasures. We have been
campaigning for over 80 years to ensure that our National Parks are beautiful,
inspirational places that are relevant, valued and protected for all.
2. National Parks are our finest landscapes with the highest level of protection. They
contribute significantly to the well-being of the nation, by providing safe, attractive,
healthy places for recreation. They also deliver key environmental resources and
services, like water provision and carbon storage in peat soils and forests, which can
mitigate the effects of climate change. As well as being inspiring places for people to
enjoy and improve their health and well-being, National Parks make a significant
contribution to the economy through tourism, farming, and other related businesses.
The English National Parks currently attract 94 million visitors a year, who spend
more than £5 billion and support 75,000 full time equivalent tourism related jobs.
3. All of the English National Parks are affected to some extent by the strategic road
network (SRN) and several have significant lengths of this network within or close to
their boundaries. It is therefore essential that the plans for RIS2 take full account of
the additional planning protection that applies in National Parks. We are very
concerned at the potential for RIS2 to include road schemes which could be
extremely damaging for National Parks, undermining their special qualities and
putting at risk the significant economic benefits that these areas provide. There is
evidence that road schemes justified on the basis of reduced journey times fail to
deliver the promised economic benefits2 and such schemes would be particularly
damaging in areas such as National Parks where the economy is heavily dependent
on a high quality environment.
4. We are particularly concerned at the threat posed to the Peak District National Park
by the revised Trans-Pennine Tunnel study and proposals for major upgrades to the
A628. The decision to shorten the length of the proposed tunnel means that most of
the upgraded route would be above ground through the National Park, or adjacent to
its boundary and within the setting of the Park. While we do not yet know exactly
what is planned for the A628, it appears from the information about expressways in
the SRN Initial Report that the plan is to upgrade the road to motorway standard.
Such extensive road-building is completely inappropriate in a National Park.
5. There is a long-established presumption against significant road widening or the
building of new roads in National Parks. This is clearly set out in paragraph 5.152 of
the National Policy Statement for National Networks3 published in 2014, which states
that “there is a strong presumption against any significant road widening or the
building of new roads and strategic rail freight interchanges in a National Park, the
Broads and Areas of Outstanding Natural Beauty, unless it can be shown there are
compelling reasons for the new or enhanced capacity and with any benefits
outweighing the costs very significantly. Planning of the Strategic Road Network
should encourage routes that avoid National Parks, the Broads and Areas of
Outstanding Natural Beauty.”
6. In addition, paragraphs 5.150 and 5.151 of the National Policy Statement for National
Networks reiterate the more general presumption against major development in
National Parks, which is also set out in paragraphs 115 and 116 of the National
Planning Policy Framework. The Government emphasised the additional planning
protection for National Parks in the recent 25 Year Environment Plan (p57)
alongside strong support for greater enhancement of our landscapes.
7. Furthermore, Highways England also has a duty to take account of the potential
effect of its decisions and activities on National Park purposes, including activities
undertaken outside National Park boundaries which may affect land within them.
National Parks’ statutory purposes as set out in the Environment Act 1995 are:
to conserve and enhance natural beauty, wildlife and cultural heritage; and
to promote opportunities for public enjoyment and understanding of their special
qualities.
8. This means that Highways England should be seeking to conserve and enhance
National Parks through all of its activities. High volumes of traffic already have a
negative impact on the tranquillity and natural environment in some parts of our
National Parks. It is completely inappropriate to propose projects which would
increase these negative impacts. Instead Highways England should be
demonstrating how it has fulfilled this duty by placing a much stronger emphasis in
RIS2 on measures to reduce the negative impacts of the SRN on National Parks.
This should include, for example, a commitment to prioritise these areas for
measures which reduce noise and light pollution such as low impact lighting and
noise-reducing road surfacing. Tranquillity and dark skies are two of the special
qualities for which many areas of National Parks are particularly valued.
9. Highways England should also be demonstrating that it takes its responsibilities
towards National Parks seriously by actively managing demand for road capacity on
sections of the SRN which pass through National Parks and instead encouraging the use of routes which avoid these protected areas; and placing a much stronger emphasis on investment, and promotion of, public transport as an alternative to roadbuilding.
10. Unfortunately, our recent experience with proposals for the SRN in other National
Parks provides evidence that Highways England does not always take account of the
additional protection afforded these areas. For example, the consultation on the A27
Arundel bypass last autumn only included options which involved unacceptable
damage to the South Downs National Park and failed to take account of alternative
options that would have reduced the impact on the National Park.
11. The consultation document states that one of the key aims of RIS2 is to “make a
positive contribution to the environment”. This will only happen if Highways England
takes its responsibilities towards National Parks seriously. We therefore seek a
reassurance that the strong presumption against significant road widening or the
building of new roads in National Parks will be upheld and that damaging proposals
such as the A628 upgrade will be abandoned.
