1 London Borough of Hillingdon WRITTEN SUMMARY of ORAL

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1 London Borough of Hillingdon WRITTEN SUMMARY of ORAL London Borough of Hillingdon WRITTEN SUMMARY OF ORAL SUBMISSION AND INFORMATION REQUESTED NOVEMBER 2015 (ENVIRONMENT HEARING) – APPENDIX E – CUMULATIVE ASSESSMENTS AND LOCAL IMPACTS HIGHWAYS ENGLAND'S RESPONSE 1.1 The following comments are in response to questions various questions (including 2, 8 and 23) of the Environment hearing specific topics (transport themes). The response to the questions have been grouped together to provide a definitive position on the cumulative assessment and local impacts which are inherently linked. 1.2 Additional information was supplied to the Council by the applicant and this has now been reviewed and considered in the Councils response. Background 1.3 Prior to considering the cumulative and local impacts of the scheme, it is necessary to establish the context. The M4 provides the east/west access for the southern part of the London Borough of Hillingdon. It is therefore the primary route into and out of London. In addition, much of Hillingdon's business and industrial uses are located in the south of the Borough near Heathrow airport. The M4 and its links into the south of the borough are therefore extremely important and commensurately busy. 1.4 There are two junctions serving Hillingdon's local network, Junction 3 (connecting the A312) and Junction 4 (M4 Heathrow Spur and A408). The map below shows the M4 in the context of the South of the Borough. Deadline V - Responses to Summaries of Issue Specific Hearings: LB Hillingdon - Environment Appendix E 1 Highways England Figure 1; Reference Map Deadline V - Responses to Summaries of Issue Specific Hearings: LB Hillingdon - Environment Appendix E 2 Highways England 1.5 In turn, Figure 2 below; air quality map, shows recent modelling information on the areas exceeding air quality limit values. The map shows significant problems on the supporting network to the M4 particularly around the A312 (although mapping is not available for that part of the road outside of the borough). Figure 2; Air Quality Deadline V - Responses to Summaries of Issue Specific Hearings: LB Hillingdon - Environment Appendix E 3 Highways England 1.6 It is essential that the impacts of the proposed development are fully understood to ensure a suitable approach to mitigation. Highways England acknowledges that the proposed scheme will result in a freer flowing motorway and therefore a more attractive transport option. They acknowledge that the proposed scheme will result in an increase in traffic on the motorway. It would therefore be expected that there would be an increase in traffic to and from each of the junctions along the route. Highways England Comment 1.6.1 Highways England acknowledges that the M4 provides an important link to the local highway network within the London Borough of Hillingdon, providing access to Hillingdon’s business and industrial centres and facilitating future development within the Borough. Highways England agrees that the proposed Scheme will result in an increase in traffic on the motorway and to a lesser extent, an increase in traffic flows using junctions 3 and 4. Information on these traffic impacts has been provided to LBH in response to questions raised by email to Highways England. A copy of the information provided to LBH is at Attachment 2 to this Appendix E. This information demonstrates that the majority of the increase in traffic at junctions 3 and 4 is through traffic and not turning to/from the local road network at either junction. Cumulative Assessment 1.7 The Council responded to initial requests in 2014 for the relevant information on what it considered reasonably foreseeable development to be included within the ES as part of a cumulative assessment. However, at the hearing it was established that the baseline for the transport assessment was 'frozen' in 2013 thus predating the request. Highways England Comment 1.7.1 In response to a request from Highways England in December 2014 for information on developments to be included in the environmental cumulative assessment, LBH submitted a list (as provided at Appendix 2 to LBH’s comments on the Examining Authority’s first written questions) of some 25 sites that in their view should be considered as part of that assessment. Highways England has reviewed each of these sites, including those that have come forward after the freeze date for traffic modelling purposes of February 2014. A copy of the tabulated list, together with Highways England’s responses, is included appended to the end of this response document (Attachment 1 to this Appendix E). For each of the sites put forward by LBH for consideration, Highways England has reviewed the relevant planning application documentation, including the applicant’s transport assessments. In the majority of cases the applicant had demonstrated to the Council’s satisfaction that there was no net detriment to the local transport network arising from the development or that the additional trips associated with the development had already been accounted for within the NTEM growth allowed for in the M4 model. Accordingly, none of the sites other than the NATS site and Southall Gas Works in LB Ealing, has been identified as requiring individual assessment. These latter two sites have been explicitly assessed within the M4 traffic forecasts. 1.8 As a consequence the list of developments used in the transport assessment outlined in Appendix 16.2 is different from the more comprehensive list of developments outlined Appendix 16.1 that are indicated will be used in cumulative assessments. Deadline V - Responses to Summaries of Issue Specific Hearings: LB Hillingdon - Environment Appendix E 4 Highways England Highways England Comment 1.8.1 Chapter 16 of the ES (Examination reference APP-156) describes the approach undertaken to the assessment of combined and cumulative effects. As explained in paragraph 16.3.4, a list of development proposals was compiled, with the last update being in January 2015. It is acknowledged that LBH was one of the six authorities from the total of 11 ‘host’ authorities who provided input to this process. As further explained in paragraph 16.3.11, a study area defined as being within 1km of the M4 was adjudged to be appropriate to assess the cumulative environmental impacts. Accordingly Appendix 16.1 (Examination reference APP-356) lists those developments within the 1km band that were included in the cumulative environmental assessment. The traffic forecasts for the Scheme (on which the air quality and noise assessments were based) were developed from information on transport and development proposals collated up to February 2014. This assessment was not restricted to the 1km band and instead covered the wider traffic model study area. Consideration was given to the need to model those developments that met the criteria set out in paragraph 16.3.6 of the ES. Where the forecast growth allowance for population and/or employment for the particular model zone under consideration within NTEM was considered to adequately take account of the proposed development, the decision was taken that it was not necessary to explicitly model the development. Where there was a significant difference between the existing land use and that proposed with development and therefore where a growth factor approach would not fairly represent the impact of the development, the decision was taken to explicitly model the proposed development. Appendix 16.2 lists those developments included in the traffic model. Those developments in Appendix 16.2 that fall within the 1km band and therefore qualified for consideration in the separate environmental (excluding air quality and noise) cumulative assessment are highlighted in yellow in Appendix 16.2. 1.9 It is therefore clear that the transport assessment did not clearly consider the future developments determined to be reasonably foreseeable. However, at the hearing, Highways England indicated whilst some developments were specifically referred to in appendix 16.2, others not referenced were in any event accounted for in their forecasted growth scenarios. Highways England Comment 1.9.1 As explained above in paragraph 1.8.1, Highways England undertook a comprehensive assessment of future developments. If the application of a growth factor based on NTEM to existing land use fairly represents the effects of future development in scale and location, it is not necessary to individually model it. That does not mean that individual development proposals are ignored; account is taken of them in the overall forecasts. 1.10 It remains unclear why Highways England identified some specific developments, but not others. Furthermore, it is not clear what assumptions have been made for the future growth, particularly in Hayes (linked to the A312 and then Junction 3) where significant strategic growth has been identified by the Council. 1.11 Figure 3 below; Cumulative development map, identifies the range of developments, some partially completed (with permission), some with permission but not commenced, some in the planning process (submitted but not yet approved) and others allocated for future growth. Deadline V - Responses to Summaries of Issue Specific Hearings: LB Hillingdon - Environment Appendix E 5 Highways England Figure 3; Cumulative development map Deadline V - Responses to Summaries of Issue Specific Hearings: LB Hillingdon - Environment Appendix E 6 Highways England 1.12 The total of this development amounts to over 5000 new homes and hundreds of thousands of sqm of new commercial uses (including business and industrial). These will all add significant traffic to the local area, including in particular the A312 and Junctions 3 and 4 of the M4. 1.13 In addition, the Council is keen to understand the level of growth allowed for along the A4 (south of the M4) and in particular the amount of hotels and other growth in close proximity to Bath Road. Highways England Comment Growth Assumptions 1.13.1 In response to the question relating to the growth assumptions within the M4 smart motorway model, the approach to developing forecasts from a validated base year is to apply growth factors to the base year trips.
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