Buckinghamshire County Council Written

BUCKINGHAMSHIRE COUNTY COUNCIL

WRITTEN REPRESENTATION

HIGHWAY ENGLAND'S RESPONSE

1. INTRODUCTION

1.1 My name is Christine Urry. I am the Head of Highways Development Management at Buckinghamshire County Council. I have a Bachelor of Arts Degree in Geography, a Master’s of Science in Transport Planning and Management and I am a member of the Charted Institution for Highways and Transportation. I have 7 years’ experience in the field of highway design, transportation planning and traffic engineering

1.2 The principal functions of the Highways Development Management Team are:-

(i) To provide technical advice and recommendations to the Local Planning Authorities and Council on the transport aspects of new development proposals;

(ii) To ensure that where new developments do affect the Highway the impact on highway safety, capacity and inconvenience to road users is not severe;

(iii) To negotiate and secure, where appropriate, developer contributions for "off-site" highway works under Planning Obligation or Highway Agreements;

(iv) To ensure that all new Residential Access Roads and Industrial/Commercial Access Roads comply with the appropriate standards and specification prior to their adoption;

(v) To provide technical advice and recommendations to the Licensing Authority on those applications for Goods Vehicle Operators Licences which adversely affect the interests of the County Council as Highway Authority.

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2. THE PROPOSED SCHEME

2.1 This written statement has been prepared in respect of an application made by Highways England to the Secretary of State for Transport for a Development Consent Order (DCO) under Section 37 of the Planning Act 2008.

2.2 The draft DCO is referred to as The M4 Smart Motorway Junctions 3-12. The Order would grant powers to improve the M4 Motorway to a smart motorway between junctions 3 (Hayes) and junction 12 (Theale).

2.3 The M4 is the main strategic route between London and the west of England, and on to South Wales. The M4 between junctions 3 and 12 carries over 130,000 vehicles per day. The scheme will help relieve congestion by permanently converting the hard shoulder of the M4 to a running lane and using technology that varies speed limits and manages traffic. Signs and signals will be used to inform drivers of conditions on the highway network, when and where variable speed limits are in place, and when lanes are closed.

2.4 The Scheme is some 51 km (32 miles) in length and will have a number of principal elements:

(i) conversion of the hard shoulder to a permanent running lane and, where no hard shoulder is in place at present, the construction of a new lane. This will mainly take place between junction 4b and junction 8/9;

(ii) replacement of overbridge structures where portals are too narrow to accommodate the improved motorway;

(iii) extension of underbridges and other structures such as culverts and subways to accommodate the improved motorway;

(iv) changes to junctions and slip roads needed to accommodate traffic joining and leaving the improved motorway, and to allow use of the hard shoulder as a running lane, as well as allowing "through junction running" ("TJR");

(v) provision of new gantries and signs to allow the motorway to function as a smart motorway with a variable speed limit, and to provide messages to road users; and

(vi) other infrastructure needed for the improved motorway, such as Emergency Refuge Areas (“ERAs”), enhanced communication systems, closed circuit television

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(“CCTV”) and electrical supplies, as well as works to accommodate statutory undertakers' apparatus and other parties who may be affected by the Scheme.

2.5 A draft Statement of Common Ground (SoCG) has been prepared between Highways England (HE) and Buckinghamshire County Council for the purpose of the Examination to be held by the Secretary of State. The draft SoCG considers the items raised by Buckinghamshire County Council in its relevant representation on the application, including highways and transportation issues and sets out those matters on which agreement has been reached.

Highways England's Comment

2.5.1 Highways England confirms that a Statement of Common Ground (“SoCG”) was agreed with Buckinghamshire County Council ("BCC") and signed on 4 November 2015 and will be submitted as part of Deadline III.

2.6 This written statement sets out Buckinghamshire County Council’s concerns, where to date no agreement has been reached with HE. The written statement expands on the joint Local Impact Report submitted by Buckinghamshire County Council and South Bucks District Council.

Highways England's Comment

2.6.1 Highways England confirms receipt of this written statement and the joint Local Impact Report (“LIR”). Responses to the issues raised in this written statement are addressed below. A separate response has been prepared in relation to the LIR submitted by BCC.

3. THE M4 AND SURROUNDING HIGHWAY NETWORK

3.1 The M4 motorway is one of the main strategic route in the south of England. It runs from London through to Wales and carries over 130,000 vehicles per day in places. The M4 forms Buckinghamshire’s border to the east of Slough and bisects Burnham and Dorney, within the county’s boundary.

3.2 The section of the smart motorway proposal which affects roads that are within Buckinghamshire County Council’s jurisdiction is between junction 8/9-7 and junctions’ 5- 4b, as shown in figures 1 and 2 below.

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3.3 Bath Road (A4) runs parallel to the M4 and is a strategic road that has a status towards the top of the County Road hierarchy in recognition of its strategic inter-urban purpose. It is currently a highly used A road serving Slough and Maidenhead which carries some 22,000 vehicles per day.

3.4 It should be noted that there have been 37 recorded personal injury accidents along the section of the A4 within Buckinghamshire within the last 3 years.

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3.5 The A355 runs north from Slough to Beaconsfield and the M40 motorway at Junction 2 and fulfils a major north-south connectivity role in the County road network. In recent years it has been used for motorway traffic where there is an incident on the M40 or M4. The A355 between Slough and Beaconsfield typically carries some 21,000 vehicles per day, reflecting the strategic nature of the route.

3.6 It should be noted that there have been 27 recorded personal injury accidents on the A355 between the county’s border with Slough and its junction with the M40 within the last 3 years, of which 2 have resulted in fatalities.

3.7 Both of these routes currently experience problems with capacity and delay which has not been acknowledged by HE. The County Council is aware from work undertaken as part of a number of recent planning applications along the A4 corridor that several junctions are experiencing problems with capacity and delay.

Highways England's Comment

3.7.1 Highways England notes the above points, regarding the local road network in BCC's district, which are the responsibility of BCC to administer as the local highway authority.

3.8 Table 1 shows extracts of the modelling outputs used to inform the assessment of the planning applications for the Bishop Centre (planning application reference 11/01625/FUL) and Mill Lane Taplow (15/01039/FUL and 15/01041).

3.9 The Bishops Centre is a new commercial development containing A1, A2 and A5 use classes. The site has been fully constructed and has been operational for over a year. The permissions

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on Mill Lane for 141 dwellings and 40 retirement units have only recently granted by South Bucks District Council and are subject to a Section 106 Agreement.

3.10 The above table highlights that in the network peaks, junctions along the A4 Bath Road are operating over capacity, leading to queues and delay (particularly in the westbound traffic direction). These results should be used as an indication of traffic conditions on the A4 Bath Road, taking into account committed development and forecasted traffic growth at the time of assessment.

Highways England's Comment

3.10.1 Highways England is not able to comment specifically on the data in the Tables above, as it is unclear how the data has been derived, and whether, for example,

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mitigation measures have been included in the assessments to address the impacts of the respective developments. However, both of the two developments concerned were included in the traffic forecasts, based on information obtained from South Bucks District Council (“SBDC”), as the local planning authority. In the case of the Bishops Centre, allowance was made for 9000 sq m of retail space. For the Mill Lane site in Taplow an allowance has been made in the traffic model for up to 200 houses based on information from SBDC. Accordingly, the traffic model has taken these developments into account as part of the cumulative assessment and the associated trip generations included in the background growth.

3.11 The County Council has been lobbied hard about traffic conditions on the A4 and A355 from local Parish Council’s and actions groups such as the Taplow Society. Residents of Buckinghamshire will expect the County Council to represent the interests of its residents in seeking to ensure that proposals do not temporarily or permanently lead to a further deterioration of conditions on these key routes. However, it will be seen from later parts of this Statement that no such information has been provided by the HE.

Highways England's Comment

3.11.1 The County Council has requested to be advised of the effects of the Scheme on the A4 and A355 routes within Buckinghamshire. Highways England notes these concerns raised by the County Council and has addressed this issue with the provision of additional information at paragraph 4.15.1.

4. CHANGES IN TRAVEL PATTERNS

Construction Impacts

4.1 Chapter 13 of the Environmental Statement (ES) prepared by HE “Effects on all Travellers” includes an indicative assessment of the likely traffic impacts of construction on the operation of the M4. An assessment year of 2018 was considered as this is likely to be the time when traffic management has been introduced to substantial portions of the M4 to support the construction works.

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4.2 The tables below (13.12 and 13.13 of the ES) consider predicted driver stress by eastbound M4 drivers for the construction assessment year. The tables consider a ‘do minimum’ scenario (without scheme) and a ‘do something scenario’ (with scheme)

4.3 The results show a reduction in average peak hourly flow per lane and average journey speeds during the construction period as a result of traffic management on the M4, including the use of narrow lanes and reduced lane speeds. A similar situation is predicted in the westbound traffic direction, as denoted in tables 13.14 and 13.14 of the ES.

4.4 The reduction in peak hourly flows, suggests that vehicles are likely to be displaced from the M4 onto routes that adjoin or run parallel to the motorway. The ES acknowledges that other non-motorway links could be affected during the construction period however this has not been quantified and the impact on network performance untested.

Highways England's Comment

4.4.1 Chapter 13 of the Environmental Statement (“ES”) (Application Document Reference 6-1) assesses the impact of the Scheme on driver stress, which includes an assessment of speed flow changes that will result from the construction and operation of the Scheme, as required under the Design Manual for Roads and Bridges (“DMRB”) methodology.

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4.4.2 The minimum requirements for the assessment to comply with DMRB are to compare a base year with a scenario equivalent to the worst case year 15 years after scheme opening, in this case 2037. For the assessment undertaken for the ES, a single year (2018) was selected to provide a representative assessment when the Scheme would be partially constructed. By definition, this assessment does not purport to provide a comprehensive assessment of all potential construction impacts; as stated later at paragraph 13.7.1 it is an indicative assessment and further in paragraph 13.7.2 that the net result from applying the methodology was beneficial and therefore counter-intuitive. As such professional judgement was applied in recording an adverse impact.

4.4.3 The effects of the proposed traffic management regime and phasing of the works during the construction of the Scheme on road users is described in paragraphs 8.3.1 to 8.3.6 of the Engineering and Design Report (“EDR”) (Application Document Reference 7-3). To assess the possible effect of the construction traffic management on users of the M4 the Highways England bespoke software program QUADRO (QUeues And Delays at ROadworks) was run. Analysis of the delays predicted by the program shows that the delays arising from the additional time to travel through the works during the first phase of works reached a maximum predicted journey time extension of 10 minutes in each of the Monday – Thursday peak periods. Only during the Friday PM peak in the westbound direction do journey extensions exceed 10 minutes and queues occur.

4.4.4 During phase 2 of the works, the capacity of three narrow lanes is exceeded during peak periods between junctions 3 and 4 and between junctions 5 and 6. The initial effect as capacity is reached is that vehicles will start to queue but there is the risk that diversion to other routes may occur. Should all vehicles above the capacity limit choose to divert, the potential level of diversion as assessed by QUADRO is limited in number, totalling 106 vehicles per day two- way Monday to Thursday between junctions 3 and 4 and a total of 296 vehicles per day two-way Monday to Thursday between junctions 5 and 6.

4.4.5 The assessment that a limited amount of traffic diversion will occur during the construction of the Scheme is also reinforced by a comparison of traffic flow data captured during roadworks on the M4 in 2014. Two sets of works were undertaken – resurfacing between junctions 8/9 and 10 and bridge works between junctions 10 and 11, each using 3 narrow lanes of traffic management.

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Comparisons were made between traffic flows over the period May to September during which the works were carried out and the same period the previous year using data from Highways England’s Traffic Flow Data System (“TRADS”). The comparisons showed that flows in 2014 were marginally lower than the preceding year only during the peak periods. During the remainder of the day outside the peaks, flows in 2014 were typically 2-3% higher than 2013. This suggested that if diversion was occurring, it was limited to the peak periods.

4.5 Tables 4 and 5 (13.4 and 13.5 of the ES), identify possible alternative routes for vehicles during the construction period. Those in the jurisdiction of Buckinghamshire County Council are as follows:

Highways England's Comment

4.5.1 As explained above, a detailed assessment has been undertaken of the level of diversion that can be expected to occur as a result of the Scheme onto the local

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road network. The subsequent driver stress assessment reported in chapter 13 of the ES included all the roads listed in Tables 4 and 5 above (replicated from Tables 13.4 and 13.5 of the ES) and has demonstrated that none of the routes within Tables 4 or 5 would be significantly impacted during the construction of the Scheme.

4.6 The ES does not consider the displacement of vehicles during the construction period or the impact this will have on the operation or safety of the local road network within Buckinghamshire, in particular the A4 and A355. It is essential that this is properly assessed and understood and if appropriate mitigation is proposed to ensure that the works do not have a severe impact on the local highway network.

Highways England's Comment

4.6.1 As explained above, a detailed assessment has been undertaken of the likely displacement of traffic from the M4 onto the local road network, including the A4 and the A355, during the construction of the Scheme. That assessment indicates that there will be no impact on the operation or safety of the A4 or A355 within Buckinghamshire from displaced traffic as a result of the Scheme and accordingly that no mitigation is required.

On the basis of the limited information provided to date it is not possible for the County Council to confirm that the impact of the works will not be severe for users of the A4, A355 or local residents. The construction period is likely to be the period that will have the biggest impacts on the County Council’s highway network.

Highways England's Comment

4.6.2 Additional information on the forecast effects on traffic flows on the A4 and A355 routes has been provided at paragraph 4.15.1 in response to the specific point raised by the County Council. There is a small net increase in flows forecast to occur on the A4 and negligible effect on the A355 route. There are no effects during the construction period on either of these routes. Highways England does not agree that the impact of the works will be severe for either road users or local residents.

Operational Impacts

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4.7 The HE has developed a Variable Demand Model (M3M4DM) and a Highway Assignment Model (M3M3HAM) to assess the impacts of smart motorway operations on both the M3 and M4. The models have been calibrated and validated in accordance with Webtag Guidance for the motorway network.

4.8 The M4 Junction 3-12 Smart Motorway Traffic Forecasting Report, published in October 2014, has assessed a scheme opening year of 2022 and a design year of 2037. The results from the SATURN assignment model indicate that the implementation of the scheme would significantly improve driving conditions along the M4 in the peak periods both in 2022 and 2037.

4.9 Table 6 ( Table C-21 and C22 of the Smart Motorway Traffic Forecasting Report), denotes the volume capacity ratios of the M4 in both 2022 and 2037 with and without the implementation of the scheme:

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4.10 It is anticipated that capacity will be at 95.7% between junctions 8-7 in 2022 ‘do nothing’ scenario for eastbound traffic in the am peak and 99.6% for westbound traffic in the pm peak hour. The motorway network is therefore running close to capacity in these directions during these periods.

Highways England's Comment

4.10.1 The above statement is correct. However, it should be noted that Tables C-21 and C-22 of the Traffic Forecasting Report (which was provided at Appendix 1 to the Response to Relevant Representations at Deadline I), on which Table 6 above is based, illustrate the volume to capacity ratios under the ‘low growth’ scenario (one of three scenarios used to appraise the scheme, each of which reflects varying assumptions on the level of growth in the economy). In contrast, the assessment of the Scheme has been based on the core scenario (a central forecast between high and low growth alternatives), for which the equivalent tables in the Traffic Forecasting Report are A-22 and A-23. The equivalent figure for junctions 8 to 7 in the 2022 ‘do nothing scenario', eastbound in the am peak is 97.0% and for westbound traffic in the pm peak, 100% i.e. with even more severe congestion than is demonstrated in the Tables referred to in the response. These figures demonstrate that in the absence of the Scheme, the motorway network will therefore be running close to or at capacity.

4.11 It is predicted that the implementation of the smart motorway will increase available capacity along the stretch of the M4 between junctions 12 and 3 in both directions during the morning and evening peak hours. It is anticipated that capacity will be at 84.8% between junctions 8-7 in 2022 ‘do something scenario’ for eastbound traffic in the am peak and 86.7% for westbound traffic in the pm peak hour.

4.12 Travel time reductions along the M4 between junctions 1-13 are forecasted to range from 5% (eastbound in the inter peak period) to 11% (westbound in the pm peak) by 2037 as a result of implementing the scheme. The model however forecasts an increase in journey times on sections of the A4 in both 2022 and 2037 modelling periods of up to 3% as a result of implementing the scheme. It should be noted that base year observed, modelled and forecast year journey times are only available for the section of the A4 between Langley and Chiswick (tables C-26 and C-20 of the forecasting report).

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Highways England's Comment

4.12.1 As explained above, the appropriate table to quote for the do-something scenario is Table A-23 in the Traffic Forecasting Report, from which the equivalent figure for the eastbound direction in the am peak between junctions 8 to 7 is 86.6% and for the evening peak in the westbound direction is 88.4%.

4.12.2 Similarly, the journey time comparisons for the core, as opposed to the low growth, scenario are detailed in Tables A-26 to A-29 of the Traffic Forecasting Report. However, the percentage changes summarised by the Council in 4.13 above are identical between the two scenarios.

4.12.3 Whilst it is correct to state that journey times on the A4 do increase by up to 3%, this figure is only applicable to the section between Chiswick and Hounslow in the pm peak in 2037 and arises from an additional 37 vehicles assigned to this link under the do-something scenario during that hour in that year. A more representative summary, drawing on the results for all of the modelled time periods, would be that journey times vary on the sub-sections that make up the A4 between Langley and Chiswick, changing by between a reduction of 2% (between Hounslow and Langley in the pm peak period in 2037 due to a reduction of 29 vehicles in that hour) and the 3% increase in journey time quoted above. In neither case are the flow changes significant in comparison to the total volume of traffic using the A4.

4.13 The ES considers driver stress for the A4 link in table 13.2 and concludes that the effect for users is neutral. This has not been quantified with changes to vehicle flows, queues and journey times and does not consider the above findings of the forecast report.

Highways England's Comment

4.13.1 Taken together, based on the results of the driver stress assessment and the level of changes to flows and journey times described in paragraph 4.13.2 and 4.13.3 above, Highways England considers that a conclusion that the effect on the A4 is neutral to be correct.

4.14 The ES considers driver stress for the approaches to the M4 in table 13.27 and 13.28. The A355S approach from Slough, which links into junction 6 of the M4 is likely to experience an increase in driver stress as a direct result of the scheme implementation from low to

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moderate. No assessment has been undertaken to understand the local highway impacts resulting from this change.

Highways England's Comment

4.14.1 The largest impacts, in numerical terms, on the A355 are likely to occur within Slough, on the approach to junction 6. The traffic model forecasts that on opening of the Scheme in 2022, average peak hourly flows would increase by 186 vehicles, or +5%, which was adjudged (and reported in table 13.27 of the ES) to raise the level of driver stress from low to moderate.

4.15 Further information is required from the HE to understand the implications of the scheme once constructed on the future operation of the A4 and A355. Insufficient information has been provided for Buckinghamshire County Council to assess the impact of the proposal on the local highway network.

Highways England's Comment

4.15.1 Outputs from the M3/M4 traffic model forecasts for the proposed opening year of 2022 have been abstracted and collated in the table below. These show that there is forecast to be a small increase in traffic flows on the A4 within Buckinghamshire and negligible impact on traffic using the A355 route in the County. Highways England considers neither of these impacts will have a material impact on traffic conditions on either route.

Traffic Model Flows by time period on A4 and A355 in Buckinghamshire in Scheme Opening Year: 2022.

Time A4, west of A4094 A355 at Farnham Common A355 at Farnham Royal Period

No With Diff No With Diff No With Diff Scheme Scheme Scheme Scheme Scheme Scheme

Early 1057 1132 +75 1460 1480 +20 1259 1266 +7 AM

AM 1038 1110 +72 1797 1815 +18 1297 1310 +13

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IP 1580 1641 +61 1134 1124 -10 979 977 -2

PM 2225 2227 +52 1870 1875 +5 1374 1377 +3

AADT 21220 21841 +621 18856 18861 +5 15141 15158 +17

AAWT 24391 25105 +714 21673 21678 +5 17404 17423 +19

Key: Early AM: 07.00-08.00; AM: 08.00-09.00; IP: average of 10.00-16.00; PM: 17.00-18.00

AADT: Annual Average Daily Traffic; AAWT: Annual Average Weekday Traffic

5. CONSTRUCTION TRAFFIC MANGEMENT PLAN

5.1 The outline construction traffic management plan (appendix E to the Outline Construction Environmental Management Plan) predominantly focuses on the traffic management requirements associated with the construction of the M4. Little consideration has been paid to the following:

(i) Impact of bridge closures and associated diversion routes

(ii) Impact of construction sites and compounds (access/egress arrangements)

(iii) Impact of construction traffic (volume and routing)

Highways England's Comment

5.1.2 The Construction Traffic Management Plan ("CTMP") that was provided with the application is an outline of what will be the final CTMP (Annex E of the outline Construction Environmental Management Plan (“CEMP”) (Appendix 4.2A of the ES (Application Document Reference 6-3))). The final CTMP for the Scheme will incorporate all issues associated with the impact of the Scheme and the management of vehicular and non-vehicular traffic impacted by the works, including those listed in the response above. The CTMP will be prepared prior to commencing the construction of the works in accordance with requirement 18 at Schedule 2 to the draft Development Consent Order. During its drafting, consultation with key stakeholders will be undertaken, including BCC.

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5.1.3 As per item 13.2.3 within the outline CEMP, the contractor’s dedicated Traffic Management Manager will form a Traffic Management Working Group (“TMWG”) consisting of key stakeholders (incl. BCC) The Traffic Management Manager will arrange TMWG meetings to identify concerns associated with both the main line works and the local network. These concerns will then be considered within the development of the CTMP and will include the diversion routes associated with the bridge closures.

5.2 The Outline Construction Traffic Management Plan does not provide any indications of the impact of additional traffic on the performance, congestion or road safety of the County’s network.

Highways England's Comment

5.2.1 It is not the role of the CTMP to address the impact of the Scheme on the local road network. Those impacts have been assessed and addressed as part of the Environmental Impact Assessment for the Scheme and are reported in the ES and the various reports referred to in the response to this representation. In particular, the effect on Buckinghamshire’s highway network is discussed at chapter 13 of the ES, where it is concluded that the impacts are neutral

5.2.2 In addition, the further modelling work undertaken to assess the effects of traffic management on the M4 during construction of the Scheme have been described in paragraphs 4.4.1 to 4.4.5.

Impact of Bridge Closures and Associated Diversion Routes

5.3 Four bridges are affected within Buckinghamshire County Council’s administrative area:

(i) Thames Bray Bridge- to be widened to the north

(ii) Lake End Road – to be built off-line

(iii) Marsh Lane Bridge – to be built on-line

(iv) Old Slade Bridge – to be built on-line

5.4 Both Marsh Lane and Lake End Road bridges are to be replaced in order to facilitate Smart Motorway operations. Marsh Lane and Lake End Road are the main access roads for Dorney Village together with the local businesses and Eton Dorney Lake, as shown in figure 4.below:

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5.5 Lake End Road is to be built off-line, following representations made during the formal consultation. The HE have agreed in the draft SoCG that works to Lake End Road and Marsh lane will not be undertaken during the same period. Lake End Road bridge is to be constructed first, followed by Marsh Lane bridge as illustrated in the construction programme in Appendix 4.1 of the ES.

5.6 Marsh Lane will be shut whilst a new bridge is constructed on-line between November 2018 and December 2019. The potential diversion route is via Lake End Road/A4 Bath Road and involves a 10km detour. Lake End Road and its junction with the A4 Bath Road will

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experience increased traffic as part of the planned online development of Marsh Lane over a 13 month period. The impact of this diversion route, particularly on the junction of Lake End Road and the A4 Bath Road has not been assessed and Buckinghamshire County Council cannot confirm that it will not be severe.

Highways England's Comment

5.6.1 Highways England does not consider that there would be a significant impact on Marsh Lane or Lake End Road, due to displaced traffic during construction. However, this issue will be examined in further details, in liaison with Buckinghamshire County Council pursuant to the CTMP to ensure that any mitigation measures required during construction are identified.

5.7 Old Slade Lane forms part of the Colne Valley Trail, a prominent series of walkways through the Colne Valley Park. The bridge is therefore primarily used for walkers, cyclists and horse riders with a gate present to stop vehicles crossing.

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5.8 The County Council is currently seeking formal designation of this route to a bridleway to connect Buckinghamshire and South Bucks District Council on the north side of the M4 with Slough Borough Council on the south side.

Highways England's Comment

5.8.1 As stated at 3.16 of the signed and agreed Statement of Common Ground between BCC and the Applicant, "Highways England supports the dedication of a shared use bridleway and will continue to work with these authorities to establish the standards required to enable Old Slade Lane Overbridge to be made suitable for vehicles / pedestrians / horseriders, within the Scheme design and Order limits."

5.9 In the draft SoCG HE has agreed to review the current designation status of the public right of way over the bridge and ensure that the bridge is made suitable for vehicles, pedestrians, cyclists and horse-riders within the scheme design and order limits. No assurance has been

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made that Highways England will dedicate the path as a bridleway, as part of the works to the bridge.

Highways England's Comment

5.9.1 As stated in the SoCG between Highways England and BCC, signed on 4 November 2015, Highways England “supports the dedication of a shared use bridleway and will continue to work with these authorities to establish the standards required to enable Old Slade Lane Overbridge to be made suitable for vehicles / pedestrians / horseriders, within the Scheme design and Order Limits. The proposed design is suitable for shared space, with 1.8m high parapets, which are suitable for equestrians, and a 5m width, as shown in Drawing 11 of the EDR Report, Appendix F Overbridges (Application Reference Document 7-4). Highways England will review the current designation status of the public right of way over the bridge and incorporate this standard into the new bridge as a minimum”.

5.10 Old Slade Bridge is to be closed between November 2017 and December 2018. Due to the nature of the bridge the proposed diversion route is considered to be impractical, requiring a 6km detour. The ES considers the impact of severance in closing Old Slade Bridge to be severe, however no mitigation has been proposed.

Highways England's Comment

5.10.1 As stated in paragraph 13.7.21 of Chapter 13 of the ES, Highways England confirms that the length of the proposed diversion route will be 7.1km.

5.10.2 The impact of severance has been assessed as severe based on the DMRB criterion (Volume 11, Section 3, Part 8, chapter 6, paragraph 6.1) of an increase in journey length of over 500m, however the closure will only take place for a temporary period of 12 months and therefore no further mitigation is proposed.

5.11 Two 12 hour counts of users of the bridge were undertaken on 3 and 6 June 2015, the results of which are appended to Appendix 1 of the draft SoCG. On Wednesday 3 June 2015, a total of 58 people used the bridge (45 adults, 6 children and 7 cyclists) and on Saturday 6 June 2015 44 people were observed using the bridge (35 adults and 9 cyclists).

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Highways England's Comment

5.11.1 Highways England confirms that the above quoted figures are correct, being drawn from the Non-Motorised Users Report of Survey (submitted as Document 3 in Appendix 2 of the submission for Deadline I). As the Non-Motorised Users Report of Survey notes at paragraph 2.2.16: “The majority of users were adults. The numbers indicate that this particular route is lightly used and does not have significant variances between the weekend and weekdays.” No horse riders were observed using the bridge during the surveys.

5.12 Buckinghamshire County Council is of the view that access during bridge construction should be maintained. The HE has suggested that off-line construction of Old Slade Bridge is not viable due to the proximity to the M25 slip roads and presence of a lake, as set out in Table 6 of the Engineering and Design Report (Application Document Reference 7.3). The County Council has suggested the provision of a temporary off-line bridge for use whilst the existing bridge is demolished and re-built in order to mitigate the impact during construction.

Highways England's Comment

5.12.1 Highways England confirms that the on-line solution has been developed to avoid the need for additional land take and to minimise the additional impact of temporary construction works and associated vegetation clearance. As stated in Table 6 of the EDR, there are site constraints at this location due to the M25 slip roads and the presence of a lake at the south-east.

5.12.2 The site constraints which restrict the permanent solution would also apply to a temporary structure and further constraints would arise through having two structures adjacent to each other, i.e. the construction and demolition activities would likely be affected by the reduced working space. Any reduced working space for construction activities would likely extend the construction period for the bridge which in turn would cause disruption to local residents for an extended period of time.

5.12.3 With regards to the form of any potential temporary bridge, it would need to be a single span as the hard shoulder discontinuities under the existing bridge and the proximity of junction 4b slip roads mean that it is not possible to construct a central pier. The single span would therefore have to approximately be 50m, which is towards the upper limit for temporary bridges currently available and

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would likely mean that such a structure would need to be restricted to pedestrian loading only.

5.12.4 Highways England carried out two non-motorised user survey for Old Slade Lane in June 2015. As summarised in Table 1 of the Non-Motorised Users Report of Survey (Document Reference 514451-00-ZZ-RP-TR-400074, provided as Document 3 in Appendix 2 to the Deadline I submission), Old Slade Lane Bridge carried the least number of non-motorised users compared to all other surveys sites over the two days period.

5.12.5 Therefore considering the current usage of Old Slade Lane Bridge, Highways England surmise that providing a temporary off-line bridge alongside the existing bridge for the duration of the construction works would not be a practical solution as it would provide additional construction constraints, a lengthened construction programme and further disruption to all of the local residents for a longer duration.

Impact of Construction Traffic

5.13 The majority of the works will be carried out within the existing M4 corridor however as part of the construction process the contractors are anticipated to use a number of sites for operational processes. Two sites have been identified within Buckinghamshire:

(i) Compound 6 (within junction 7)

(ii) Compound 9 (Colnbrook Landfill Site, Sutton Lane)

5.14 No information has been provided by HE in relation to the likely volume or the proposed routing of construction traffic. This needs to be properly assessed, taking into account the constraints of the local highway network, to ensure that routes are suitable for the proposed levels of traffic. The County Council would expect either temporary or permanent mitigation to be proposed to ensure that the works do not have a severe impact on the operation of the highway network.

Highways England's Comment

5.14.1 Highways England confirms that Construction Compounds 6 and 9 will be used as satellite compounds to locally service the construction of the Scheme.

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5.14.2 Construction Compound 9 will be used for the location of recovery vehicles, storage, welfare and office set up initially to support the bridgeworks to Old Slade Lane, M4 Junction 5 and Riding Court Road Bridge. After completing these bridgeworks, Construction Compound 9 will provide a similar facility for the works to the mainline of the M4 between the M25 and junction 6.

5.14.3 Construction Compound 6 initially will support the replacement of Huntercombe Spur Bridge at junction 7, Oldway Lane Bridge and Lake End Road Bridge. After completing these bridgeworks, Construction Compound 6 will provide a similar facility for the works to the mainline of the M4 between junction 6 and 8/9.

5.14.4 Neither Constructions Compounds 6 nor 9 will be the main construction compound, therefore the levels of traffic are not anticipated to be significant. Further information on the volume and routing of construction traffic will be provided during the Examination after Deadline III.

5.14.5 The routes for traffic accessing these construction compounds will be confirmed in the final CTMP, taking into account the constraints of the local highway network. The routes will be developed in consultation with the local authorities, including BCC, to ensure their suitability, and will include measures to mitigate the impact of the use of these compounds on the local highway network and to ensure that the works do not have a severe impact, as suggested in the response. The measures are likely to include where possible bulk materials will be delivered directly to site. Agreed designated delivery routes will be used by suppliers and sub-contractors. Please refer to 13.8 within the CEMP, for controls and selection of access routes for construction traffic.

5.15 Buckinghamshire County Council has raised the following local areas of concern to HE:

(i) Construction traffic to Old Slade Lane – construction traffic associated with the construction of Old Slade Bridge should be routed via Lakeside Road due to concerns regarding HGV’s using Richings Way and Iver areas to the north.

Highways England's Comment

5.15.2 With regard to the construction traffic to Old Slade Lane, Highways England agrees that if access is available from Lakeside Road then the principal route for the works would be from the South via Lakeside Road. This will be reflected in

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the final CTMP. However, it should be noted that, for the construction of the abutments, access will be via the local networks to the respective sides, North Richings Way and South Lakeside Road. Once the structure has been demolished access can only be gained via the local networks either side of the motorway, access cannot be achieved from the Motorway due to the location of the M25 slip roads.

(i) Access to Compound 9 (Colnbrook Landfill Site, Sutton Lane) – vehicle movements to and from this compound should be restricted to ensure that HGVs vehicles do no use North Park or Richings Way. Vehicles should be routed via London Road (A4) and Sutton Lane.

Highways England's Comment

5.15.3 Highways England confirms that, pending access availability from Lakeside Road, restrictions will be put in place in the final CTMP to ensure that HGVs do not use North Park and Richings Way. Instead, HGVs will be routed via the London Road (A4) and Sutton Lane as suggested in the representation. HGV access will be required on both sides of the bridge to enable construction of the abutments.

(iii) Richings Park and Iver - ongoing consultation with the local Parish Council and further research being undertaken as part of South Bucks District Local Plan identify that there is a popular alternative route for HGV’s through the district from Richings Park to the M40. This route involves the Village Town Centre of Iver, which is already experiencing high volumes of HGVs. The County Council would not wish the scheme to add to this problem either directly or indirectly.

Highways England's Comment

5.15.4 Highways England will endeavour to ensure that Richings Park and Iver are not used for the routing of HGVs, pending access availability from Lakeside Road, and will take BCC's representation on this matter into account in the development of the access routes in the final CTMP.

5.16 Buckinghamshire County Council wishes to enter into routing agreements with HE, to minimise the impact of construction on the local road network and surrounding communities and prevent large vehicles from using unsuitable roads. The agreement would need to detail

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how routing will be monitored and enforced by HE to ensure compliance by contractors and suppliers.

Highways England's Comment

5.16.1 Rather than entering in to a routing agreement Highways England will agree suitable routes for large vehicles and for diversions via agreement of the CTMP, which will also include details of monitoring and enforcement.

5.16.2 Compliance with the CTMP is required pursuant to requirement 18 at Sch. 2 to the DCO. Non-compliance with the CTMP would constitute an offence under s.161 of the PA 2008. As such, Highways England are of the view that a routing agreement should not be required, and these matters are can be appropriately addressed in the CTMP.

5.17 It should be noted that HE has referred the County Council to Schedule 2, Requirement 18 (1) of the Draft DCO which states:

“No authorised development is to commence until a construction traffic management plan, detailing traffic management measures during construction of the authorised development and substantially in accordance with the outline construction traffic management plan annexed to the CEMP, has been submitted to and approved by the relevant planning authority.”

5.18 Schedule 2, Requirement 18 (1) of the Draft DCO does not offer any certainty due to the inadequacies of the Outline Construction Traffic Management Plan that has been submitted.

Highways England's Comment

5.18.1 It is standard practice for an outline CTMP to be submitted with the Application, which will be developed in consultation with appropriate bodies pursuant to a requirement in the DCO. It is not considered that the Outline CTMP submitted with the Application is inadequate to enable the effective development of a final CTMP in accordance with requirement 18. As explained in paragraph 1.1.2 of the Outline CTMP, the document "provides a framework for the methodology for the works, which will enable the final management measures to evolve".

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6. SUMMARY

6.1 This written statement has been produced to outline the concerns of the County Council in relation to highway matters and should be read in conjunction with the Local Impact Report, jointly submitted by South Bucks District Council and Buckinghamshire County Council., and the draft SoCG.

6.2 The County Council needs to ensure that proposals do not temporarily or permanently lead to a further deterioration of conditions, particularly on the A4 or the A355. The County Council is of the view that the Environmental Statement submitted in support of the Development Consent Order does not adequately assess the impact of the proposed smart motorway scheme on the local road network for the following reasons:

(i) The ES does not consider the displacement of vehicles from the M4 onto the local highway network during the construction period or the impact this will have on the operation or safety of Buckinghamshire County Council’s network.

(ii) The Outline Construction Traffic Management Plan does not provide any indications of the impact of additional/diverted traffic on the performance, congestion or road safety of the County’s network.

(iii) No mitigation measures are proposed to address the County Council’s concerns relating to severance or routing.

6.3 It is essential that the impacts of the scheme are properly assessed and understood and if appropriate mitigation is proposed to ensure that works do not have a severe impact on the local highway network.

Highways England's Comment

6.3.1 A detailed response to the matters raised in this summary has been provided in the response above and is not repeated here.

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