Local Impact Report for Borough Council Development Consent Order Application for M4 Smart Motorway Junctions 3 to 12

8th October 2015

M4 Smart Motorway DCO: Slough Local Impact Report

M4 (Junctions 3 to 12) (Smart Motorway) Development Consent Order Application Local Impact Report

Contents

1 INTRODUCTION AND SLOUGH CONTEXT 2

2 POLICY National Policy Statement for National Networks (NNNPS) 2 Slough Local Plan 2 Slough Local Transport Plan 3 Green Belt 4 3 ENVIRONMENT Landscape and visual impact 4 Flooding 6 Ecology and nature conservation 6 Air Quality 6 Noise and vibration 13 Heritage assets 15 4 ENGINEERING AND DESIGN Motorway Junctions 16 Overbridges 16 Underbridges 17 5 IMPACT ON ROAD USERS Traffic Safety and information 17 Traffic on Local Roads 18 Non-motorised forms of travel 20 6 LAND ACQUISITION 21 7 SOCIO-ECONOMIC ASPECTS 22 8 OTHER MATTERS Scheme programme and Cumulative Effect of Other Strategic Infrastructure Schemes 23 Junction 5 Langley Interchange and SBC SMaRT scheme 24 Windsor Branch Line Services 25 Cost of Legal Orders 25 APPENDIX 1 Environmental barriers and air quality 26 APPENDIX 2 NO2 Effect of barriers and speed controls for residential (Separate receptors spreadsheet)

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1. INTRODUCTION AND SLOUGH CONTEXT

1.1. This Local Impact Report sets out the preliminary position of Slough Borough Council (SBC) in relation to the issues of concern in the Borough arising from the M4 Smart Motorway Scheme (referred to as ‘the Scheme’). The report also responds to the First Written Questions of the Examining Authority (ExA) where relevant to Slough.

1.2. Slough is a compact densely built-up Borough with a population of some 143,000. The M4 fringes the southern edge of the town and runs approximately parallel to the A4, the historic route between and Bath. Three motorway junctions serve Slough:  Junction 7 linking with the A4 via the Huntercombe Spur;  Junction 6 linking with the A355 which connects southwards with Windsor and northwards with Slough Trading Estate, South and the M40; and  Junction 5, the Langley Interchange, linking with the A4 and giving access to Heathrow and Slough town centre.

1.3. Between Junctions 7 and 6 the M4 runs close to residential areas and public open space at . East of Junction 6 the motorway fringes residential areas and school grounds at and Herschel Park. East of Junction 5 it severs the built up area, with Langley to the north and Brands Hill to the south. Air quality, noise and visual amenity are major concerns and Slough Borough Council (SBC) is anxious to protect its residents and others from negative impacts arising from the Smart Motorway scheme.

1.4. Because of its proximity to London, Heathrow and the M25, and being home to the extensive Slough Trading Estate, the Borough experiences high levels of traffic. Traffic leaving or joining the M4 at Slough regularly causes queuing and congestion on the local road network during peak periods. Occasionally, heavy congestion or an incident on the M4 can bring traffic in Slough to a virtual standstill as drivers divert off the motorway. SBC notes from the Socio-Economic Report (2.1.1 APP-090) that the M4 typically carries over 130,000 vehicles per day and that this is forecast to increase to an average 160,000 vehicles per day over the next 20 years. Unless properly managed, this additional traffic could significantly increase pressures on the local road network.

2. POLICY

National Policy Statement for National Networks (NNNPS)

2.1. SBC takes particular note of those sections of the NNNPS that require HE to provide evidence that they have considered ‘reasonable opportunities to deliver environmental and social benefits’ as part of the Scheme (NPS para 3.3); and ‘use reasonable endeavours to address the needs of cyclists and pedestrians in the design of new schemes’ (NPS para. 3.17).

Slough Local Plan

2.2. SBC confirms that Table 1 of APP-089 accurately identifies the Development Plan for Slough, i.e.  Slough Borough Council Local Plan (March 2004);  Saved Policies (September 2007);  Core Strategy;  Development Plan Document 2006-2026 (December 2008).

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2.3. The Highways (HE) Planning Statement refers to Core Policy 7 and SBC draws attention to the following wording: ‘Development proposals will, either individually or collectively, have to make appropriate provisions for.... improving air quality and reducing the impact of travel upon the environment, in particular climate change.’

2.4. SBC also draws attention to Core Policy 8 which includes the wording: ‘Development shall not: a) Give rise to unacceptable levels of pollution including air pollution, dust, odour, artificial lighting or noise’.

2.5. Reference is correctly made in the HE Planning Statement (6-49) to the ‘Action Plan for Slough Air Quality Management Areas Nos. 3 and 4’, November 2012. However SBC wishes to make clear that the Action Plans for Air Quality Management Areas no. 1 (M4 corridor) and no. 2 (Brands Hill) were included in ‘Annex C of the Second Local Transport Plan, March 2006’ which superseded the provisional document of July 2005 referred to in 6-48. Furthermore, these action plans were revised and specific measures incorporated into the ‘Slough’s Third Local Transport Plan 2011- 2026’ (para 5.6.4.): see 2.8 below.

2.6. SBC’s comments on HE’s assessment of the project against these Core Strategy policies (APP- 089) are as follows:  Ref Planning Statement 5.4.25: summary description of proposals in Slough area is acknowledged but it excludes reference to construction compounds near Junctions 6 and 7;  5.4.26: SBC agrees that ‘very special circumstances’ apply in relation to Green Belt but not necessarily in the case of the proposed Construction Compounds (see 2.10 below);  5.4.27: SBC accepts that there would be no significant detrimental effect on nature conservation interests or watercourses and the floodplain; in relation to archaeology and landscaping, SBC accepts that mitigation measures and enhancement measures are proposed but not that they would satisfactorily comply with the policy requirements;

2.7. SBC confirms that there are no other developments which are either proposed in or in accordance with the Local Plan which might be affected by the project. However there are other strategic infrastructure schemes proposed in the vicinity of Slough and the potential cumulative effect of these should be taken into account: see 8.1-8.3.

Slough Local Transport Plan

2.8. SBC confirms that Table 1 of APP-089 accurately identifies the Local Transport Plan (LTP) for Slough, i.e. the Slough’s Third Local Transport Plan 2011- 2026. However no reference is made to the Supplementary Strategy Documents (SSD) that give further details on Slough’s local transport strategy. Of particular relevance are those relating to network management and Intelligent Transport Systems (ITS).

2.9. SBC’s comments on HE’s assessment of the project against the policy guidance set out in the LTP are as follows:  5.4.28: SBC accepts that the Scheme is in generally alignment with the LTP framework but does not agree that overall changes in air quality would be insignificant nor that noise impacts would be negligible;  SBC does not consider that the Scheme would directly contribute to LTP strategies aimed at increasing the uptake and mode share for public transport, walking and cycling

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(reflecting NNNPS para.3.17) but it is recognised that there are opportunities open to HE to assist in delivery of these strategies, i.e. o Partnership working to provide bus priorities at Junction 5 Langley Interchange A4 roundabout for SBC’s SMaRT bus rapid transit scheme to link Slough and Heathrow (see 8-4,8.5); o Further improvements for pedestrians and cyclists in relation to Junction 5 Langley Interchange; o Recreation Bridge: improvements to National Cycle Network Route 61; o Old Slade overbridge: bridleway provision for Colne Valley Trail; o Wood Lane overbridge: improvements for pedestrians and cyclists; and o Enhancement of routes required for rights of way diversions.

2.10. An important part of the Slough LTP strategy is to influence travel behaviour through a ‘smarter choices’ programme which promotes sustainable transport as an alternative to private car use; there is no reference in the Socio-economic Report to these aspects of the LTP3 and the effect on mode shift . As the result of Government support through the Local Sustainable Transport Fund (LSTF) SBC has been actively implementing this programme for the last three years and additional LSTF funding is in place to extend the programme until March 2016. The DCO application for the Scheme offers the opportunity to extend the programme further as a ‘smarter choices package’ that would complement the Smart Motorway project and help deliver the environmental and social benefits foreseen in the NNNPS as touched on in 2.1 above.

Green Belt

2.11. The M4 lies in the Green Belt for most of its route through the Borough. SBC accepts that the proposed operations and gantries would not have a material impact on the openness of the Green Belt nor on the 5 purposes of that designation. However it is considered that the proposed construction compounds would, bearing in mind the uncertainties surrounding the number actually needed; the location of the main office; and their duration (potentially for the whole of the 5-year construction period), would be inappropriate development and are likely to affect the openness of the Green Belt.

3. ENVIRONMENT

Landscape and visual impact

Operational Scheme

3.1. SBC accepts the baseline information for HE’s landscape and visual assessment. The viewpoints put forward by the HE in February 2015 (APP-148 para 8.2.8) as representative of available were accepted by SBC on the basis that the HE would provide a more detailed assessment of the visual impact of the proposed new bridges. HE did suggest that further photomontages might be prepared once the DCO application had been submitted: SBC notes those provided in APP-300 but is not certain whether any additional photomontages have been produced.

3.2. The Scheme would inevitably have a visual impact on the Borough, especially in relation to new bridges and other structures; removal of vegetation for widening; installation of gantries, noise barriers and lighting; and construction compounds. SBC agrees with the Examining Authority (ExA) that it is not clear how the HE defines ‘significant’ in relation to

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the visual impact of the Scheme (APP-148). There are also uncertainties, as pointed out in the ExA’s questions, about the dimensions of the proposed gantries; the dimensions, materials, colour and location of environmental (noise) barriers; and the design of new lighting.

3.3. SBC notes the landscaping proposals put forward in the Environmental Master Plan (APP- 351) but on present evidence is not satisfied that these would provide the necessary mitigation in winter as well as summer conditions. In the Planning Statement (APP-089, 5.2.18) it is suggested that ‘opportunities for environmental enhancement measures have been taken where possible’. SBC considers that there are further enhancement opportunities that should be taken.

3.4. In terms of structures SBC is particularly concerned about the visual impact of:  Huntercombe eastern realignment of slip road (views from nearby housing, Mercian Way Recreation Ground and allotments);  Oldway Lane overbridge (views from nearby housing and Mercian Way Recreation Ground; new bridge 1.1m higher than at present);  Wood Lane overbridge, noise barrier to the west and retaining wall to east (views from nearby housing and public open space; new bridge 1.4m higher than at present);  Junction 6 slip road realignments (impact on existing vegetation);  Datchet Road overbridge (view from Upton Court Park direction; loss of trees through realignment of highway); and  Junction 5 Langley Interchange widening (prominent feature viewed from both north and south with significant disturbance to existing tree and shrub screening; new piers, embankments and retaining walls).

3.5. SBC is also concerned about the visual impact of the proposed gantries, in particular the following which have the potential to be obtrusive from neighbouring residential areas:  G5-11 Huntercombe Spur (not specifically identified on Sheet 20 Inset 1);  G5-10 Cippenham, Mercian Way Recreation Ground;  G5-03 and G5-5, Wood Lane;  G4-16 east of A332 Prince of Wales Bridge, adjacent to Winvale (SBC supports the ExA’s query about the scope for mitigation);  G4-13 Datchet Road; and  G4-02 Ditton Road.

3.6. SBC agrees with the ExA that more information is needed on the design of new lighting- especially those to be mounted on the central barrier - and how light spill would compare with the existing.

3.7. The installation of new or replacement environmental (noise) barriers could have a significant visual impact depending on the design and materials; provision of screening by vegetation; and the increased heights suggested in the Enhanced Mitigation Strategy (APP- 351). The proposed barriers on the Windsor Rail Branch bridge and Junction 5 Langley Interchange bridge would be particularly prominent features and need close attention.

3.8. It is noted that draft DCO Requirement 9 refers to a landscaping scheme being submitted to the Local Planning Authority for approval. Draft DCO Requirements 7 and 8 also mean that both the CEMP and EMP would need SBC approval. However SBC is concerned that the outline CEMP (APP-293) is not sufficient to secure mitigation and that too many details are left to the future contractor. This concern is increase in the light of the ExA pointing out that

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Requirement 8 as drafted leaves it open for the CEMP being modified by the HE after the Scheme had commenced without further reference to SBC and without any guarantee that the necessary mitigation would in fact be implemented.

Construction Compounds

3.9. Proposed Compound No. 9 would be located in a prominent position at the junction of Sutton Lane and A4 London Road/ Bypass. SBC is concerned about its potential visual impact, especially in relation to nearby housing and when fringe trees and hedges are not in leaf. As suggested by the ExA, the impact of construction compound lighting and from any night time construction works should have been assessed: such lighting could detract significantly from residential amenity.

3.10. Proposed Compound No. 8 is located outside the Borough boundary but has the potential to be visually obtrusive, particularly –as with Compound No. 9 - when existing vegetation is not in leaf.

Flooding

3.11. SBC published its Strategic Flood Risk Assessment in May 2012 and notes the comments of the Environment Agency in RR-249 about HE’s floodplain risk assessment. The Scheme proposes the extension of the Chalvey Culvert which passes under the M4: SBC has no adverse comments on the proposed works subject to them being carried out with minimum disturbance to existing vegetation.

Ecology and nature conservation

3.12. SBC does not challenge the conclusions of Table 9.5 APP-149 about the residual effect of the Scheme on ecology and nature conservation. The presence of the Herschel Park Local Nature Reserve is recorded in APP-149 but SBC is unable to find a full description of this LNR in the document. It is not clear what the potential impact of the Scheme would be on the south- eastern corner of the reserve in relation to works on the Datchet Road overbridge and gantries G5-03 and G5-05.

3.13. SBC notes that the presence of bats was detected at the Windsor Rail Branch bridge (9.10.37 of APP-149), a factor that would need to be taken into account during the construction phase. It is also noted that a full habitat survey was not made at the site of the proposed Compound No. (9.11.14 of APP-149).

Air Quality

Operational Scheme

3.14. Air quality is a material planning consideration and a significant public health issue affecting the health of hundreds of thousands of the general population in England and potentially thousands of residents in Slough who live within Air Quality Management Areas. The principal cause of poor air quality in Slough is from road traffic emissions. The principal cause of poor air quality within Air Quality Management Area (AQMA) 1, located in Slough along sections it shares with the M4, is road traffic emissions from the M4. All of SBC’s

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AQMAs have been declared due to breaches of the National Air Quality Objective for annual

nitrogen dioxide (NO2).

3.15. SBC has a comprehensive air quality monitoring network in place including monitoring air quality within AQMA 1, M4 Air Quality Management Area and the results are presented in Table 1 below and clearly illustrate that sites are consistently breaching the National Air Quality Objectives/EU limits (figures in red).

Table 1: Slough Borough Council Air Quality Monitoring Network M4 (AQMA 1) Type Air Quality Data Sets for M4 AQMA 1 5 within (2009 - 2013) Ratified year AQMA Distance Grid Reference Annual Mean (ug/m3) Ann. Site M4 From M4 X Y 2009 2010 2011 2012 2013 Av. Chalvey Air Quality Monitoring 45m Station Yes (north) 496562 179019 44.4 41.8 44.2 39.0 37.7 41.2 Paxton 30m Avenue Yes (north) 496050 179258 40.0 38.0 38.9 47.5 42.1 41.3 Spackmans 40m Way Yes (north) 496272 179187 39.6 41.0 44.0 43.4 43.6 42.3 60m Ditton Road Yes (north) 500851 177890 38.6 40.9 40.5 41.0 37.2 39.6 Chalvey 45m Station Yes (north) 496562 179019 41.4 40.3 41.1 40.8 38.0 40.3 15m Winvale Yes (north) 497488 179090 42.1 40.9 46.9 48.3 44.5 44.5 Grampian 50m Way Yes (north) 501382 178101 42.1 42.3 48.1 45.1 43.3 44.2 Torridge 30m Road Yes (south) 501637 177999 36.6 47.4 41.2 39.5 43.3 41.6

3.16. SBC raises concerns about residential receptors that may be affected by both the operational and construction phases of the Scheme and in particular where the Environmental Statement (ES) lacks sufficient detailed assessment to draw conclusions or where there is absence of proposed mitigation due to exposure of poor air quality.

3.17. In response to the ExA’s question: ‘whether there are locations where EU limits for traffic pollutants would be exceeded as a result of the scheme?’ SBC considers that there: these are discussed below and set out in Table 2.

3.18. The ExA asks ‘Having regard to the final judgement of the Supreme Court in the “ClientEarth” case, does the assessment of air quality impacts set out in the ES indicate that the scheme would comply with this requirement of the NNNPS?’ There are Slough residents predicted to be affected by breaches of the EU Limit on NO2 annual mean at the year of opening (2022) and therefore, without mitigation, the Scheme would not in our view comply with the requirements of the NNNPS. This would be for either of the following scenarios: for a compliant zone (SE zone) becoming non-compliant at year of operation (2022); or if the SE zone does reach compliance by 2020 as outlined by the Government’s proposed draft action plans then the M4 Smart Motorway may delay compliance with the EU limits within the shortest possible time, unless mitigation is adopted

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3.19. The ExA asks ‘to what extent have the local authority Environmental Health Officers and Air Quality Officers been consulted on the assessment set out in Chapter 6? (APP-146) Can the applicant, local authorities and other interested parties identify areas of agreement and disagreement with regard to the assessment of air quality impact set out in the ES?’ There was no pre-consultation on the methodology applied for air quality assessment prior to submission of the ES. SBC accepts the methodology applied by HE’s consultant, including its limitations which are significant in respect of adjustment factors applied, but does not wish to dwell on technical aspects of the methodology. SBC does not accept the assessment of significance applied by the HE consultant and their justification for not adopting mitigation

for residential receptors exposed to breaches of the EU limit for NO2 annual mean.

3.20. Outdoor air quality is one of the most significant public health issues affecting the modern

world, and there is a growing body of medical evidence that the prolonged exposure to NO2 pollution may have longer term impacts on health, in particular lung function and respiratory symptoms, and there is more data coming through epidemiological studies. The most recent study completed by Kings College for London exposure assumes increased in

mortality rates as a result of exposure to N02 this follows guidance from the World Health organisation,. see link to Kings College report. https://www.london.gov.uk/sites/default/files/HIAinLondon_KingsReport_14072015_final.pdf

3.21. Government policy with respect to air quality has substantially changed in recent months, further due to the successful Supreme Court Challenge by ‘Client Earth’. The UK Government have now submitted (September 2015) a consultation on draft plans to improve air quality. We would request the ExA to take these new draft action plans and evidence base into account, as these plans are likely to have repercussions for the M4 Smart Motorway Scheme.

3.22. Perhaps of most significance is the evidence annex and reference to NO2 exposure where it applies by the recent Committee on Medical Effects of Air Pollutants (COMEAP) advice

directly linking NO2 exposure to mortality. DEFRA has applied this evidence to the exposure levels across the UK and suggests that exposure to NO2 is increasing mortality by the equivalent of 23,500 deaths per year and with a range of 9,500 to 38,000 deaths. Whilst the evidence on health impacts is still being assessed and is subject to a number of uncertainties a precautionary approach has been applied. Even applying the COMEAP lowest coefficient of 1% the monetised health impact of reducing NO2 to the UK is £980 million. Applying the central coefficient (2.5%) the monetised health impact of reducing NO2 to the UK is £2,495 million. See link https://consult.defra.gov.uk/airquality/draft-aq-plans

3.23. The Government primary driver for action on air quality is the impact it can have on health and the environment. The draft plans set out actions planned, being implemented and already taken at local level, regional and national level to meet the annual and hourly EU

nitrogen dioxide (NO2) limit values over the shortest possible time. Slough falls within the South East UK 0031 Zone, and has submitted 40 measures to improve NO2. The Government predict the South East Zone will be compliant with the EU limits by 2020 but only if Euro 6 emission standards perform as modelled. There is significant concern that real world Euro 6 passenger diesel car emissions standards are not performing as modelled in which case compliance may not be reached. It is noted the HE modelling attempts to verify modelled results and then applies adjustments to represent the observed long term trend (LTT) profile

of N02 concentrations described in the IAN 170/12. The HE advised that the results are considered to present a realistic worst case scenario, as only a portion of the full anticipated improvements in air quality by DEFRA guidance are assumed to occur in the Gap Analysis

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result in 2022 (year of operation). However, even applying this adjustment needs to be treated with caution because it is clear air quality is not improving at predicted rates and the trend is still continuing.

3.24. SBC has recently secured funding from DEFRA to develop a low emission strategy which it is due to publish in Spring 2016. The strategy is aimed at reducing the NOx emissions from

road transport within the Borough. The objective is to comply with all NO2 Limits by 2020 (10 years after we should be complying with the EU limits). Slough has 3 other AQMAs located along the A4 and A355 and the impact of increasing capacity on the M4 needs to be assessed in relation to its likely effect on traffic on the local road network. There is no traffic data reported within the ES section 6.9.15 (an increase of 11,700 AADT on M4) and no details relating to impact of traffic on the local road network within Slough as a result of the Scheme. Thus no evaluation of the air quality impacts on the local road network has, as far as SBC is aware, been undertaken by HE (see 5.7). This is considered by SBC to be a major failing.

3.25. As stated the South East Zone within which the Scheme mostly falls is predicted to be compliant by 2020, however the air quality assessment of the Scheme during year of operation 2022 indicates some receptors may experience a breach of the annual EU nitrogen

dioxide (NO2) limit, including within the SBC AQMA 1: this is very concerning.

3.26. SBC are even more concerned that HE considers the impact on those residents exposed to breaches of the EU Limit at the year of opening (2022) not to be significant because they are applying their own ‘non-statutory’ ‘Interim Advice Note 174/13 Updated Advice for evaluating significant local air quality effects for users of BMRB Volume 11, Section 3, Part 1 ‘Air Quality (HA207/07)’. SBC believes this advice note does not adequately address the policy changes within NNNPS and more importantly the more urgent requirements under the DEFRA Draft Action Plan to reach compliance with the EU Directive with respect to

compliance of exposure to annual concentrations of nitrogen dioxide (NO2) limit values in the shortest possible time.

3.27. Therefore the HE conclusion and Evidence in Support of Professional Judgement covered within Section 6.15.16 is challenged. The principal basis of the HE ‘significance test’ relates to the relatively small number of residents exposed to breaches of the Air Quality Objective (including (Sindlesham, Emmbrook, Dorney Reach, Lane End, Chalvey, Upton, Harlington, Brentford and Chiswick at the time of opening, 2022: a total of 18 residential receptors but with 11 of these receptors within Slough) and the medium to small ‘detrimental’ magnitude of change of the limit value. The main concern is that this is a limit value that should have be complied within in 2010. The HE is proposing no mitigation and SBC does not consider that this is an acceptable way of assessing significance, particularly with regards to the Government’s recent publication of draft action plans (currently under consultation) to

achieve NO2 compliance in the shortest possible time.

3.28. SBC has suggested to HE that speed restrictions would be an appropriate mitigation measure to alleviate poor air quality. However HE’s response has been that this would not be compliant with their national policy. SBC takes the view that is an unsound justification for not considering speed control as an effective measure to alleviate poor air quality and that it is outweighed by NNNPS and Government policy.

3.29. HE state in Chapter 6: Table 6.22 that it will be difficult to avoid or reduce or repair or compensate for the effect of the Scheme as the M4 is as an existing route and therefore

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‘traditional options to adjust alignment are limited’. However, SBC considers other options are available to mitigate the impact of the Scheme on residential receptors if they experience breaches of the EU limits at year of opening including:

 Barrier treatment: changing the height of the barriers to reduce NO2 exposure to residential receptors to within EU limits;

 Variable speed controls to reduce NO2 exposure to residential receptors to within EU limits; and  Boundary treatment of residential facades with carbon filtration ventilation systems to

reduce the impact of NO2 exposure where these are predicted to breach EU limits.

3.30. SBC has at its own expense requested its consultants Ricardo-AEA to consider mitigation options to protect Borough residents from the potential operational impacts of the Scheme in 2022. Ricardo-AEA have considered two scenarios:  The height of barriers to afford protection to Slough residents so they are not exposed

to breaches of the EU limit for annual NO2;  The average speed of traffic controlled through variable smart speed system to afford protection to Slough residents so they are no exposed to breaches of the EU limit for

annual NO2

3.31. It should be noted Ricardo do not have access to the HE base model and inputs so their modelling is not intended to recreate the HE model but is a quick assessment of the potential benefits of barriers and, demonstrate the magnitude of change achieved in respect

of NO2 reduction. It is to aid the ExA to understand the effectiveness of barriers on residential exposure to elevate levels of NO2 in breach of EU limits. Further details on the use of barriers have been supplied by Ricardo-AEA and form Appendix 1.

3.32. The receptors affected within Slough are reported below in Table 2 as is the magnitude of change taken from the ES report Chapter 6 Air Quality and Appendix 6 Results for all receptors. Only the results relevant to Slough are reported. The IAQM guidance (again non – statutory guidance) for ‘Land-Use Planning & Development Control: Planning for Air Quality’ is guidance SBC uses for the assessment of significance of air quality impacts from proposed developments within its jurisdiction. It is acknowledged that this guidance is not intended to ‘replace’ existing guidance that HE have prepared in the form of a series of advice notes on assessing impacts and risk of non-compliance with limit values.

Table 2: Slough Residential Receptors affected by breaches of the National Air Quality Objectives year of opening (2022) annual mean N02 Receptor 2013 LTT 2022 LTT 2022 Change HE SBC EU Limit ID Base Do- Do- (ìg/m³) Significance Significance Value NO2 Minimum Something IAN 174/13 IAQM Breached (ìg/m³) NO2 (ìg/m³) NO2 (ìg/m³) guidance With Scheme X30 50.8 38.7 40.0 1.3 Small Moderate YES A247 51.6 39.4 40.7 1.3 Small Moderate YES A248 51.5 39.3 40.6 1.3 Small Moderate YES A249 51.6 39.4 40.8 1.4 Small Moderate YES A250 51.9 39.6 41.0 1.4 Small Moderate YES A251 52.2 39.9 41.2 1.3 Small Moderate YES A252 52.6 40.2 41.6 1.4 Small Moderate YES A253 53.1 40.6 42.0 1.4 Small Moderate YES A254 51.5 39.3 40.6 1.3 Small Moderate YES A322 53.6 40.8 42.5 1.8 Small Moderate YES A322_1 53.1 40.3 42.1 1.8 Small Moderate YES

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3.33. However, it is worth the ExA noting the descriptor of significance attached to both sets of non-statutory guidance and to understand why SBC are concerned about the magnitude changes in air quality levels predicted at the time of operation 2022 as well as the non- compliance with EU limits.

3.34. SBC consultants Ricardo-AEA modelling results are provided on a separate an excel datasheet (relating to monitoring positions and selected residential receptors) using different height barriers and speed scenarios in order to achieve compliance with EU limits

(reductions are shown as % reduction of N02 for different barrier heights at different locations): see Appendix 2. These are summarised with in Table 3 below with respect to the receptors URS have identified that may be breached at year of opening (2022) within Slough. It can be seen from the results that if traffic is maintained at a free flowing speed of 50mph compliance will be achieved at all residential locations. It can be seen that 6m high barriers would afford sufficient protection to all residential properties affected by elevated levels of N02. The model can be refined further if HE release all model input files to SBC’s consultants so that maps can be reproduced with mitigation in place for different height barriers.

Table 3: Slough Residential Receptors affected by breaches of the National Air Quality Objectives year of opening (2022) annual mean N02 - barrier heights Receptor Site Details 2013 LTT 2022 LTT 2022 Change Barrier Change EU Limit ID Base Do- Do- (ug/m³) Height to (ug/m3) Value NO2 Minimum Something reach Breached (ug/m³) NO2 NO2 compliance With (ug/m³) (ug/m³) with EU Mitigation limit X30 Paxton 50.8 38.7 40.0 1.3 2m -0.3 (39.7) NO Avenue A247 Spackmans 51.6 39.4 40.7 1.3 6m -1.3 (39.4) NO Way A248 Spackmans 51.5 39.3 40.6 1.3 6m -1.3 (39.3) NO Way A249 Spackmans 51.6 39.4 40.8 1.4 6m -1.3 NO Way A250 Spackmans 51.9 39.6 41.0 1.4 6m -1.3 NO Way A251 Spackmans 52.2 39.9 41.2 1.3 6m -1.3 NO Way A252 Spackmans 52.6 40.2 41.6 1.4 6m -1.3 NO Way A253 Spackmans 53.1 40.6 42.0 1.4 6m -1.3 NO Way A254 Spackmans 51.5 39.3 40.6 1.3 6m -1.3 NO Way A322 Winvale 53.6 40.8 42.5 1.8 6m -3.6 (38.9) NO A322_1 Winvale 53.1 40.3 42.1 1.8 6m -3.6 (38.5) NO

3.35. SBC respectfully requests that the ExA gives due consideration to these mitigation options (use of barriers and/or speed control) and considers applying them within the DCO.

3.36. Finally, with respect of operational impacts from the M4 Smart Motorway SBC is of the view that HE should install a continuous N0x analyser at an agreed location within the Borough,

close to its residential receptors and the M4 (within AQMA 1) to monitor NOX and N02 levels

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over a minimum period of 10 years from the date of consent to determine compliance with the UK National Air Quality Objectives. The ExA is requested to give due consideration to this requirement.

3.37. HE has a duty to ensure the impact of its strategic road network does not give rise to harm to public health and shall seek compliance with the EU limit values within the shortest possible time.

Construction Phase

3.38. The HE assessment methodology uses DMRB guidance to assess significant effects. SBC would advocate the use of IAQM Guidance on the assessment of dust from demolition and construction and recommend this approach be used to inform the final Construction and Environmental Management Plan (CEMP).

3.39. The consideration of construction dust is based on the approach set out in DMRB. Sensitive receptors located along the Scheme that may be adversely affected during the construction phase have been identified. Where there are sensitive receptors within 200m of construction compounds or bridge works, additional site specific mitigation measures have been recommended (see Appendix 6.1, table 6.1.2) and this is acceptable.

3.40. Preliminary estimates of the construction traffic presented in the EDR indicate that on average it is expected that there will be an additional 150 HGVs on the local highway network daily, across the length of the Scheme route and between any construction compounds used. The HE criterion for a potentially affected local route in relation to construction HGV traffic is a change of more than 200 HGVs per day. The additional number of HGV movements predicted for the Scheme is below this threshold and is not considered therefore by HE to be high enough to have the potential to cause a significant adverse effect at any sensitive receptors. Therefore, construction phase emissions from additional HGV movements have not considered further within HE’s assessment because it is concluded that the effect on sensitive receptors will be not significant.

3.41. SBC does not accept this position with respect to construction HGV movements within Slough’s AQMAs. Proposed Compound 9 has been sited within AQMA 2 Brands Hill and SBC is concerned that HGV traffic generated by this site would further deteriorate air quality levels within the Brands Hill area and jeopardise compliance by 2020. SBC therefore considers that Compound 9 should be removed from the list of potential compounds n air quality grounds.

3.42. SBC considers that all construction site traffic (HDVs) should be Euro VI compliant and LDVs Euro 6 compliant with 10% plugged in and electric hybrid vehicles to be used. SBC would expect non-road mobile construction machinery to comply with London NRMM standards for emissions.

3.43. In relation to the ExA’s question about the 200m study area for construction phase traffic effects SBC would expect this buffer to extend around the construction compounds and along construction routes along the local road network.

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Noise and vibration

Operational Scheme

3.44. Road traffic noise is the most pervasive environmental noise source in the UK and affects more than 92% of dwellings in England and Wales, 2% are affected by motorway noise, and prolonged exposure to high levels of road traffic noise can give cause to harm to public health through impact on cognitive processing and learning, particularly children, heightened annoyance, anxiety and stress which may lead to cardiovascular disease.

3.45. The European Noise Directive (2002/49/EC) aims are to “define a common approach intended to avoid, prevent or reduce on a prioritised basis the harmful effects, including annoyance, due to the exposure to environmental noise”. The Directive Member States are to monitor environmental noise problems (using the Lden and Lnight), informing and consulting the public about noise exposure and its effects, addressing local noise issues (no limit value is currently defined, unlike for air quality) and developing a long-term EU strategy (principally aimed at reducing the number of people affected by noise in the longer term). Member States are required to draw up ‘strategic noise maps for major roads, railways, airports and agglomerations. These were enshrined within English Legislation under the Environmental Noise (England) Regulations 2006, as amended.

3.46. For new or improved highways, the Land Compensation Act 1973 allowed regulations to be promulgated to provide compensation for dwellings affected by increased noise. These regulations are the Noise Insulation Regulations 1975, as amended 1988. If certain criteria are met, the highway authority must offer secondary glazing and alternative ventilation for habitable rooms of dwellings so affected. This relates to new highway or altered highways where additional carriageway is being constructed. Properties within 300m of the highway will be eligible if the use of a highway causes or is expected to cause noise at a level not less

than the specified level L 10 (18-hour) of 68dB(A) if:

(a) the relevant noise level is greater by at least 1dB(A) than the prevailing noise level and is not less than the specified level, and

(b) noise caused or expected to be caused by traffic using or expected to use that highway makes an effective contribution to the relevant noise level of at least 1dB(A).

3.47. DEFRA has also adopted a Noise Action Plan to reduce road noise (including major roads. The Action Plan aims to promote good health and good quality of life (wellbeing) through the effective management of noise. This Action Plan will be relevant to highways authorities, including HE and it is intended that it will assist the management of environmental noise in the context of Government policy on sustainable development. It has been estimated that the approximate number of people associated with the Important Areas (noise “hotspots”) identified through the process described in the Action Plan for the major roads outside agglomerations is just under 51,000. However the Important Area is not defined but is likely to be close to the specified level quote above. It is noted the last round of noise mapping took place in 2012 and the next round in 2017 will need to take account of the increase capacity on the M4 when it is fully operational in 2022.

3.48. The M4 has been strategically noise mapped and there are a number of noise hotspots identified these are referred to under DEFRA guidance ‘Important Areas’. Within the Slough

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jurisdiction there are 8 ‘Important Areas’. HE has submitted plans to reduce the road traffic noise (including the use of noise barriers, and low noise surfacing).

3.49. It is noted that calculated noise levels within Slough are quite high: M12 Hoylake Close is calculated to have L 10 (18-hour) of 69dB(A); M13 Cooper Way to have L 10 (18-hour) of 63dB(A); M14 Winvale to have L 10 (18-hour) of 66dB(A); and M17 Severn Crescent to have L 10 (18-hour) of 70dB(A). The monitored noise levels are within 1Db at Winvale and Severn Crescent. The difference at Cooper Way and Hoylake Close suggests the monitoring location was not appropriate or shielded from road traffic noise. This does raise issues over the robustness of the noise model used.

3.50. The World Health Organisation (WHO) has recommended a night time noise guidelines of

Lnight, outside 40 dB and an interim target of Lnight, outside 55 dB. The latest DEFRA Action Plan

advises that just less than 1 million people in England experience road traffic noise Lnight, outside above 55 dB. The onset of significant community annoyance in the daytime is

observed above levels of Leq, 16 hours 55 dB. The DEFRA Action Plan identifies more than 2 million people experience road noise above this level.

3.51. Exposure to elevated levels of road traffic noise directly links to public health outcomes. HE needs to ensure that if the Scheme leads to an increase in noise levels above EU limits, mitigation is required to prevent unacceptable exposure to residents.

3.52. It is noted within the noise study that 44,259 residential properties and 69 schools, 52 places of worship, 59 community facilities and 1 hospital lie within 1km of the Scheme. All of these are considered sensitive receptors. A do-nothing and do-something assessment has been undertaken to compare the existing with proposed scheme. It is noted the EU does not specify noise limits.

3.53. SBC assumes the entire stretch of the M4 between junction 3 and 12 would be resurfaced with a low-noise surface rather than just the re-surfacing of the existing hard shoulder and far-side lane. Confirmation of this is requested.

3.54. Future baseline conditions consider ‘do minimum’ traffic noise levels and the change from the opening year (2022) to future assessment year (2037). It is noted when comparing the long term change in traffic noise levels between 2022 and 2037 there is an increase in

daytime noise level between 0.1-2.9 dB L 10 (18-hour) at 2,954 dwellings and at night-time Lnight, outside of 1179 dwellings. Most dwellings are expected by HE to experience a slight improvement in traffic noise because of low-noise surfaces. SBC is not convinced on this point.

3.55. It is noted seven properties would experience a minor increase in road traffic noise levels as a result of the Scheme against the ‘do minimum scenario’ and 27% experience a negligible increase in noise when comparing the opening year of scheme with existing. When comparing 2037 (Scheme open 15 years) against the ‘do minimum’ of 2022, 29% of residents experience a negligible increase.

3.56. Between Junction 7 and 6 there are 6,878 residential properties lying within 1km of the motorway. It is understood that one additional noise barrier is to be erected with 5 existing noise barriers and low noise surfaces of the carriageway already in place. The section between Junction 6 and 5 has 6,450 residential properties within 1km of the M4 and noise reduction measures appear to consist of 5 additional noise barriers and low noise surfacing

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of two sections of the carriageway. A total of 3,012 residential properties lie within 1km of the motorway between Junction 5 and 4b with measures focusing on 7 existing noise barriers and 5 sections with low-noise surfacing.

3.57. It is clear that the M4 with or without the Scheme exposes significant numbers of residents

above the WHO interim target of Lnight, outside 55 dB level; there is clear evidence of impacts to public health above this level. The motorway is noisy and has 8 Important Areas within the Slough jurisdiction that require noise mitigation even without the Scheme. There is a requirement on HE under the DEFRA Noise Action Plan to take steps to minimise noise in the Borough.

3.58. The following environmental noise information is required :

 clarification of all Slough residential properties that may be entitled to noise compensation or insulation under the Land Compensation Act 1973 and the Noise Insulation Regulations 19759, as amended 1988; and

 a significant number of properties are expected by HE to experience what is termed a negligible increase of more than 1dB as a result of the Scheme, but how many will also

experience the specified level of L 10 (18-hour) of 68dB(A)?

Construction Phase

3.59. SBC notes the outline Construction Environmental Management Plan (CEMP) but is particularly concerned about the impact of piling operations (noise and vibration), night time noise impact from construction activities and dust impact to our residents in Slough and questions whether the outline CEMP as drafted is sufficiently robust on these issues. The HE detailed noise assessment of demolition, piling and construction is based on BS5228 guidance and references. A detailed noise management plan (page 88 to 99 of the Outline CEMP, Appendix 4.2A) includes noise limits and noise monitoring.

3.60. In Appendix 12.3 (APP-349) ‘construction noise data and results’, the assessments suggest a number of Slough’s residential properties would be significantly affected by construction activity particularly in the evening and at night and this gives SBC concern. SBC would want to impose restrictions on evening and night-term working that could adversely harm residential amenities and seeks ways and means through the DCO process to enable such controls to be applied.

Heritage assets

3.61. SBC notes that Table 7.3 of Chapter 7 APP-147 concludes that there would be slight adverse temporary and permanent impacts on the setting of Cippenham Court scheduled monument. This emphasises the need for appropriate mitigation of the works proposed at the Wood Lane overbridge (see paras 3.3, 3.4).

4. ENGINEERING AND DESIGN

4.1. SBC has been consulted on the engineering and design of the Scheme and made comments during the consultation period (APP-096 Engineering & Design applies). Other comments are made below.

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4.2. It is noted that draft DCO Requirement 6 gives scope for the design of the Scheme to be altered subject to approval of SBC as Local Planning Authority but the ExA has questioned its validity. SBC looks forward to clarification of this issue.

Motorway Junctions

4.3. In relation to Junction 7, SBC notes that the proposed works would result in a realignment of the Huntercombe overbridges eastwards. As the finished level of the bridges would be about 1.2m higher than the existing overbridges, the link road and approach embankment would also need to be realigned eastwards. The result would be to bring these structures closer to residential areas in Cippenham, the Mercian Way Recreation Ground and allotment. Given the engineering challenges in replacing the existing Junction 7 bridges whilst maintaining use of the Huntercombe Spur, no objection is raised to this in principle provided appropriate mitigation is put in place (see 3.3, 3.4)

4.4. SBC understands that no significant works are proposed to Junction 6 and the associated bridges except for some widening of slip roads. At Junction 5 the symmetrical widening of the underbridges would be a major undertaking: SBC has no comment on the engineering design but comments are put forward in Section 3 on the environmental impact; in Section 5 on the traffic management and rights of way aspects; and in Section 8 on the relationship of these works with SBC’s SMaRT bus rapid transit scheme.

Overbridges

4.5. The Scheme would mean the replacement of 4 overbridges within the Borough with varying impacts on residents, businesses and road users, especially during the construction phases.

4.6. SBC accepts that offline structures are the most practicable for the Wood Lane and Datchet Road and overbridges. No adverse comments are raised on the engineering designs provided that the horizontal and vertical profiles would satisfactorily tie in with those of the adjacent carriageways and that suitable provision is made for pedestrians and cyclists.

4.7. Bridleway 17 SLO crosses the current Wood Lane overbridge and the new structure would need to be designed to appropriate standards for a bridleway, including parapets with a minimum height of 1.8m, and a footway of sufficient width to allow pedestrians to cross safely off-carriageway (The proposed design in APP-120 indicates two verges and further discussion is invited on these details).

4.8. Beyond the Slough boundary in Datchet Road there are currently laybys and stops for both northbound and southbound bus services. It is not clear to SBC what provision would be made by HE for their relocation as a result of the proposed bridge works.

4.9. The on-line replacement of the Oldway Lane and Old Slade overbridges will be disruptive to rights of way users (see 5.xx) but SBC makes no comments on the design of the new structures provided that sufficient arrangements are made for future rights of way use.

4.10. Although Riding Court overbridge is located outside the Borough, drivers use it to gain access to the A4 and A332 within Slough. SBC considers that consideration should be given to the relocation of the overbridge north- west of its present position to provide better access to the future CEMEX Riding Court Farm sand and gravel extraction site.

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Underbridges

4.11. SBC notes the proposed widening of the Windsor Branch Rail bridge on the southern side and has no adverse comments on the design at this stage subject to the outcome of HE’s review into embankment options (7.7.23 APP-096).

4.12. The proposed works to the two road underbridges at Langley Interchange offer the opportunity for modifying the roundabout to provide bus priorities: this is discussed in Section 8.

5. IMPACT ON ROAD USERS

Traffic Safety and Information

5.1. Given the relatively limited distances between Junctions 5, 6 and 7 and the amount of M4 traffic, especially at peak times, SBC is concerned that the All Lane Running(ALR) proposed in the Scheme would give rise to safety issues and will be interested in the responses from HE to the ExA’s questions on this subject. Incidents on the Slough section of the M4 are unfortunately quite common and collisions can have a major impact, not only to those personally involved but to other road users through delays and congestion.

5.2. SBC submitted comments on the HE’s variable speed management consultation and sought confirmation that the introduction of this regime would result in better incident management and reduce the need to divert M4 traffic onto the local road network. Other points raised by SBC were:  Need for widespread publicity in advance of speed management being introduced to raise awareness and give drivers early warning;  Interaction between variable speed working on the M4 and that on the M25 and M3;  Interaction between Advanced Motorway Indicators/ Variable Message Signs between Junctions 4B and Junction 8/9, i.e. to what extent will speeds be varied between the junctions used by traffic entering/ leaving the M4 at Slough; and  Further consultation requested on information to be displayed on direction signs, e.g. directing HGVs to Slough Trading Estate.

5.3. As well as requesting further discussion about direction signing SBC sees the opportunity for more collaboration between HE and the local highway authorities on wider driver information. SBC has a strategy for deployment of ITS in the Borough and would welcome an exploration of how this could be linked with HE’s ITS proposals for implementing variable speed limits, lane control and variable message signs.

5.4. In carrying out its Network management duty SBC is required to facilitate ‘the expeditious movement of traffic on road networks for which another authority is the traffic authority’. Both SBC and HE therefore have a responsibility to work with each other to achieve this goal including coordination meetings, providing information about planned works and developments, and contacting each other in emergency situations. This includes the potential for the sharing of information for use within the ITS equipment operated by the respective partners. SBC has recently installed a number of state of the art VMS at strategic locations and sharing and displaying information relating to cross-authority traffic movements would have a positive impact for drivers travelling into, through and out of Slough as follows :

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 Northbound on A355 Tuns Lane between the M4 Junction 6 roundabout and the Copthorne roundabout. (Useful information for drivers leaving the M4 and approaching Slough Trading Estate or the town centre);  Westbound on A4 Bath Road towards the Huntercombe Spur roundabout. (Useful information for drivers heading out of Slough on traffic conditions around Junction 7 of the M4); and  Eastbound on A4 Bath Road, approaching the Huntercombe Spur roundabout. (Useful information for drivers approaching a decision point, either to continue on the A4 or to turn onto the Huntercombe Spur link towards Junction 7 of the M4.

5.5. This is all subject to having the ability for data / information to be transferred between systems. Such transfer would have to be automated to be most effective; however some manual intervention would inevitably be required. SBC is therefore very keen to enhance the network management partnership arrangements with HE. Any positive impact on the local area will be maximised by increased commitment from both parties, for example commitments to develop interfaces between the HE and SBC ITS systems and to share data and information to facilitate the development of an ITS strategy and incident management or contingency protocol alongside HE’s operational schedule.

5.6. SBC understand that enforcement of variable mandatory speed limits is planned to be carried out using a combination of gantry-mounted and verge mounted speed enforcement equipment, and traditional enforcement by the Police. As the distances between Junction 5, 6 and 7 are relatively short, SBC considers that average speed enforcement would prove a more effective alternative.

Traffic on Local Roads

Operational Scheme

5.7. As outlined in Section 1 there is a close relationship between traffic movements on the M4 and the local road network, emphasised by the presence of 3 junctions along a relatively short motorway section at Slough. Current experience is that motorway incidents and events lead to congestion which encourages drivers to divert onto local roads through Slough. The aim of the Scheme is to reduce congestion, smooth the flow of traffic to improve journey times and make journeys more reliable. SBC remains unconvinced that this aim can be achieved without some knock-on effect on local roads, taking into account the forecast increase in M4 traffic. Some of this increase, at least, is likely to be generated by traffic accessing the motorway at Junction 5, 6 or 7 – all involving use of the A4 and/ or A355. SBC is not aware that a quantitative assessment has been made by HE of the impact of the Scheme on local roads, i.e. consideration of the net effect of indirectly encouraging car use which could present additional local car journeys as residents enter/exit the M4. Another issue is the impact on non-motorised road users as a result of this effect and also during diversions in the case of an incident.

5.8. In APP-153 HE make however a qualitative assessment of ‘driver stress’ on local roads that feed in to the M4. Table 13.8 suggests that stress is currently ‘high’ on:  Junction 7 M4 Huntercombe Spur northbound;  Junction 6 A355 Tuns Lane northbound; and  Junction 5 A4 London Road/Colnbrook Bypass west and eastbound to/from Heathrow.

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5.9. Table 13.27 foresees no change in stress by 2037 on these roads with or without the Scheme. Stress levels on the A355 Tuns Lane southbound to Junction 6 are shown to go up from ‘low’ to ‘moderate’. On the A4 London Road between Junction 5 and Slough town centre stress levels are expected to remain ‘moderate’.

5.10. In December 2015 SBC are planning to begin implementation of the ‘A355 Route Enhancement scheme’ aimed at reducing congestion and improving safety along A355 Tuns Lane between Junction 6 and the A4 in Slough and the main access to Slough Trading Estate. This scheme has the support of the Thames Valley Local Enterprise Partnership and features in the Strategic Economic Plan for Thames Valley Berkshire. Most of the funding for the scheme is being provided from the Local Growth Fund. The A355 scheme includes the remodelling of the Copthorne roundabout (located between Junction 6 and the A4 Bath Road), signal and junction upgrades and selected widening.

5.11. Between the Copthorne roundabout and Junction 6 SBC will be implementing a 30mph speed limit. The traffic signals at the motorway junction are currently operated by Reading Borough Council and maintained by SBC. Microprocessor Optimised Vehicle Actuation (‘MOVA’) is being installed and SBC is seeking to take over the operation of the system. It is understood that HE will continue ramp metering for both east and westbound traffic. Through coordination with HE SBC is seeking to ensure the smooth running of traffic between Junction 6 and the A355 in Slough, particularly for ‘high stress’ northbound movements.

5.12. The traffic signals at Junction 5 are also currently operated by Reading Borough Council and maintained by SBC. As with Junction 6, SBC sees it essential as local highway authority to have the means to manage traffic flows at this important roundabout and coordinate with ramp metering by HE which it is understood will continue for westbound M4 traffic. East of this roundabout the ‘high stress’ A4 London Road/ Colnbrook Bypass is an important connection to , representing the strategic interface between the M4 and the local road network. (The A4 is also the route of the SMaRT bus rapid transit scheme- see 8.4, 8.5.

Construction Phase

5.13. SBC notes that the construction phase on the M4 ‘main line’ will involve narrowing lanes and a 50 mph speed limit: this may encourage some drivers to divert from the motorway on to the local road network. SBC would seek cooperation from HE to discourage this. Shuttle working is proposed for the M4 Huntercombe Spur overbridge and slip road works and SBC is concerned about the potential impact on traffic movements at its intersection with A4 Bath Road. This is especially the case if the shuttle working were to continue throughout the duration of the reconstruction works which it is understood could last for 26 months.

5.14. The duration of the Huntercombe Spur works and planned dates for start and completion are however unclear and SBC has identified a number of differences between the programme put forward for bridge and other works in the Outline Construction Programme (APP-107) and the details set out in other documents (e.g. APP-153). It is acknowledged that detailed programming would be continually refined but greater clarity is essential at this stage so that the likely impact on the local road network can be assessed, bearing in mind the other major infrastructure schemes planned for the Slough area- see 8.1, 8.2.

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5.15. The proposed shuttle working during construction of the new Datchet Road overbridge (potentially lasting 20 months) has the potential to create significant journey delays on the B376 which links Slough to Datchet, Old Windsor and Staines.

5.16. At the Langley Interchange reference is made in Table 13.20 of APP-153 to the narrowing of lanes on the M4 ‘main line’ during widening of the underbridges and the outline programme (APP-107) suggests that these works could last for 12 months. SBC is unclear how these works would affect traffic movements on the Junction 5 roundabout and is concerned about potential increases in congestion and journey delays on the A4 and B470 that could arise from traffic management proposals.

5.17. HE foresee construction of the Scheme giving rise to some 150,000 two way HGV movements, averaging 150 vehicles per day over the estimated 1000 working days of the project. Without some indication of the routes that would be needed for HGV movements it is difficult to judge the likely impact on the local road network. SBC acknowledges that this would partly depend on the location of Construction Compounds, the use to which they would be put (including the siting of the main office) and the duration of their operation. It is understood that these issues would be left to the future contractor to address: this is unhelpful particularly in the light of other major schemes in the area which are due to generate significant HGV flows- see Section 8.

5.18. Proposed Construction Compound No. 9 is located within the Borough and SBC notes that the DCO boundary extends along Sutton Lane: the reason for this is not clear. HGV movements along Sutton Lane and the A4 London Road/ Colnbrook Bypass are already significant and have an adverse impact on the amenities of local residents including air quality (the Brands Hill Air Quality Management Area). SBC is concerned that HGV flows to and from a compound in this location would exacerbate existing traffic and safety problems in this general area.

5.19. SBC notes the Outline CEMP (APP-293) and draft DCO Requirement 8 relating to a CEMP being submitted for approval to the relevant Local Planning Authority, including a plan for managing traffic. Management of traffic across the local road network would be a challenge, given that most journeys cross administrative boundaries, and SBC is unclear how the CEMP regime would be applied. SBC agrees with the ExA’s questioning the wording of Requirement 8 which would currently allow HE to modify the CEMP once the Scheme had started without seeking the agreement of the Local Planning Authorities and also would offer no commitment to delivery of mitigation measures.

Non-motorised forms of travel

5.20. The Scheme would have an impact on public rights of way in the Borough as a result of closures and diversions. During the construction phase the disturbance to a number of rights of way could extend for lengthy periods. Surveys of non-motorise users have been carried out by HE where public rights of way cross the M4 by overbridges that would be reconstructed on-line. SBC consider that the survey should have been extended to Wood Lane and the Windsor Brach Rail bridges where users could be disadvantaged the works even though they are off-line.

5.21. SBC’s understanding of the effect of individual bridge works is as follows:  Oldway: closure of bridleway SLO 49 and diversion for approx 8 months;

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 Wood Lane: bridleway SLO 17would transfer to the new bridge when completed (approx 20 month period);  Windsor Branch Rail: footpaths SLO 32 and 33a (part of Slough- Windsor cycle route) run on either side of the railway and would be subject to temporary closures;  Recreation Ground (just outside Borough boundary): closure of right of way (including NCN 61) and diversion for approx 8 months;  Langley Interchange: closure of subway (footpath SLO 9) and diversion for approx 12 months; and  Old Slade: closure of footpath Colnbrook with 24 (Colne Valley Trail) and diversion for approx 12 months.

5.22. The closure of the Oldway, Recreation Ground and Old Slade overbridges for on-line replacements would involve inconvenient diversions for users over lengthy periods. Potential diversionary routes are outlined by HE and it is proposed that the details be left to be resolved by the CEMP under draft DCO Requirement No. 8. SBC considers that leaving all details to that later stage would be unreasonable and put users at a disadvantage. As found by the HE user survey these rights of way are of value to local communities with some, like the Langley Interchange subway and Recreation Ground overbridge, very well used with significant numbers of children, school pupils and cyclists as well as adult pedestrians.

5.23. SBC takes the view that changes to the use of rights of ways that would be caused by the Scheme should be considered in a more comprehensive way. Improvement works for example are likely to be needed to diversionary routes, the cost of which should not have to be borne by the local authority. Such improvements would supplement those already being sought by the local authorities in relation to the new overbridges at Old Slade (designation as a bridleway) and Recreation Ground (NCN 61 cyclepath enhancements).

5.24. Four other issues need to be raised:  Wood Lane: HE propose to maintain access for bridleway and footpath users during construction of the new overbridge: details of these arrangements are needed;  Datchet Road overbridge: arrangements need to be clarified for maintaining access for pedestrians and cyclists across the M4 in the transition from the closure of existing bridge and opening of the new;  Langley Interchange pedestrian subway: HE propose to provide a temporary route for pedestrians and cyclists around the Junction 5 roundabout; this needs to be considered ed as part of the comprehensive investigations called for in 8.5; and  Proposed site for Compound No. 9: development of this site would seriously affect Public Footpath Slough 8 which crosses it diagonally.

6. LAND ACQUISITION

6.1. The Scheme would have an impact on land in statutory allotment use near The Myrke which involves 20 tenanted plots. Statutory allotments close to Huntercombe Spur will also be affected.

6.2. Public open space at Cippenham is located within the Order line and has important boundary trees, embankments, recent tree planting and public rights of way. Other public open space is included within the Order line at Chalvey as is part of the Herschel Local Nature Reserve. Near Recreation Ground bridge is SBC land which forms part of Upton Court Park and is used for motocross purposes.

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6.3. Part of SBC’s Chalvey local authority depot is included in the Order boundary.

6.4. The arrangements for temporary or permanent use of these parcels of land for the Scheme are still under discussion.

7. SOCIO-ECONOMIC ASPECTS

7.1. SBC is one of the 6 Berkshire authorities on the Thames Valley Berkshire Local Enterprise Partnership which produced the Thames Valley Berkshire Strategic Economic Plan (SEP) submitted to the Government in 2014. The SEP strategy document (see RR-040) states that ‘we welcome the planned M4 Smart Motorway Scheme from Junction 3 out to Junction 12, due to start construction in 2016. This should include screening, noise reduction and air quality measures’. The Scheme also features prominently in the SEP Implementation Plan.

7.2. SBC notes from the Socio-Economic Report (APP-090, para 6.2.7) that it is recognised that ‘Increases in traffic along the route of the Scheme are likely in the future as a result of increasing populations and the continued development of housing and employment areas. Traffic congestion is a possible constraint to the further economic development of the sub- region, affecting not only travel to work journeys, but also the attractiveness of the wider area as a place to live and visit’. SBC agrees that future congestion would have a negative impact on the economy of Slough and Thames Valley Berkshire as a whole and that the Scheme has the potential to provide a more reliable and flexible route for commuters, and indeed for all motorists in the area.

7.3. As outlined in para. 5.7 of this report SBC is concerned however that future increases in traffic along the M4 could generate additional traffic movements on the local road network. SBC notes from the Socio-Economic Report (para 6.2.11) that travel-time data has been used to measure the impact of the Scheme on journey times in the hinterland of the ‘Regeneration Areas’ including Slough. This suggests that journey times in the Slough area within the 30-60 minute category might be reduced by 10% but SBC is uncertain on how this conclusion has been reached: further details would be useful.

7.4. In terms of social sustainability the Scheme can be anticipated to make Slough more accessible. By contrast, improving the motorway could work against SBC’s aim of reducing reliance on private car use and encouraging a shift towards more sustainable modes. Making use of the M4 easier and more convenient for car commuters could reduce the relative attractiveness of public transport and active transport (i.e. walking and cycling) alternatives. Any increase in traffic and congestion on linked, local routes including the A4 could delay buses and create further hazards for pedestrians and cyclists. This could discourage use of sustainable travel alternatives, resulting in a reduced level of social inclusion, deteriorating environmental conditions and a downturn in public health.

7.5. Some benefits to pedestrians and cyclists could be provided by the Scheme as outlined in para. 5.23. The Scheme could also contribute to improving public transport by assisting SBC in achieving bus priorities at Junction 5 as described in paras. 8.4 and 8.5.

7.6. The Socio-Economic Report published by HE is fundamentally flawed in its consideration of the impact and effect on modal shift as well as its incomplete and inadequate assessment of behaviour change and attitudinal research. The M4 does not operate in isolation and therefore the impact on the associated road network and local travel behaviour is a key consideration for the granting of a DCO.

22 22 M4 Smart Motorway DCO: Slough Local Impact Report

7.7. In the Socio-Economic Report reference is made to Slough having the highest concentration of SMEs and large businesses, with further reference given to the Slough Trading Estate. In contrast it has the lowest self-containment. This indicates the travel behaviour of individuals who work in the Borough and suggests people who work in Slough travel from other neighbouring areas and further afield. There is thus a significant dis-benefit associated with improving traffic flow and capacity on the M4 as it makes for a more attractive form of travel to and from Slough. This statement is further corroborated when considering the Department for Transports analytical paper, ‘Understanding the drivers of road travel: current trends in and factors behind roads use’, where reference is made to the evidence that despite increased car ownership, people are driving less in urban areas. This correlation is partly due to increased levels of congestion, with further reference made to attitudinal research and the preference for car journeys. https://www.gov.uk/government/publications/understanding-the-drivers-of-road-travel- current-trends-in-and-factors-behind-roads-use

7.8. Mitigating measures are therefore needed to influence an uptake towards sustainable modes of travel, and to encourage and achieve behaviour change during the construction of the M4 Smart scheme in anticipation of its operational launch. These funds can also aide in promotional activity on the use of Smart motorways to residents who are likely to make motorway journeys as part of their daily commute, thus addressing some of the safety concerns mentioned previously. This could also be utilised to raise awareness and support activity to mitigate the negative impact during the construction phase/s of the scheme.

7.9. The contribution from HE for mitigating this effect is suggested to be £22.5 million during a 5 year construction period (taken as 4% of the est. build cost as referenced in the Socio- economic Report) to be divided by junction and the affected local authorities to take a corresponding share of funds for each junction that impacts on their locality. As an alternative mechanism, the amount corresponds to £2.05 million per authority when divided equally or £12.3 million for the Thames Valley Berkshire Local Enterprise Partnership. The circa £410k per annum for each authority will be used to address the issues highlighted in section 7.8.

8. OTHER MATTERS

Scheme Programme and Cumulative Effect of Other Strategic Infrastructure Schemes

8.1. The Socio-Economic Report APP-090 identifies a number of developments in the vicinity of the Scheme under the heading ‘Future Conditions’ in the link-by-link assessment in Section 4. Future developments at the Slough Trading Estate are identified as are Crossrail, the Mayor of London’s ‘Opportunity Areas’ at Heathrow and the Riding Court Farm sand and gravel site (see 4.10 for SBC’s comments on the location of the Riding Court overbridge). SBC believes that consideration of the M4 DCO application should take account of 3 other strategic infrastructure developments:  Western Rail Link to Heathrow scheme (Network Rail project for new rail tunnel, leaving the Great Western Main Line between Langley and , connecting to the airport; subject to public consultation in early 2015; business case now being refreshed for formal DCO application);  Heathrow Express (HEx) depot at Langley (a proposal forming part of the High Speed Rail [London West Midlands] Bill, Additional Provision of July 2015); and  Heathrow North West Runway scheme (recommendation of the Airports Commission Final report, July 2015).

23 23 M4 Smart Motorway DCO: Slough Local Impact Report

8.2. All three schemes directly affect the Borough and, although there are many uncertainties attached each, their future delivery has the potential to coincide with implementation of the M4 Smart Motorway scheme as shown in Table 4 below:

Table 4: Programming of Strategic Infrastructure Schemes Scheme Start of End of Programme Note construction construction Overlap below Rail Western Rail Link to Heathrow Spring/ Summer end 2021 HEX, M4, 1 (WRLtH) 2017 Heathrow HEx Langley depot June 2017 July 2019 WRLtH, M4 2 M4 Smart Motorway J7 to J4b Bridges March 2018 July 2020 WRLtH, HEX, 3 Verge works July 2019 June 2020 Heathrow Central reserve works July 2020 May 2021 Heathrow NW Runway M4/M25 road diversion April 2020 Jan 2024 WRLtH, M4 4 A4 Bath Road diversion April 2020 May 2023 New NW runway Sept 2021 June 2025 New T6A terminal Feb 2023 April 2026 1. National Rail website http://www.networkrail.co.uk/heathrow/ 2. HS2 Hybrid Bill Supplementary Environmental Statement and Additional Provision 2 Environmental Statement July 2015 3. APP-107: HE EDR-Annexes B Outline Construction programme 4. Heathrow Airport Ltd: Technical Appendices 3 submission to Airports Commission (based on Government giving go ahead Sept 2015)

8.3. SBC is concerned about the cumulative effect of these strategic projects and suggested during the Smart Motorway consultation period that the sequence of Scheme activities put forward in the outline construction programme should be reviewed. In the light of recent events (i.e. Airports Commission Final Report and HS2 Bill Additional Provision both published in July this year). SBC believes that this review is more urgent.

Junction 5 Langley Interchange and SBC SMaRT scheme

8.4. Junction 5 at Langley Interchange is the eastern end of Phase 1 of SBC’s SMaRT scheme (Slough Mass Rapid Transit, not to be confused with the Smart Motorway project) which will deliver a dedicated bus lane and enhanced bus services along the A4 corridor between Junction 5, Slough town centre and Slough Trading Estate to the west. This runs roughly parallel to the route of the M4 and will provide commuters with increased opportunity to switch from cars to public transport along this important east-west corridor; this in turn would be expected to improve traffic conditions and air quality. Construction of Phase 1 is programmed to start in December 2015 with funding from the Government’s Local Growth Fund and support from the Thames Valley Berkshire Local Enterprise Partnership.

8.5. Phase 2 is planned to continue SMaRT from Junction 5 to Heathrow to provide a fast attractive public transport link between Slough and the airport. Backing has been received from Thames Valley Berkshire Local Enterprise Partnership and Heathrow Airport Ltd to carry out a feasibility study of Phase 2 as the prelude to preparation of the business case. To connect the SMaRT scheme from Slough to Heathrow means crossing under the M4 using

24 24 M4 Smart Motorway DCO: Slough Local Impact Report

the Junction 5 roundabout. SBC is seeking the cooperation of HE in achieving, as part of the Scheme, an efficient and effective way for buses to pass around this roundabout with minimum delay. This would be regarded by SBC as one of the ‘reasonable opportunities to deliver environmental and social benefits’ foreseen in NN NPS para 3.3 as well as giving due consideration to ‘impacts on local transport networks and policies’ as stated in NN NPS para. 5.211. (See also SBC’s comments on management of traffic signals at this roundabout in 5.10 of this LIR).

8.6. In addition to benefits for public transport at the roundabout SBC considers that there are further opportunities to enhance conditions for pedestrians and cyclists in the vicinity of Langley Interchange. In relation to the right of way that traverses the roundabout the Engineering and Design Report states that ‘the three lanes of the roundabout and the footpaths under the bridge will be kept operational for the bulk of the construction period with only short-term closures anticipated’ (APP-096, 7.8.20). However it is understood that when closures are necessary the aim is to find a suitable surface level diversionary route for pedestrians and cyclists. There may be scope for a route if this kind to become a permanent feature and offering an alternative to the current subway and extensive ramps.

Windsor Branch Line Services

8.7. The Slough- Windsor branch railway is an important link between the two towns and provides essential connections with First Great Western Main Line services to London and Reading. SBC notes that widening works on the railway bridge are programmed to take 27 months but is uncertain about the impact on rail services on the branch line and on Network Rail’s plans for electrification.

Cost of Legal Orders

8.8. A number of Side Road Orders and Public Rights of Way diversion/temporary closure orders will need to be processed, for which the legal and staff costs to SBC will need to be reimbursed by HE.

25 25 M4 Smart Motorway DCO: Slough Local Impact Report

APPENDIX 1 Environmental barriers and air quality

“The air quality benefits at roadside receptors from installation of barriers have been the subject of significant research in recent years and there is little doubt of their benefits in reducing off-road exposure. The recent “Dutch Air Quality Innovation Programme” (1) concluded that “Noise barriers reduce concentrations of nitrogen oxides and airborne particulates along motorways. That is the conclusion drawn by (international) air quality experts based on the measurements obtained during two years of large-scale practical trials.” This work is recognised by Defra as having relevance to the UK and there is no doubt that roadside barriers would have a beneficial effect on air pollution and health outcomes at the most compromised receptors along the M4. Indeed I would suggest that barriers could be an effective solution to existing exceedances of EU Limit Values given the conditions along the M4 through Slough.

Slough Borough Council have instructed me to prepare a screening air quality dispersion model to test the potential benefits of installing such barriers along the M4. The model only seeks to assess the magnitude of benefit and does not seek to mirror the Environmental Statements submitted to date.

The results indicate potential air quality benefits amounting to >10% at some receptors depending on location and barrier height. This is not a trivial reduction (equivalent in exposure terms to reducing road traffic by >10%) and should be explored further, particularly as there remains significant uncertainty in emissions data from the road fleet, and in light diesel vehicles in particular. Diesel vehicles are now known to emit significantly more emissions than previously thought and this should factor into mitigation decisions regardless of the outcomes of dispersion modelling. In my professional experience working for government, industry and Local Authorities in the UK for the past 10 years I am not aware of a single instance of predicted future emissions reductions in the road fleet coming to pass in reality- the reverse is true where NOx emissions have been repeatedly scaled upwards over time to reflect evidence of real world conditions. In basic terms there is good reason to suspect that emissions reductions assumed in the fleet by 2022 (as in the ES) will not transpire in reality, as has been the case in recent years (2).

The results of our initial barrier modelling study are broadly in line with work done in the Netherlands (3). The plot below shows the relative change in concentrations for a perpendicular wind at roadside receptors- the reduction in concentrations is about 15% or more and the benefit extends to quite significant distance from the road. These benefits have the potential to offer significant reductions in exposure to air pollution along the M4 in Slough.

26 26 M4 Smart Motorway DCO: Slough Local Impact Report

Dispersion models are inherently uncertain, and so in light of the continued presence of exceedances along the M4 in 2022 we would suggest that further investigations into the usefulness of roadside barriers is warranted. In fact barriers would seem to offer a safeguard to receptors who could be exposed to more pollution by virtue of sources being moved closer to them under the proposed scheme. Dispersion models submitted with the ES may show that only small changes in exposure are expected but their accuracy in such circumstances is open to debate and under such conditions mitigation can be used to a) protect people from exposure to more pollution and b) offer improvements to even the pre-scheme conditions.

Additionally Slough Borough Council have a statutory duty to reduce air pollution and protect public health so they should seek mitigation in these circumstances where benefits are obvious and scientifically demonstrable- this is one such instance in my view. By providing mitigation in this instance there is potential to not only reduce the impacts of the Smart Motorway scheme itself, but also to reduce the impacts of the motorway in general on the receptors who live at its side.

All discussion provided above apply in principle to NO2, but the same benefits will hold true for PM10, PM2.5, carbon monoxide, black carbon, VOCs, polycyclic aromatic hydrocarbons and a whole range of other less obvious air pollutants which are all emitted by road traffic. Therefore mitigation would additionally protect public health by limiting chronic exposure to these pollutants as well. In my view the health benefits of mitigation could be obscured by focussing solely on NO2 even in instances where exceedances of these other pollutants are not present. For instance demonstrable benefits to health are achieved by reducing exposure to PM10 and PM2.5 even at levels below EU Limit Values (the WHO Guideline Values (4) for these pollutants are significantly below the UK adopted standards- for PM2.5 the annual mean value is 10ugm3 as opposed to 25ugm3 as adopted by Europe and the UK).

Refs (1) http://laqm.defra.gov.uk/documents/Dutch_Air_Quality_Innovation_Programme.pdf (2) http://uk- air.defra.gov.uk/assets/documents/reports/cat05/1108251149_110718_AQ0724_Final_report.pdf

27 27 M4 Smart Motorway DCO: Slough Local Impact Report

(3) http://www2.hoevelakenbereikbaar.nl/MilieuZaken/luchtkwaliteit/Examples-air-quality- measures-near-roads-in-europe-200507.pdf (4) http://apps.who.int/iris/bitstream/10665/69477/1/WHO_SDE_PHE_OEH_06.02_eng.pdf

Dr Scott Hamilton Knowledge Leader Urban Scale Air Quality Modelling and Assessments ------Email: [email protected] Direct Dial: +44 (0)1235 753 716 Mobile: +44 (0)7968 707 112 Reception: +44 (0)1235 753 000

Ricardo Energy & Environment 18 Blythswood Square, Glasgow, G2 4BG, UK Website: ee.ricardo.com

28 28 M4 SMART MOTORWAY DCO APPLICATION: SLOUGH LOCAL IMPACT REPORT - APPENDIX 2 NO2 Effect of barriers and speed controls for residential receptors 2m barrier % 4m barrier % 6m barrier % 8m barrier % NO2 NO2 NO2 NO2 10mph 30mph 50mph 60mph Receptor x y base NO2 2m barrier 4m barrier 6m barrier 8m barrier reduction reduction2 reduction3 reduction4 NO2 NO2 NO2 NO2 SLH 7 496562 179109 36.2 35.8 35.3 34.5 33.7 1.0 3.0 5.0 7.0 45.4 34.8 33.3 34.9 Chalvey (CAS) 496562 179109 37.6 37.0 36.2 35.2 34.2 2.0 4.0 6.0 9.0 47.3 36.0 34.4 36.2 Ditton Road 500851 177890 33.4 33.0 32.6 32.0 31.4 1.0 2.0 4.0 6.0 40.8 32.2 33.5 32.3 Grampian Way 501382 178101 34.1 33.7 33.2 32.5 31.8 1.0 3.0 5.0 7.0 41.8 32.7 27.6 33.0 Paxton Avenue 496050 179258 33.3 33.0 32.6 32.0 31.4 1.0 2.0 4.0 6.0 40.5 32.0 30.8 32.2 Spackmans Way 496272 179187 33.3 33.0 32.7 32.0 31.5 1.0 2.0 4.0 6.0 40.5 32.0 30.8 32.2 Torridge Road 501637 177999 36.6 36.3 35.9 35.1 34.4 1.0 2.0 4.0 6.0 47.1 35.5 28.8 35.3 Tweed Road 501518 177882 30.8 30.7 30.6 30.1 29.8 0.0 1.0 2.0 3.0 37.2 30.0 26.2 30.0 Winvale 497488 179090 43.2 42.2 41.0 39.5 38.0 2.0 5.0 9.0 12.0 56.4 41.6 39.4 41.6 MO51 496443 179117 37.8 37.2 36.4 35.4 34.4 2.0 4.0 6.0 9.0 47.4 36.0 34.4 36.3 MO57 497489 179090 43.2 42.1 40.9 39.4 38.0 2.0 5.0 9.0 12.0 56.2 41.5 39.4 41.5 035_URS 501471 177853 30.2 30.1 30.0 29.6 29.3 0.0 1.0 2.0 3.0 36.2 29.4 26.0 29.4 037_URS 500757 178292 23.7 23.7 23.7 23.6 23.6 0.0 0.0 0.0 0.0 24.9 23.5 24.0 23.5 038_URS 497273 179185 30.7 30.5 30.3 29.9 29.5 1.0 1.0 3.0 4.0 36.6 29.8 28.9 29.9 039_URS 496416 179121 38.0 37.3 36.6 35.5 34.5 2.0 4.0 7.0 9.0 47.7 36.2 34.6 36.4 081_URS 497489 179091 42.8 41.8 40.6 39.2 37.8 2.0 5.0 8.0 12.0 55.6 41.2 39.0 41.2 MO61 501789 178069 44.7 44.2 43.5 42.3 41.3 1.0 3.0 5.0 8.0 60.7 43.6 39.7 43.0 036_URS 501261 178056 34.6 34.2 33.7 32.9 32.2 1.0 3.0 5.0 7.0 42.6 33.2 28.1 33.5 077_URS 501262 178110 29.5 29.3 29.1 28.8 28.5 1.0 1.0 2.0 3.0 34.5 28.6 25.9 28.8 Roadside1 501490.4 178006.7 46.0 45.0 43.8 42.0 40.3 2.0 5.0 9.0 12.0 61.9 44.3 32.1 44.0 Roadside2 501606.2 178036.5 46.4 45.4 44.2 42.3 40.5 2.0 5.0 9.0 13.0 62.7 44.8 32.6 44.5 Roadside3 501663.4 178059.2 50.9 49.4 47.6 45.2 42.8 3.0 6.0 11.0 16.0 69.7 49.1 35.3 48.6 Roadside4 501786.3 178097.7 59.7 57.4 54.3 50.3 46.3 4.0 9.0 16.0 23.0 84.9 58.1 63.1 57.2 Roadside5 501460 178105.8 37.8 37.1 36.3 35.2 34.2 2.0 4.0 7.0 9.0 47.5 36.1 29.1 36.4 Roadside6 501377.6 178090.4 35.7 35.1 34.5 33.7 32.9 1.0 3.0 6.0 8.0 44.2 34.1 28.3 34.4 Roadside7 501272 178072.8 32.9 32.5 32.1 31.5 31.0 1.0 2.0 4.0 6.0 39.9 31.6 27.3 31.8 Roadside8 501017.8 177973.1 32.4 32.1 31.7 31.2 30.7 1.0 2.0 4.0 5.0 39.1 31.2 28.5 31.4 Roadside9 500818.7 177875.5 33.4 33.1 32.7 32.0 31.5 1.0 2.0 4.0 6.0 41.0 32.3 35.4 32.4 Roadside10 498595 177827.5 48.5 48.4 48.3 48.0 47.7 0.0 0.0 1.0 2.0 66.1 47.2 44.1 46.6 Roadside11 498367.9 178131.8 41.9 41.2 40.2 38.7 37.3 2.0 4.0 8.0 11.0 55.6 40.7 38.4 40.4 Roadside12 497881.5 178828.3 54.3 52.6 50.5 47.8 45.2 3.0 7.0 12.0 17.0 75.9 53.0 49.2 52.0 Roadside13 497483.9 179081.5 47.7 46.1 44.3 42.2 40.1 3.0 7.0 12.0 16.0 63.1 45.9 43.2 45.8 Roadside14 497192.5 179096 51.5 49.5 47.2 44.6 42.0 4.0 8.0 13.0 18.0 68.5 49.4 46.5 49.3 Roadside15 497300.7 179106.2 45.2 43.8 42.3 40.3 38.4 3.0 7.0 11.0 15.0 59.2 43.4 41.1 43.4 Roadside16 496457.8 179122.2 36.3 35.8 35.2 34.3 33.4 1.0 3.0 6.0 8.0 45.1 34.7 33.2 34.9 Roadside17 496242.2 179191.7 34.0 33.6 33.2 32.5 31.9 1.0 2.0 4.0 6.0 41.5 32.5 31.3 32.7 Roadside18 496060 179247.3 34.2 33.9 33.4 32.7 32.0 1.0 2.0 5.0 6.0 41.9 32.8 31.5 33.0 Roadside19 495875.3 179322.4 32.6 32.4 32.0 31.4 30.9 1.0 2.0 4.0 5.0 39.4 31.4 30.3 31.5 Roadside20 495815.2 179331.3 33.9 33.6 33.1 32.4 31.8 1.0 2.0 4.0 6.0 41.4 32.5 31.3 32.7 Roadside21 495652.6 179386.1 34.1 33.7 33.3 32.6 32.0 1.0 2.0 4.0 6.0 41.7 32.7 31.5 32.9 Roadside22 495368.4 179485.7 34.6 34.3 33.8 33.1 32.5 1.0 2.0 4.0 6.0 42.7 33.4 32.1 33.5 Roadside23 494826.7 179676 33.1 32.8 32.5 31.9 31.3 1.0 2.0 4.0 5.0 40.3 32.0 30.9 32.1 Roadside24 494966.1 179629.6 33.2 32.9 32.6 32.0 31.5 1.0 2.0 4.0 5.0 40.5 32.1 31.0 32.2 Roadside25 494482.2 179794 32.4 32.2 31.9 31.3 30.8 1.0 2.0 3.0 5.0 39.3 31.4 30.4 31.5 Roadside26 494266.2 179856 33.2 32.9 32.5 31.9 31.3 1.0 2.0 4.0 6.0 40.5 32.1 31.0 32.2 Roadside27 494074.2 179917.1 33.1 32.8 32.4 31.8 31.2 1.0 2.0 4.0 6.0 40.4 32.1 30.9 32.2 Roadside28 493606.1 180113.3 25.8 25.7 25.6 25.4 25.3 0.0 1.0 1.0 2.0 28.6 25.4 25.0 25.5 Roadside29 495470.1 179461.9 33.4 33.1 32.8 32.2 31.6 1.0 2.0 4.0 5.0 40.8 32.3 31.1 32.4 Roadside30 495578.9 179424.4 32.9 32.6 32.3 31.8 31.3 1.0 2.0 3.0 5.0 39.9 31.7 30.6 31.8 Roadside31 496334.8 179176 32.7 32.5 32.1 31.5 31.0 1.0 2.0 4.0 5.0 39.5 31.4 30.3 31.6 Roadside32 497155.2 179134 36.3 35.8 35.2 34.3 33.5 1.0 3.0 5.0 8.0 45.5 35.0 33.5 35.1 Roadside33 498248.8 178251.8 35.8 35.5 35.0 34.2 33.4 1.0 2.0 4.0 7.0 45.6 34.8 33.2 34.6 Roadside34 498397.5 178051.4 37.9 37.5 36.9 35.8 34.9 1.0 3.0 5.0 8.0 49.1 36.9 35.0 36.6 Roadside35 498464.7 177866.5 32.8 32.6 32.4 31.8 31.2 1.0 1.0 3.0 5.0 40.7 32.0 30.8 31.9 Roadside36 500392.5 177659.9 35.6 35.1 34.5 33.7 32.9 1.0 3.0 5.0 8.0 44.6 34.4 46.7 34.5 Roadside37 500675.8 177854.5 29.8 29.6 29.5 29.1 28.8 1.0 1.0 2.0 3.0 35.2 29.0 33.9 29.1 Roadside38 500574.6 177781.5 31.6 31.4 31.1 30.6 30.1 1.0 2.0 3.0 5.0 38.1 30.7 38.4 30.8 Roadside39 501304.3 178076.4 33.9 33.5 33.0 32.3 31.7 1.0 3.0 5.0 6.0 41.5 32.5 27.7 32.8 Roadside40 501697.6 178065.8 50.5 49.1 47.4 45.0 42.7 3.0 6.0 11.0 15.0 69.2 48.8 36.2 48.3 Roadside41 501415.7 178107.3 34.8 34.3 33.8 33.0 32.3 1.0 3.0 5.0 7.0 42.8 33.3 27.9 33.6 Roadside42 501852.3 178095.5 51.9 50.5 48.8 46.5 44.2 3.0 6.0 10.0 15.0 73.1 51.2 39.9 50.1 Roadside43 501559.9 178007.8 41.3 40.7 40.0 38.7 37.5 1.0 3.0 6.0 9.0 54.6 39.9 30.2 39.6 Roadside44 501953.9 178067.5 39.6 39.2 38.7 37.6 36.6 1.0 2.0 5.0 8.0 53.3 39.1 30.1 38.5 Roadside45 502221.7 178214.1 43.2 42.1 40.7 39.1 37.5 3.0 6.0 9.0 13.0 57.0 42.1 31.4 42.0 Roadside46 494192.6 179881.2 33.0 32.7 32.3 31.7 31.2 1.0 2.0 4.0 6.0 40.1 31.9 30.8 32.0 Roadside47 494338.7 179833.1 33.2 32.9 32.5 31.9 31.3 1.0 2.0 4.0 6.0 40.4 32.1 31.0 32.2 Roadside48 494433.3 179808.1 32.6 32.4 32.0 31.5 31.0 1.0 2.0 4.0 5.0 39.5 31.6 30.5 31.7 Roadside49 498280.5 178213.8 36.5 36.2 35.7 34.8 33.9 1.0 2.0 5.0 7.0 46.9 35.5 33.9 35.3 Roadside50 498378.1 178096.9 39.5 38.9 38.2 37.0 35.9 1.0 3.0 6.0 9.0 51.7 38.4 36.4 38.1 Roadside51 501725 178045.9 41.7 41.2 40.5 39.3 38.1 1.0 3.0 6.0 9.0 55.6 40.5 33.1 40.1 Roadside52 501631.8 178028.4 42.3 41.7 40.8 39.5 38.2 2.0 4.0 7.0 10.0 56.3 40.9 31.1 40.6 Roadside53 501798.2 178085.4 50.4 49.6 48.7 47.2 45.8 1.0 3.0 6.0 9.0 69.8 49.2 47.2 48.4 Roadside54 501540.7 177996.5 40.0 39.5 38.8 37.7 36.7 1.0 3.0 6.0 8.0 52.5 38.6 29.7 38.4 Roadside55 501614.6 178206.9 29.9 29.7 29.5 29.1 28.8 1.0 1.0 2.0 4.0 35.1 29.0 25.9 29.1 Roadside56 502244.1 178203.5 49.3 48.2 46.9 45.4 44.1 2.0 5.0 8.0 11.0 66.4 48.1 34.3 47.9