1. The road is not designed or intended to combat our local traffic problems:
The prime objective of the scheme is to improve communications between Morecambe, Heysham (particularly the Port of Heysham) and the M6. Port-related HGV traffic makes up a very small proportion (less than 3%) of existing traffic and the contribution to Lancashire’s economy is exaggerated. It employs only about 100 people directly, and handles just 0.7% of tonnage moved through all UK ports. Recent changes in ownership (for the third time in four years) suggest an uncertain future.
The perception that port traffic congests local roads can be dispelled by studying data presented in the Major Scheme submission. The HGV modal split in total is a small percentage. 1998 data suggest that 325,000 freight vehicles used Heysham on an annual basis. Projected increases will add about 75,000 vehicle movements by about 2007/2008. (Lancaster Guardian 18th Mar 2005). Daily flow will then become a projected 1,100 vehicles.
Using LCC traffic flow projections for the “Do Minimum” scenario in 2010, this means that freight traffic from the Port of Heysham accounts for about 3-4% of the total traffic flow across the Skerton and Greyhound bridges. Journey times between the port and Junction 34 are predicted to be 19.6 minutes without a link, and 10.3 with it. The projected time and cost savings for port traffic is relatively insignificant as a proportion of the total costs for freight journeys that end or originate well beyond the Lancaster transport boundary.
The amount of HGV traffic encouraged to divert to Heysham will be limited when the major origination points of this traffic are from the south and east. HGV traffic using west coast ports to and from Eire will consider the substantial costs of travelling a further 30 miles beyond Liverpool as a major drawback against the benefits of just a few minutes time saving. Heysham Port is therefore already disadvantaged both in terms of costs and facilities offered.
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2. The local Morecambe-Lancaster congestion problem is not properly addressed:
While traffic flows on the Lune bridges are forecast to reduce in the opening year, those on the Lancaster gyratory system barely change, and district congestion problems are not addressed. Within a decade or so, traffic growth will bring volumes in Lancaster back to current levels.
The Major Scheme Business Case includes traffic flow projections for 2010 and 2025, with and without the link road. They show that traffic in 2025 in Lancaster would be considerably higher than 2001 levels. Most parts of the District will have similar or worse traffic in 2025 with the link road than in 2001 without it.
Lancaster Centre, Galgate, Heysham, Torrisholme, White Lund, Hest Bank, and Conder Green and Slyne would all have significantly more traffic in 2025 than in 2001. Greyhound Bridge, parts of Skerton and the Coastal Road between Morecambe and Carnforth are the only areas which would have significantly less traffic in 2025.
This points to the complete failure of the scheme to achieve its aim of relieving traffic in Lancaster. The 2001 public consultation brochure only showed opening year traffic flows and did not say how long it would take for traffic growth to outstrip temporary reductions.
No data is presented in the Business Case to analyse the true causes of congestion in the district. However, survey data presented by LCC (at the Lancaster Local Plan Public Inquiry in October 1998) suggests that, of vehicles crossing the Lune bridges daily, only 9.5% were travelling to or from the M6, and a further 10.5% were travelling between the A6 and Heysham.
So only 10-20% of traffic in the most congested part of the network can be considered long-distance through-traffic. The rest is locally generated and many journeys could be transferred to other modes. But LCC has not presented any proposals for alternative travel modes that are independent of the link road.
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3. There is no convincing evidence that the road will regenerate Morecambe or Heysham:
One of the main justifications of the road is the economic regeneration of the district, but the Council's "Economic Impact Report", which makes this claim, is not based on impartial analysis, but on wishful thinking. The Council calculates that 6,014 jobs will be created on 6 sites, but the sums are bogus. It claims: available land exists, if the road is built, the land will fill with jobs. But it doesn't say how.
Some sites have problems with land contamination: who will pay for the clean-up? And how many jobs will be lost, as outside businesses can serve the district more easily? Any road-building project means that wealth and jobs can flow out of a district as well as into it.
Lancaster Business Park is being developed now, but the take-up of land has been low (1.5 hectares out of 8 ha between 1998 and 2004). So access to the motorway does not mean that available land will automatically be developed. The road would not help Bailrigg Business Park, which the NWDA has identified as the only critical Business Development Site in the district, or the Luneside regeneration area, which is a matter of local & regional priority.
There is no evidence to show that building a link road would assist the development of tourism. That depends more on local attractions, weather, and cheap flights abroad, rather than journey times through Lancaster.
A recent business survey found that most businesses had difficulties recruiting staff. By far the biggest reason given was the lack of applicants with the right skills. Not lack of a link road - lack of skills. We believe that a better way to achieve regeneration would be to invest in local businesses and skills.
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4. The cost of the road is escalating rapidly:
The cost of the scheme in the Business Case is £118 million (at 2002 values). This is much higher than the £62 million cost of the scheme that was conveyed to the general public in 2001. Even in 2004/5 LCC has been presenting costs in the order of £87 million, failing to reflect the maintenance and taxation elements, and the government requirement for a 35% optimism bias.
The costs presented do not include those associated with noise mitigation measures. The Faber Maunsell report cautions that where other significant costs cannot be presented in monetised form then the analysis presented does not provide a good measure of value for money.
The capital costs of the scheme do not include estimates for maintenance, which may be considerable within the design life horizon of the road. Phase 1 of the Link road is already requiring substantial remedial work to the street lights due to corrosion caused by coastal salt. This amounts to several hundreds of thousand pounds and comes within 10 years of its opening date.
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5. There has been no meaningful public consultation:
There has been no real consultation on these plans and LCC still use the MORI 2001 poll for justification. They claim it shows 79% wanted a link road, but the actual support for the northern route was: 16% strongly support and 28% tend to support.
Only road-building alternatives were offered (“a bypass, or nothing”). The same poll asked which policies people would support to solve transport problems in Lancaster. Only 15% wanted to build more roads, but 42% wanted to improve public transport and other alternatives to the car.
Since then, the detailed plans have been revealed. In the only recent test of public opinion, people who saw the plans at the LCC exhibitions completed LCC’s own questionnaires. When asked about the road, their answers were: Strongly support 16%, tend to support 5%, tend to oppose 8%, strongly oppose 68%. So 76% were clearly against this road once they saw how massive and destructive it would be.
The exhibitions were held “to inform the public about the proposals”, although LCC now claim they were consultations. In fact, many objections were made, but only one produced a change (underpass on Torrisholme Road). Again, no alternatives to building a road were offered.
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6. It would destroy our countryside:
The new road would be in extreme contrast to the character of the Green Belt north of Lancaster, and any mitigation measures would change the natural coastal drumlin topography. The mature trees, hedgerow vegetation and general openness of the landscape cannot be substituted.
The scheme would destroy over 70 hectares of agricultural land that are feeding grounds for 5 species of bats recorded locally. There would be major disruption to the travel and feeding patterns of these protected species, and there may be a need for licensing approval.
Many veteran trees and over 11km of hedgerows would be removed, 87% of which are protected under the Hedgerow Regulations 1997, losing what is recognised as the most important habitat type for numerous flora and fauna. Hedgerows would not have acceptable mitigation habitat for about 15 years or more, and the ultimate ecological structure would be very different from that which exists now. Mature trees cannot be replaced except in the extreme long term.
Lancashire County Council (LCC) would plant trees and screening at the A683 and say it would be operational “in a short period of time”. But discussion papers by ADAS (Agricultural Development & Advisory Service), the consultants who studied the environmental effect of the road, contradict this, and recognise that such vegetation takes 15 years or more to become substantial screening, and even longer for mature trees to develop. It is possible that they would not be replaced in our lifetime.
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7. The project would damage the environment:
Currently, most of the route is tranquil. To the West, the road would be on massive embankments in order to cross Torrisholme Road at 26 ft and the main coast railway line at 43 ft. Lights, lit all night “for safety reasons”, would be 33 ft above that. Mitigation would be limited on the severe banking. The road would be seen for miles around. Visual, noise and light pollution would result.
Increases in greenhouse gases and local air pollutants are forecast. Carbon dioxide (CO2) increases by 24,000 tonnes, Nitrogen dioxide (NO2) by 140 tonnes, Particulate Matter (PM10) by 4 tonnes. The Local Transport Plan includes mandatory targets for PM10 and NO2. This would require a reduction of 10% each year for 5 years. But it predicts a reduction of only 3.2% in the first year, with later increases brought about by this road scheme. This could jeopardise Britain’s ability to meet binding international pollution targets.
The western edge of the proposed road is in an area that the Environment Agency has designated as at risk to flooding, and is already prone to poor drainage and localised flooding. Contaminated run-off held by the SUDS (so-called “Sustainable Drainage Systems”) ponds might overspill into the surrounding area. The SUDS ponds do not support wildlife. They are drainage systems that are usually shallow and dry out for much of the year. Rainfall brings concentrated petrochemical pollutants to the ponds where they accumulate. This produces an environment with very little ecological value.
Cuttings in the eastern end of the route may have severe impacts on the surrounding water flows. Changes to the ground water levels may change the nature of the agricultural land, which may no longer produce the quality grazing for which it is valued.
Pillar supports for the link bridge will severely intrude into the bed of the river, disrupting protected species (salmon, crayfish). Holding ponds for salmon and siltation beds for crayfish will be especially vulnerable to changes in the flow of the river and erosion to the banks and riverbed. The River Lune, Howgill Brook, Long Bank Brook, Cote Beck now have a “Good” water classification, but this may be compromised by the building and operating of the new road.
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8. The road would adversely impact on the health and well-being of our communities:
LCC admit that the structure would have a major adverse impact in the Torrisholme area. The Business Case states that it will “visually separate and dominate the settlements of Scale Hall and Torrisholme in this location, introducing a built feature which is out of scale with the developments along the B5321”.
Halton would see an increase in traffic attracted to the new M6 link point. The new Shefferlands roundabout would be very busy, coping with a predicted 5,200 traffic movements per day. Slyne would see traffic almost doubled on the A6 approaching the traffic lights at the access to the link road.
The provision of an additional cycleway and footway alongside the busy dual-carriageway is scant compensation. It is unlikely that people will want to walk or cycle in such a polluted atmosphere.
Increasing road capacity, overall vehicle numbers and traffic speeds (70 mph) could lead to increased accidents and accident severity. There have been recent incidents of HGVs overturning at large roundabouts on the A683, causing spillage and contamination. The prospect of future incidents will be increased with two roundabouts on the proposed road with much higher approach speeds.
There would be significant disruption to Lancaster and Morecambe College. This contradicts Government objectives to improve the health and physical well being of people, as it takes land from the college sports fields, and separates students from the remainder by a busy dual carriageway. It contradicts too the Government aim of enhancing education opportunities: large traffic flows would be immediately adjacent to teaching rooms, making it difficult for students to study.
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9. The road is only the beginning of the destruction:
Most of the scheme is in the Green Belt. The raised part of the road would affect the open character of this part of the countryside, contrary to Green Belt policy. It would probably encourage "ribbon development" at a later date. Regional Planning Guidance 13 policy SD3 refers to Lancaster as a "historic town requiring continual conservation with sensitive integration of development, where needed, plus a regard for maintaining and enhancing [its] setting." It is hard to see how this road scheme supports this end.
This area is part of Countryside Agency’s Joint Character Area 31 “Morecambe Coast and Lune Estuary”. In its report “Countryside Quality Counts”, which tracks change in the English countryside, this area was described as suffering "change inconsistent with character". The road scheme would make this worse. The scheme extends the urban footprint further into the open countryside.
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10. The scheme does nothing to curb car usage:
The Government now accepts that we cannot keep on building new roads to relieve congestion. Alistair Darling (Secretary of State for Transport) said recently “We cannot build our way out of our present congestion problems.” (June 2005).
Schemes to transfer freight to rail should be investigated more thoroughly for Heysham port, following the lead from other British ports. This road scheme fails to support policy outlined in the Transport White Paper to make best use of existing infrastructure, or to reduce the impact of freight on congestion and the environment. The Business Case concedes that there is no impact on freight interchange.
Projected flows suggest that the road would increase traffic by 13.9%, well above the 2010 do minimum projection, and far exceeding natural growth of traffic. It is in direct conflict with Government aims expressed in the Transport White Paper to reduce traffic to 2001 levels by 2010. The level of growth also hampers policies relating to air quality and noise.
Regional Planning Guidance suggests that where port-related road traffic compromises local highway networks there should be a presumption in favour of making best use of existing local infrastructure where possible. The proposed scheme does not consider any other links such as the existing branch line of the railway infrastructure, or how to make best use of existing road space.
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